CIT v. Lovely Exports (P) Ltd.

216 CTR 195Supreme Court of India2008#66 most cited

What is CIT v. Lovely Exports (P) Ltd. authority for?

If an assessee company receives share application money from alleged bogus shareholders and provides their details to the Assessing Officer, no addition can be made under Section 68 in the company's hands; the Department must proceed against the shareholders by reopening their individual assessments.

772

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2008 to 2026.

Also referred to as

CIT v. Lovely Exports (P) Ltd. · Section 68 · share application money · bogus shareholders · creditworthiness of creditor · genuineness of transaction · addition u/s 68 · reopening assessments of shareholders · 216 CTR 195 · Supreme Court 2008

Sections most often in play

Section 68Section 133(6)Section 143(3)Section 147Section 131Section 148Section 143(2)Section 153A

Issues it is cited on

creditworthiness of the creditorsource of sourceshare capital and share premiumshare application moneypaper companyretracted statementaddition u/s 68addition under section 68genuineness of the transactionentry operatoraccommodation entrysection 133(6)

Judgments citing CIT v. Lovely Exports (P) Ltd.

INCOME TAX OFFICER, WARD-1(1), FARIDABAD, FARIDABAD vs. AGARWAL EARTH MOVERS PRIVATE LIMITED, FARIDABAD

In the result, the appeal filed by the Revenue is dismissed

ITA 6084/DEL/2025[2020-21]Status: DisposedITAT Delhi08 Apr 2026AY 2020-21

Bench: Shri S. Rifaur Rahman & Shri Sudhir Kumarincome Tax Officer, Ward-1(1), Vs. Agarwal Earth Movers B-Block, New Cgo Complex, Private Limited, Nh-Iv, Nit Fartidabad 1316, Sector-29, Faridabad Haryana Haryana-121001 [Pan: Aadca7184K) (Appellant) (Respondent)

For Appellant: Sh. Ved Jain, Adv. & Ms. Uma Upadhyaya, CAFor Respondent: Sh. Pramod Kumar, Sr. DR
Section 132Section 132(4)Section 142(1)Section 143(2)Section 147Section 148

…lenders and Bank statement of appellant showing transaction. There is no adverse inference in regard to any of such material. The appellant has cited decision of Hon'ble Supreme Court in case of Commissioner of Income- tax vs. Lovely Exports (P.) Ltd. [2008] 216 CTR 195 (SC)[11-01-2008] where it has been held that “Once identify is established and loan is through banking channels, no addition can be made in hands of the assessee; department may proceed against the creditor.” The appellant has also mentioned the fact that loans has been repaid during the year itself and cited the following decisions 7 wherein it…

DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE)- 3(1), KOLKATA, KOLKATA vs. AUXINITE SUPPLIERS PRIVATE LIMITED, KOLKATA

In the result, the appeal of the Revenue is dismissed and CO of the assessee is allowed

ITA 139/KOL/2025[2019-2020]Status: DisposedITAT Kolkata02 Apr 2026AY 2019-2020

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Dy. Commissioner Of Income Auxinite Suppliers Private Tax (Cc)-3(1) Limited 4Th Floor, Aaykar Bhawan 44/2A Jain Tower, Hazra Road, Vs. Poorva, 110 Shantipally, Kolkata- Kolkata-700019, West Bengal 700017, West Bengal (Appellant) (Respondent) Pan No. Aaecb3974H Co No. 11/Kol/2025 (Arising In Ita No. 139/Kol/2025 For A.Y. 2019-20) Dy. Commissioner Of Income Auxinite Suppliers Private Tax (Cc)-3(1) Limited 4Th Floor, Aaykar Bhawan 44/2A Jain Tower, Hazra Road, Vs. Poorva, 110 Shantipally, Kolkata- Kolkata-700019, West Bengal 700017, West Bengal (Appellant) (Respondent) Assessee By : S/Shri Rajeeva Kumar & Giridhar Dhelia, Ars Revenue By : Shri V. Vidhyadhar, Dr Date Of Hearing: 11.02.2026 Date Of Pronouncement: 02.04.2026

For Appellant: S/Shri Rajeeva Kumar &For Respondent: Shri V. Vidhyadhar, DR
Section 132Section 133(6)Section 143(2)Section 153CSection 68

…erverse and liable to be quashed - Held, yes [Paras 4 and 5] [Matter remanded]” In CIT vs. Roseberry Mercantile (P) Ltd, ITAT 241 of 2010, the Hon’bleCalcutta High Court had followed the decision of the Hon’bleSupreme Court in the case of Lovely Export (2008) 216 CTR 195 that if the share subscription was received from alleged bogus shareholders, the Revenue can reopen their individual assessment and addition cannot be made in the hands of the recipient company: "On the facts and in the circumstances of the case, Ld. CIT(A) ought to have upheld the assessment order as the transaction entered into by the assessee…

