STONEWELL DEVELOPERS PVT.LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-18, JHANDEWALAN EXTN, NEW DELHI

ITA 3338/DEL/2024Status: DisposedITAT Delhi09 December 2025AY 2007-2008Bench: SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER, SHRI NAVEEN CHANDRA (Accountant Member)7 pages
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What did the Tribunal hold?

The Tribunal found that the CIT(A) had not properly adjudicated the issues of legality of reopening and the merits of the addition. Therefore, the Tribunal set aside the appeals and remanded the matter back to the CIT(A) for a fresh adjudication.

What were the facts?

The Revenue appealed against the deletion of an addition of Rs. 9.70 Crore, made on account of bogus share capital and premium, by the CIT(A). The assessee challenged the legality of the reopening of assessment under Section 147/148.

What were the issues?

Whether the reopening of assessment under Section 147/148 was legally valid and whether the addition on account of share capital and premium was justified on merits.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 68,Section 143(3),Section 132,Section 133A,Section 153A,Section 153D,Section 133(6)

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Income Tax Appellate Tribunal, DELHI ‘G’ BENCH,

Before: SHRI SATBEER SINGH GODARA, & SHRI NAVEEN CHANDRA

For Appellant: Shri Rajeshwar Painuly, CA
For Respondent: Shri Manish Gupta, Sr. DR
Hearing: 04.11.2025Pronounced: 04.11.2025

Heard together (2 matters)

ITA No. 2847/DEL/2017
ITA No. 3338/DEL/2024

Read from the judgment's own cause title. This page is filed under one of them.

PER NAVEEN CHANDRA, A.M:- ITA No. 3338/DEL/2024 Stonewell Developers Pvt Ltd [A.Y. 2007-08] The above captioned cross appeals by the Revenue and the assessee are directed against the order of the ld. CIT(A)-27, New Delhi

dated 28.02.2017 for A.Y 2007-08 respectively.

2.

Since both the appeals were heard together and pertain to same

assessee, they are being disposed of by this common order for the sake

of convenience and bre

The order continues below.

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