KALAIYARASAN RAJANGAM MUDALIAR,AHMEDABAD vs. ASSESSING OFFICER, AHMEDABAD

ITA 2669/AHD/2025Status: DisposedITAT Ahmedabad22 September 2026AY 2022-237 pages
AI SummaryRemanded

What were the facts?

The assessee claimed a short-term capital loss on the sale of unquoted shares. The Assessing Officer disallowed this loss, citing discrepancies between the assessee's shareholding documents and the company's reported details. The CIT(A) confirmed the disallowance due to the assessee's failure to provide supporting documents.

What did the Tribunal hold?

The Tribunal found that the discrepancy in shareholding particulars and the purchase price required fresh verification. It also noted the assessee's explanation of a distress sale and the need to examine the transaction's genuineness.

What were the issues?

Whether the short-term capital loss on the sale of unquoted shares is allowable, considering discrepancies in shareholding details and the valuation of shares.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144B,Section 270A,Section 272A,Section 50CA,Section 80D

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B” BENCH, AHMEDABAD

Before: SHRI SANJAY GARG & SHRI GANGADHAR PANDA

For Appellant: Shri Fenil H Mehta, AR
For Respondent: Shri Deependra Kumar, Sr. DR
Hearing: 17.08.2026Pronounced: 22.09.2026

PER GANGADHAR PANDA - ACCOUNTANT MEMBER:

This appeal filed by the assessee is directed against the order dated 08.10.2025 passed by the Ld. Commissioner of Income Tax (Appeals) (hereinafter referred to as the “Ld. CIT(A)”), National Faceless Appeal Centre, Delhi [in short “NFAC”], for the Assessment Year 2022-203 arising out of the assessment order dated 27.03.2024 completed under section 143(3) read with section 144B of the Income-tax Act, 1961 (“the Act”).

2.

The assessee has raised the following grounds of appeal:

“1. Disallowance of Short term capital loss on sale of unquoted shares of Fiducia Infrastructure Private Limited of Rs. 3,38,00,000/

The order continues below.

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