SALONI GIRRAJKISHOR AGRAWAL,MUMBAI vs. INCOME TAX OFFICER, WARD - 25(1)(1), MUMBAI

IN THE INCOME-TAX APPELLATE TRIBUNAL“G” BENCH,
MUMBAI
BEFORE JUSTICE (RETD.) C. V. BHADANG, PRESIDENT
&
SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER
Saloni Girrajkishor Agrawal
1601/1602,
Green
Acre,
Lokhandwala Complex, Andheri
(West), Mumbai – 400 053,
Maharashtra v/s.
बनाम
Income Tax Officer, Ward
–25(1)(1),Kautilya Bhavan,
Bandra
Kurla
Complex,
Bandra (East), Mumbai –
400051, Maharashtra
स्थायी लेखा सं./जीआइआर सं./PAN/GIR No: ANUPA1692D
Appellant/अपीलार्थी
..
Respondent/प्रतिवादी

Appellant by :
Shri Prakash Jhunjhunwala, AR
Respondent by :
Shri Swapnil Choudhary, (Sr. DR)

Date of Hearing
16.10.2025
Date of Pronouncement
04.11.2025

आदेश / O R D E R

PER PRABHASH SHANKAR [A.M.] :-

The present appeal is filed by the assessee against the order passed by the Learned Commissioner of Income-tax (Appeals)/National
Faceless Appeal Centre, Delhi [hereinafter referred to as “CIT(A)”]
pertaining to assessment order passed u/s. 143(3) r.w.s. 147 of the Income-tax Act, 1961 [hereinafter referred to as “Act”] dated 30.12.2016
for the Assessment Year [A.Y.] 2013-14. P a g e | 2
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Saloni Girrajkishor Agarwal

Saloni Girrajkishor Agarwal ld.Assessing Officer passed order under section 143(3) r.w.s. 147 of the Act rejecting the claim of deduction under section 10(38) of the Act on sale of shares of Esaar India Ltd.(‘EIL’) by holding that it was penny stock. In this regard, the AO relied upon various information from the Investigation wing of the Department which suggested that the sale transaction of these shares was a bogus transaction being part of huge penny scam and accordingly, assessed the aforesaid profits thereon u/s 68 of the Act asUnexplained income of the assessee. As per the details shares, the assessee had purchased 40,000 shares of ESL for a sum of Rs
20,00,000/-. Later, one share of face value of Rs. 10/- was split into 10
shares of Rs. 1/-. She sold the same for Rs 2,09,79,000/- resulting in a huge profit of Rs. 1,89,52,506/- within a short span of time, thereby booking exponential profits @ 947.6%.
3.1 As per the assessment order, it was noticed by the AO that the assessee was not an experienced share trader and yet she had traded in single scrip and made huge profit without any optimistic cost benefit analysis or satisfactory reasoning. She was stated to have opted to engage intrading shares of the said penny stock company, which was found to exist without any basic financial parameters. Based on transaction of such a penny stock company which existed on paper, she booked exponential profits @ 947.6% on selling of such shareswhich

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Saloni Girrajkishor Agarwal appeared to be unrealistic. These shares had been sold to several non- existing paper entities/companies. It was further observed that 4,00,000/- shares of the ESL had been sold to Exit Providers/ counter parties at an exorbitant rates. It is pointed out by the AO that many of the purchasers had been named in Investigation wing reports. As per the said report, exit providers had purposely bought the shares of aforesaid penny stock company ESL at huge values so as to claim bogus losses and set off the same bogus loss against its taxable profit.
4. In the subsequent appeal before the ld.CIT(A), the assessee submitted details such as bank statement, contract notes transacted through registered brokers. Besides, it was claimed that she had never known parties to book bogus gain from sale of shares, in a pre-arranged manner. The Departmental report did not mention nor started investigation in her casewhich were carried out on the operators.
56,(Calcutta)[14-06-2022] wherein the Hon’ble Calcutta High Court on the similar set of facts related to taxability of LTCG on sale of shares considered as manipulated Penny stocks.

