2024 (9) TMI 1860

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....ta Jha, Sr. Adv. with Mr. Himanshu Aggarwal, Mr. Anuroop Chakravarti, Advs. For the Respondent Through: Mr. Abhishek Maratha, SSC along with Mr. Apoorv Agarwal, Mr. Parth Samwal, JSCs, Ms. Nupur Sharma, Mr. Gaurav Singh, Mr. Bhanukaran Singh Jodha, Ms. Muskaan Goel and Mr. Kamakshraj Singh, Advs. ORDER 1. We take note of the following facts that had fallen for our consideration in terms o....

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....hereto to arrive at a conclusion of under valuation. 3. Mr. Maratha, learned counsel representing the respondent in the absence of instructions is presently unable to state whether the aforesaid material also refers to the transactional value referable to Telenor or is based on any other independent material. 4. In order to enable Mr. Maratha to complete instructions, let these m....

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....te that the following significant findings have come to be returned by the ITAT in the order impugned before us: "5. After hearing both the parties and on perusal of the impugned order, we find that it is an undisputed fact that the shares purchased by the assessee of Simpson Unitech Wireless Pvt. Ltd. and Acorus Unitech Wireless Pvt. Ltd. from Unitech Holdings Pvt. Ltd. at Rs.10/- was no....

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....y the Ld. CIT (A) which is based on material on record. Thus, we do not find any infirmity in the findings of the Ld. CIT (A), and therefore, the same is confirmed. Consequently, the appeal filed by the Revenue is dismissed." 6. The ITAT has taken into consideration what appears to be the undisputed position of the Assessing Officer ["AO"] having essentially been guided by the transaction....