2025 (11) TMI 463

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....or the Department : Ms. Pooja Swaroop, CIT(DR) ORDER PER SATBEER SINGH GODARA, JM This assessee's appeal for assessment year 2017-18, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the "CIT(A)/NFAC"], Delhi's DIN and order no. ITBA/NFAC/S/250/2024-25/1073626545(1), dated 24.02.2025 involving proceedings under section 143(3) of the Income....

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....light of Principal Commissioner of Income Tax vs. Era Infrastructure (India) Ltd. (2022) 448 ITR 674 (Del) that their lordships have already settled the issue in the assessee's favour and against the department that the above statutory amendment does not carry any retrospective effect. Faced with this situation, we hereby quote Cheminvest Ltd. v. Commissioner of Income-tax (CIT) (2015) 378 ITR 33 ....

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....n to its detailed paper-book running into 209 pages contained all of its supportive evidence to discharge the onus of proving genuineness as well as creditworthiness of the impugned share capital coming from M/s. P.R. infrastructure (supra), who happens to be its group/holding company only. 5. Learned counsel, more particularly, invites our attention to the assessee's confirmation of accounts a....