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Saloni Girrajkishor Agarwal

Saloni Girrajkishor Agarwal trading activities of the scrip Esaar India Ltd for the period 30.06.2011
TO 28.02.2015.Copy of the final order of SEBI dated 31.05.2019 has been placed on record. It is pointed out that as per para 14 of the order, the scrip has been given clean chit.
6. We have duly considered the facts of the case, the contents of the assessment order, detailed submissions of the assessee as also various case laws. We also find that the co-ordinate benches of ITAT, Mumbai have in several cases considered similar cases of addition of LTCG arising out of Investigation wing Kolkata report in such penny shares. One such case of Manisha
Narpatkumar
Chopra in dealt with similar issue though involving another scrip of Pine Animation. However, the findings and observations in the following paras as below squarely apply to the facts of the instant case well:
“11. We heard rival contentions and perused the record. We notice that the AO has primarily placed reliance on the report given by the Investigation
Wing of the Income-tax Department, Kolkata in order to arrive at the conclusion that the Long Term Capital Gain reported by the assessee is bogus in nature. We notice that the investigation report prepared by Investigation
Wing, Kolkata is a generalized report with regard to the modus operandi adopted in manipulation of prices of certain shares and generation of bogus capital gains. We notice that the AO has placed reliance on the said report, without bringing any material on record to show that the transactions entered by the assessee were found to be a part of manipulated transactions, i.e., it was not proved that the assessee has carried out the transactions of purchase and sale of shares in connivance with the people, who were involved in the alleged rigging of prices. We notice that the promoters and P a g e | 7
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Saloni Girrajkishor Agarwal their associations of M/s. Pine Animation Ltd., were initially debarred from accessing stock market, but the same has been revoked by the SEBI, vide its order dated 19th September, 2017. The following observations made by the SEBI in the above said order are worth noting:-
"10. Considering the fact that there are no adverse findings against the aforementioned 114 entities with respect to their role in the manipulation of the scrip of PAL, I am of the considered view that the directions issued against them vide interim order dated May 08, 2015 which were confirmed vide Orders dated June 02, 2016, July 05, 2016, August 22, 2016 and June
02, 2017 need not be continued."

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Saloni Girrajkishor Agarwal of prices of shares. Hence, there is no reason to suspect the purchase and sale of shares undertaken by the assessee.

“3. Mr.Sureshkumar seriously complained that such finding rendered concurrently should not have been interfered with by the Tribunal. In further Appeal, the Tribunal proceeded not by analyzing this material and concluding that findings of fact concurrently rendered by the Assessing Officer and the Commissioner are perverse.
The Tribunal proceeded on the footing that onus was on the Department to nail the Assessee through a proper evidence and that there was some cash transaction through these suspected brokers, on whom there was an investigation conducted by the Department. Once the onus on the Department was discharged, according to Mr.Sureshkumar, by the Revenue-Department, then, such a finding by the Tribunal raises a substantial question of law. The Appeal, therefore, be admitted.

Saloni Girrajkishor Agarwal

Commissioner extensively referred to the correspondence and the contents of the report of the Investigation carried out in paras 20, 20.1,
20.2 and 21 of his order, what was important and vital for the purpose of the present case was whether the transactions in shares were genuine or sham and bogus. If the purchase and sale of shares are reflected in the Assessee's DMAT account, yet they are termed as arranged transactions and projected to be real, then, such conclusion which has been reached by the Commissioner and the Assessing Officer required a deeper scrutiny. It was also revealed during the course of inquiry by the Assessing Officer that the Calcutta Stock Exchange records showed that the shares were purchased for code numbers S003 and R121 of Sagar Trade Pvt. Ltd. and Rockey Marketing Pvt. Ltd. respectively. Out of these two, only Rockey Marketing Pvt.Ltd. is listed in the appraisal report and it is stated to be involved in the modus- operandi. It is on this material that he holds that the transactions in sale and purchase of shares are doubtful and not genuine. In relation to Assessee's role in all this, all that the Commissioner observed is that the Assessee transacted through brokers at Calcutta, which itself raises doubt about the genuineness of the transactions and the financial result and performance of the Company was not such as would justify the increase in the share prices. Therefore, he reached the conclusion that certain operators and brokers devised the scheme to convert the unaccounted money of the Assessee to the accounted income and the present Assessee utilized the scheme.