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7842/DEL/2025[2022-23]Status: DisposedITAT Delhi20 Mar 2026AY 2022-23

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

…d by the Hon'ble Supreme Court in Commissioner of Income Tax v. Hon'ble Supreme Court in Commissioner of Income Tax v. Hon'ble Supreme Court in Commissioner of Income Tax v. Hon'ble Supreme Court in Commissioner of Income Tax v. Lovely Exports (P) Ltd. (2008) 216 CTR 195 (SC) that if the Lovely Exports (P) Ltd. (2008) 216 CTR 195 (SC) that if the Lovely Exports (P) Ltd. (2008) 216 CTR 195 (SC) that if the Lovely Exports (P) Ltd. (2008) 216 CTR 195 (SC) that if the share application money is received by the assessee share application money is received by the assessee share application money is received by the asse…

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7841/DEL/2025[2021-22]Status: DisposedITAT Delhi20 Mar 2026AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

…t respond to the notice issued by the Assessing Officer under Section 133 (6) of the Act, it cannot be taken that the said transaction was ingenuine. It has been held by the Hon'ble Supreme Court in Commissioner of Income Tax v. Lovely Exports (P) Ltd. (2008) 216 CTR 195 (SC) that if the share application money is received by the assessee company from alleged bogus shareholders, whose names are given to the Assessing Officer, then the department is free to proceed to re-open their individual assessments in accordance with law. But the said amount cannot be taken as unexplained income in the hands of the assessee.…

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7840/DEL/2025[2020-21]Status: DisposedITAT Delhi20 Mar 2026AY 2020-21

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

…d by the Hon'ble Supreme Court in Commissioner of Income Tax v. Hon'ble Supreme Court in Commissioner of Income Tax v. Hon'ble Supreme Court in Commissioner of Income Tax v. Hon'ble Supreme Court in Commissioner of Income Tax v. Lovely Exports (P) Ltd. (2008) 216 CTR 195 (SC) that if the Lovely Exports (P) Ltd. (2008) 216 CTR 195 (SC) that if the Lovely Exports (P) Ltd. (2008) 216 CTR 195 (SC) that if the Lovely Exports (P) Ltd. (2008) 216 CTR 195 (SC) that if the share application money is received by the assessee share application money is received by the assessee share application money is received by the asse…

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7838/DEL/2025[2018-19]Status: DisposedITAT Delhi20 Mar 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Amit Goel andFor Respondent: Ms. Monika Singh, CIT-DR
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

…t respond to the notice issued by the Assessing Officer under Section 133 (6) of the Act, it cannot be taken that the said transaction was ingenuine. It has been held by the Hon'ble Supreme Court in Commissioner of Income Tax v. Lovely Exports (P) Ltd. (2008) 216 CTR 195 (SC) that if the share application money is received by the assessee company from alleged bogus shareholders, whose names are given to the Assessing Officer, then the department is free to proceed to re-open their individual assessments in accordance with law. But the said amount cannot be taken as unexplained income in the hands of the assessee.…

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT CENTRAL CIRCLE -05 , DELHI

ITA 5521/DEL/2025[2024-25]Status: DisposedITAT Delhi20 Mar 2026AY 2024-25

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

…d by the Hon'ble Supreme Court in Commissioner of Income Tax v. Hon'ble Supreme Court in Commissioner of Income Tax v. Hon'ble Supreme Court in Commissioner of Income Tax v. Hon'ble Supreme Court in Commissioner of Income Tax v. Lovely Exports (P) Ltd. (2008) 216 CTR 195 (SC) that if the Lovely Exports (P) Ltd. (2008) 216 CTR 195 (SC) that if the Lovely Exports (P) Ltd. (2008) 216 CTR 195 (SC) that if the Lovely Exports (P) Ltd. (2008) 216 CTR 195 (SC) that if the share application money is received by the assessee share application money is received by the assessee share application money is received by the asse…

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT, CENTRAL CIRCLE-05, DELHI

ITA 5520/DEL/2025[2023-24]Status: DisposedITAT Delhi20 Mar 2026AY 2023-24

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

…t respond to the notice issued by the Assessing Officer under Section 133 (6) of the Act, it cannot be taken that the said transaction was ingenuine. It has been held by the Hon'ble Supreme Court in Commissioner of Income Tax v. Lovely Exports (P) Ltd. (2008) 216 CTR 195 (SC) that if the share application money is received by the assessee company from alleged bogus shareholders, whose names are given to the Assessing Officer, then the department is free to proceed to re-open their individual assessments in accordance with law. But the said amount cannot be taken as unexplained income in the hands of the assessee.…

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT, CENTRAL CIRCLE-05, DELHI

ITA 5517/DEL/2025[2020-21]Status: DisposedITAT Delhi20 Mar 2026AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

