2025 (12) TMI 1579

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....C/S/250/2024-25/1067505369(1) arising out of the order dated 30.03.2022 u/s 147 r.w.s 144B of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') passed by the National Faceless Assessment Centre, for AY: 2016-17. 2. Heard and perused the records. The first issue raised was that the reopening reasons are borrowed satisfaction and show non application of mind. Which has been opposed by ld. DR asserting that reopening reasons are self contained. 3. Now what comes up is that the appellant filed his return of income on 29.03.2017 declaring total income Rs 25,59,000; claimed long-term capital gains Rs 1,57,78,700 as exempt under section 10(38) of the Act. Notice dated 31.03.2021 under section 148 of the Act was issued and the c....

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....s relevant is that the appellant purchased 1,00,000 shares of Anax Com Trade Limited on 10.01.2013 for Rs. 1,25,000/- and 2,50,000 shares of Fidelo Power and Infrastructure Limited on 03.04.2014 for Rs. 2,50,000. The aforesaid two companies amalgamated into YICL and on amalgamation of Anax Com Trade Limited with YICL, the appellant received 80,000 shares of YICL and on amalgamation of Fidelo Power and Infrastructure Limited with YICL, the appellant received 2,00,000 shares of YICL. Thus, the purchase consideration of Rs 3,75,000 for 2,80,000 shares in YICL. The appellant sold the shares in YICL on the following dates:- Date No of shares Sale price Sale consideration 09.06.2015 40,000 61.51 24,60,400 12.06.2015 ....