Saloni Girrajkishor Agarwal with two brokers were available and which gave details of the transactions. The contract note is a system generated and prescribed by the Stock Exchange. From this material, in para 11 the Tribunal concluded that this was not mere accommodation of cash and enabling it to be converted into accounted or regular payment. The discrepancy pointed out by the Calcutta Stock Exchange regarding client Code has been referred to. But the Tribunal concluded that itself, is not enough to prove that the transactions in the impugned shares were bogus/sham.
The details received from Stock Exchange have been relied upon and for the purposes of faulting the Revenue in failing to discharge the basic onus. If the Tribunal proceeds on this line and concluded that inquiry was not carried forward and with a view to discharge the initial or basic onus, then such conclusion of the Tribunal cannot be termed as perverse. The conclusions as recorded in para 12 of the Tribunal's order are not vitiated by any error of law apparent on the face of the record either.

"2. We have considered the impugned order with the assistance of learned counsels and we have no reason to interfere. There is a finding of fact by the Tribunal that the transaction of purchase and sale of P a g e | 11
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Saloni Girrajkishor Agarwal shares of the alleged penny stock of shares of Ramkrishna Fincap Ltd
("RFL") is done through stock exchange and through the registered
Stock Brokers. The payments have been made through banking channels and even Security Transaction Tax ("STT") has also been paid.
The Assessing Officer also has not criticized the documentation involving the sale and purchase of shares. The Tribunal has also come to a finding that there is no allegation against the assessee that it has participated in any price rigging in the market on the shares of RFL.

“....The CIT(A) came to the conclusion that respondent bought 3000
shares of RFL, on the floor of Kolkata Stock Exchange through registered share broker. In pursuance of purchase of shares the said broker had raised invoice and purchase price was paid by cheque and respondent's bank account has been debited. The shares were also transferred into respondent's Demat account where it remained for more than one year. After a period of one year the shares were sold by the said broker on various dates in the Kolkata Stock Exchange..

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Pursuant to sale of shares the said broker had also issued contract notes cum bill for sale and these contract notes and bills were made available during the course of appellate proceedings. On the sale of shares respondent effected delivery of shares by way of Dematinstruction slips and also received payment from Kolkata Stock
Exchange. The cheque received was deposited in respondent's bank account. In view thereof, the CIT(A) found there was no reason to add the capital gains as unexplained cash credit under section 68 of the Act. The Tribunal while dismissing the appeals filed by the Revenue also observed on facts that these shares were purchased by respondent on the floor of Stock Exchange and not from the said broker, deliveries were taken, contract notes were issued and shares were also sold on the floor of Stock Exchange. The ITAT therefore, in our view, rightly concluded that there was no merit in the appeal."

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Saloni Girrajkishor Agarwal

“9.1. In the course of hearing, ld. Sr.DR had referred to various adjudication orders passed by SEBI and asserted that the share transactions undertaken by the assessee are of tainted scrips which were investigated and subjected to penalties. Ld. Counsel for the assessee has placed on record his rebuttal and clarifications on various orders of SEBI vide submission dated 15.05.2024. 9.2. On each of the above orders, assessee has made his submission which is discussed as under:
a) For order at Sr. No.1, it is submitted that this relates to period between
01.04.2014 to 11.03.2016, whereas assessee had sold the shares of Essar India Ltd. between 08.10.2012 and 27.02.2013. Thus, this order has no relevance to the facts of the present case.
b) ………..
c) ………..
d) ………….
e) …………...
10. We note that transactions for purchase and sale of the aforesaid shares were undertaken on the stock exchange platform through the SEBI registered broker on which STT was levied and the consideration was routed through normal banking channel. The entire flow of these transactions is corroborated by relevant documentary evidences placed on record. While making the addition, there are no discrepancies pointed out by the Assessing
Officer in the documents and the details furnished by the assessee. Ld. AO has not bothered to discuss or point out any defect or deficiency in the documents furnished by the assessee. These evidences furnished have been neither controverted by the Ld. AO during the assessment proceedings nor anything substantive brought on record to justify the addition made by him. At any stage of the present case, Revenue has not brought on record any material about participation of the assessee with any such dubious transactions relating to accommodation entry, price rigging or exit providers. To our mind, Ld. AO could have taken an adverse view only if he could point out the discrepancies or insufficiency in the evidence and details furnished in his office. Once the assessee has produced documentary evidence to establish the veracity of his claim, the burden would shift on the Revenue to establish its case.

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Saloni Girrajkishor Agarwal

On the perusal of records, it is discernible that ld. Assessing Officer had proceeded on the basis of analysis of the financials of the companies.
According to him, sharp jump in the share prices of the aforesaid scrips is not justified. He has relied upon the search and survey operations conducted by the investigation wing of the Department at various locations in respect of alleged penny stocks which sets out the modus operandi adopted in the business of providing entries for bogus capital gains. The conclusion drawn by the ld. Assessing Officer of implicating the assessee is un-supported by any cogent material on record. The finding arrived at by the ld. Assessing
Officer is thus purely an assumption based on conjectures and surmises. In our thoughtful considerations to the facts and circumstances of the case, it is not in controversy that assessee has discharged his burden by submitting the relevant documents, details of which are already extracted above by way of index of the two paper books.
10.2. For the above observations and findings, we place our reliance on the decision in the case of CIT vs. Jamnadevi Agrawal[2012] 20
taxmann.com 529 (Bom), wherein it was held that transactions of purchase and sale of shares cannot be considered to be bogus, when the documentary evidences furnished by the assessee establish genuineness of the claim. We also draw our force from the decision of Hon'ble High Court of Delhi in the case of PCIT v. Krishna Devi [2021] 126 taxmann.com 80
(Del) wherein the Court noticed that the reasoning given by the Assessing
Officer to disbelieve the capital gain declared by the assessee, viz.
astronomical increase in the price of shares, weak fundamentals of the relevant companies are based on mere conjectures.
10.3. Also, reliance placed by the ld. Assessing Officer on the report of investigation wing without further corroboration based on cogent material does not justify the conclusion that the impugned transaction is bogus, sham and part of racket of accommodation entries. It does not prove that the assessee has carried out the impugned transactions of purchase and sale of shares in connivance with the people who were involved in the alleged rigging of share prices. In absence of any such material, enquiry and examination, the addition made pertaining to receipt of sale consideration of the impugned transaction cannot be sustained. In our considered view, ld.
Assessing Officer has not established that the assessee was involved in price rigging.
11. We note that ld. Assessing Officer has observed about the so called purchasers of shares sold by the assessee who have not been identified as none responded to the notices issues u/s.133(6) of the Act. In this context, it is P a g e | 15
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Saloni Girrajkishor Agarwal worth noting that impugned share sale transactions undertaken by the assessee are on the online digital trading platform of stock exchange of BSE which is a regulated market under the aggies of a regulator viz. SEBI. There is nothing on record from the market regulator SEBI for the relevant periodwhich establishes the 'tainted' status of the scripinvolved in the present case, so as to hold the share sale transactions as bogus/accommodation entry as alleged by the ld. AO. Also, the operations and modus operandi of this regulated market does not in any way provide for any mechanism by which assessee can bring forth the identity of the buyers of his shares and their creditworthiness. Further, sale proceeds are received through the stock market process into the pre- identified bank account of the seller i.e., the assessee which cannot be tainted as 'unexplained or unaccounted or undisclosed' money for the addition madeu/s. 68 by the ld. Assessing Officer.
11.1. From the perusal of the statement of assessee recorded by the ld.
Assessing Officer during the course of assessment for Assessment Year 2013-
14 as reproduced in the impugned order demonstrates that he is a long-term investor, investing since year 2006 and is aware of his DMAT account, brokers through whom transactions were undertaken, shares in which he had invested and stock market operations. He produced all the relevant documentary evidences before the ld. Assessing Officer in support of his deposition in the statement recorded. From all of this, we notice that assessee has - a. purchased the shares under preferential allotment by making payment through banking channel.
b. dematerialized the shares purchased by credit to the DMAT account and were later sold out of the same holding. c. sold the shares on the platform of recognised stock exchange on the then prevailing prices.
d. received the sale proceeds through stock market process in his bank account.
11.2. From the above, we note that ld. Assessing Officer has not brought on record any material to show that assessee was part of any group which was involved in the manipulation of share prices. Suspicion by the ld. Assessing
Officer on the purchase and sale of shares is baseless.
12. Ld. Assessing Officer, while drawing the adverse conclusion noted about the cash trail in the accounts of entry providers. He based his conclusion on the finding of investigations done by the Investigation Wing rather than P a g e | 16
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Saloni Girrajkishor Agarwal bringing on record any direct and cogent material to establish existence of such a cash trail where the assessee has transacted in cash. In this respect, ld.
CIT(A) has supported the ld. Assessing Officer by stating that Assessing
Officer cannot be expected to produce such evidences and has merely harped on general proposition of having circumstantial evidence leading to inference or presumption. In this respect in the absence of any corroborative material brought on record by the authorities below, we hold against drawing such inference or presumption.
13. We also note that in the first appellate order, Ld. CIT(A)while dismissing the appeal observed that ld. Assessing Officer by not allowing the assessee to cross examination the brokers, operators and exit providers whose statements were relied upon by the ld. Assessing Officer, does not vitiate the assessment. Negating the request made by the assessee, Ld. CIT(A) confirmed the addition. The approach adopted by ld. CIT(A) while dismissing the appeal and stating that assessment order passed by the Assessing Officer does not get vitiated merely because Assessing Officer did not allow cross examination, is not in compliance with the provisions of section 142(3) of the Act which is a statutory mandatory procedural requirement for making a valid assessment. We note that the required compliance with section 142(3) has not been met.
13.1. We refer to the relevant provisions of sec. 142 which are reproduced as under:
Sec. 142 (1) For the purpose of making an assessment under this Act, the Assessing Officer may serve on any person who has made a return under section 139 or in whose case the time allowed under sub- section (1) of that section for furnishing the return has expired a notice requiring him, on a date to be therein specified,-
142(2) For the purpose of obtaining full information in respect of the income or loss of any person, the Assessing Officer may make such inquiry as he considers necessary.
142(3) The assessee shall, except where the assessment is made under section 144, be given an opportunity of being heard in respect of any material gathered on the basis of any inquiry under sub- section (2) or any audit under sub- section (2A) and proposed to be utilised for the purpose of the assessment.
[emphasis supplied by us by bold and underline]
13.2. From the above and in the present context, we note that section 142(2) empowers the AO to make such enquiry as he considers necessary.
The discretion is on the AO under the said section.

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However, having conducted such enquiry as provided in Sec. 142(2), it is incumbent upon the AO u/s. 142(3) to give an opportunity of being heard in respect of any material gathered on the basis of any enquiry done u/s.
142(2) and proposed to be utilised for the purpose of the assessment. It is important to note that Sec. 142(3) uses the word "shall" which makes it mandatory requirement on the part of the AO to comply with it.
13.3.We also take note of the provisions of Sec. 143(3) wherein the assessment is to be completed by the AO which also provides in sub- section (3) that AO shall make an assessment by an order in writing, inter alia, "after taking into account all relevant material which he has gathered." Thus, by keeping the provisions of Sec. 142(3) read with section 142(2) and Sec. 143(3) in juxtaposition, we understand that it is a mandatory statutory requirement on the part of the AO to comply with the provisions of Sec. 142(3) in completing the assessment proceeding, failure of which may vitiate the entire assessment itself since this sub-section uses the word "shall". The only exception to this requirement is where an assessment is made u/s 144 which is not so in the present appeals before us.
14. As already noted above, Ld. CIT(A) dealt with extensive literature on the concept of preponderance of probability and other doctrines to dismiss the appeal of the assessee. According to us, the theory of preponderance of probability is applied to weigh the evidence of either side and draw a conclusion in favour of a party which has more favourable factor in his side.
The conclusions have to be drawn on the basis of certain admitted facts and materials and not on the basis of presumption of fact that might go against the assessee. Once nothing has been proved against the assessee with the aid of any direct material, nothing can be implicated against the assessee on the presumption or suspicion, howsoever, strong it might appear to be true.
15. Considering the totality of the facts and circumstances of the case, factual matrix and submissions of parties narrated above as well as discussion and observations made herein above, we delete the addition made u/s 68 towards proceeds of sale of listed shares which gave rise to Long Term
Capital Gain on the said sale claimed exempt by the assessee u/s 10(38), in both the assessment years. Accordingly, grounds taken by the assessee in this respect are allowed in both the appeals.
16. For the aforesaid findings, we find force of binding nature from the decisions of Hon'ble High Court of Bombay being a juri ictional High
Court:

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Saloni Girrajkishor Agarwal i) Pr. CIT v. Ziauddin A Siddique [Income-tax Appeal No. 2012 of 2017, dated 4-3-2022] held as under:-
"1. The following question of law is proposed:
"Whether on the facts and in the circumstances of the case and in law, the Hon'ble Tribunal was justified in deleting the addition of Rs. 1,03,33,925/- made by AO u/s 68 of the I.T. Act, 1961, ignoring the fact that the shares were bought/acquired from off market sources and thereafter the same was DMATed and registered in stock exchange and increase in share price of Ramkrishna Fincap Ltd. is not supported by the financials and, therefore, the amount of LTCG of Rs. 1,03,33,925/- claimed by the assessee is nothing but unaccounted income which was rightly added u/s 68 of the I. T. Act,
1961?"
2. We have considered the impugned order with the assistance of the learned
Counsels and we have no reason to interfere. There is a finding of fact by the Tribunal that the transaction of purchase and sale of the shares of the alleged penny stock of shares of Ramkrishna Fincap Ltd. ("RFL") is done through stock exchange and through the registered Stock Brokers. The payments have been made through banking channels and even Security Transaction
Tax ("STT") has also been paid. The Assessing Officer also has not criticized the documentation involving the sale and purchase of shares. The Tribunal has also come to a finding that there is no allegation against assessee that it has participated in any price rigging in the market on the shares of RFL.
3. Therefore we find nothing perverse in the order of the Tribunal."
4. Mr. Walve placed reliance on a judgment of the Apex Court in Principal
Commissioner of Income-tax (Central)-1 v. NRA Iron & Steel (P.) Ltd. but that does not help the revenue in as much as the facts in that case were entirely different.
5. In our view, the Tribunal has not committed any perversity or applied incorrect principles to the given facts and when the facts and circumstances are properly analysed and correct test is applied to decide the issue at hand, then, we do not think that question as pressed raises any substantial question of law.
6. The appeal is devoid of merits and it is dismissed with no order as to costs."
ii) PCIT vs. Indravadan Jain HUF [2023] 156 taxmann.com 605
(Bom) wherein it was held:

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"Where shares were purchased by assessee on floor of stock exchange and not from broker, payment was made through banking channel, deliveries were taken in DMAT account where shares remained for more than one year, contract notes were issued and shares were also sold on stock exchange, there was no reason to add capital gains as unexplained cash credit under section 68"
iii) CIT vs. Shyam R. Pawar [2015] 54 taxmann.com 108 (Bom) wherein it was held:
"Where DMAT account and contract note showed details of share transaction, and Assessing Officer had not proved said transaction as bogus, capital gain earned on said transaction could not be treated as unaccounted income under section 68"
17. In the result, both the appeals of the assessee are allowed.”

Saloni Girrajkishor Agarwal the basis of admission of certain individuals. Apparently, the ld.CIT(A) in the appellate order has, in a preconceived manner dittoed the assessment order rather than adjudicating by way of independent application of mind on his part. We have no hesitation in deleting the addition. The AO is therefore, directed to delete the impugned addition made thus, allowing the ground nos. 2 and 3. 8. In the result, appeal filed by the assessee stands partly allowed.
Order pronounced in the open court on 04/11/2025. [Justice (Retd.)C V BHADANG]
[PRABHASH SHANKAR]
PRESIDENT
ACCOUNTANT MEMBER

Place: म ुंबई/Mumbai
ददनाुंक /Date 04.11.2025
Lubhna Shaikh / Steno

आदेश की प्रतितलति अग्रेतिि/Copy of the Order forwarded to :
1. अपीलार्थी / The Appellant
2. प्रत्यर्थी / The Respondent.
3. आयकर आयुक्त / CIT
4. विभागीय प्रविविवि, आयकर अपीलीय अविकरण DR, ITAT,
Mumbai

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सत्यावपि प्रवि ////
आदेशानुसार/ BY ORDER,

उि/सहायक िंजीकार (Dy./Asstt.