…t respond to the notice issued by the Assessing Officer under Section 133 (6) of the Act, it cannot be taken that the said transaction was ingenuine. It has been held by the Hon'ble Supreme Court in Commissioner of Income Tax v. Lovely Exports (P) Ltd. (2008) 216 CTR 195 (SC) that if the share application money is received by the assessee company from alleged bogus shareholders, whose names are given to the Assessing Officer, then the department is free to proceed to re-open their individual assessments in accordance with law. But the said amount cannot be taken as unexplained income in the hands of the assessee.…

VESTIGE MARKETING PVT. LTD.,DELHI vs. DCIT, CENTRAL CIRCLE- 05, DELHI

ITA 5515/DEL/2025[2018-19]Status: DisposedITAT Delhi20 Mar 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Amit Goel andFor Respondent: Ms. Monika Singh, CIT-DR
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

…t respond to the notice issued by the Assessing Officer under Section 133 (6) of the Act, it cannot be taken that the said transaction was ingenuine. It has been held by the Hon'ble Supreme Court in Commissioner of Income Tax v. Lovely Exports (P) Ltd. (2008) 216 CTR 195 (SC) that if the share application money is received by the assessee company from alleged bogus shareholders, whose names are given to the Assessing Officer, then the department is free to proceed to re-open their individual assessments in accordance with law. But the said amount cannot be taken as unexplained income in the hands of the assessee.…

MS. BESTECH HOSPITALITIES PVT. LTD,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, FARIDABAD

ITA 3796/DEL/2023[2011-12]Status: DisposedITAT Delhi13 Mar 2026AY 2011-12

Bench: Shri C.N. Prasad & Shri M. Balaganesh, Accontant Member Assessment Year 2011-12 Ms. Bestech Hospitalities Vs. Dcit Pvt. Ltd. Faridabad Unit No.5D, 5Th Floor, Aria, Signature Offices, Jw Marrior Hotel, New Delhi -110037 Pan No.Aaccb2540F Appellant Respondent Appellant Sh. R. S. Ahuja, Ca Sh. Push Deep Singh, Advocate Respondent Smt. Kranti, Cit Dr

Section 132Section 132(1)Section 153ASection 68

…mpany had appeared. It was also argued that additions if any could have been made only in the case of share applicants and for this proposition, reliance was placed 9 upon the decision of Hon'ble Supreme Court in the case of M/s Lovely Export Pvt. Ltd. (2008) 216 CTR 195. It was argued that once documents have been furnished in support of share application money, further onus shifts upon the AO. In this case the AO has made addition based upon presumptions and without any evidence. 8. The Ld. AR also submitted that M/s Apoorva Leasing Finance & Investment Company Ltd., is listed in various stock exchanges of the…

YUGA PRINTPACK PRIVATE LIMITED,. vs. ITO WARD-2(5), FARIDABAD, .

Appeal of the assessee is allowed

ITA 6503/DEL/2025[2017-18]Status: DisposedITAT Delhi12 Mar 2026AY 2017-18

Bench: Shri Vikas Awasthyआअसं.6503/धिल्ली/2025 (नि.व. 2017-18) Yuga Printpack P. Ltd., C/O Ipso Legal, 1St Floor, Jangpura Extn. New Delhi 110014 ...... अपीलार्थी/Appellant Pan: Aaacy-6342-G बिाम Vs. Income Tax Officer, Ward-2(5), ..... प्रनिवादी/Respondent Cr Building, Faridabad, Haryana 122001 अपीलार्थी द्वारा/Appellant By : Shri Rajiv Saxena & Ms. Sumangla Saxena, Advocates प्रधििािीद्वारा/Respondent By : Shri Manoj Kumar, Sr. Dr सुिवाई की निथर्थ/ Date Of Hearing : 16/12/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 12/03/2026 आदेश/Order Per Vikas Awasthy, Jm:

For Appellant: Shri Rajiv Saxena & Ms. Sumangla SaxenaFor Respondent: Shri Manoj Kumar, Sr. DR
Section 68Section 69

…the documents furnished by the assessee, the AO could have made enquiries directly from the investor. However, no such inquiries were made by the AO. Reliance was also placed on the decision of Hon’ble Apex Court in the case of CIT vs. Lovely Exports P. Ltd., 216 CTR 195 to contend that if AO had doubt over genuineness of the investor, the AO was at liberty to reopen the assessment of the investor, addition u/s 69/68 of the Act cannot be made in hands of the assessee. The ld. Counsel thus prayed for allowing appeal of the assessee and quashing the impugned order. 5. After examining the bank statement it is evide…

ITO, NEW DELHI vs. M/S. WISDOM EXPORT PVT. LTD., DELHI

In the result, the appeal of the Revenue is dismissed

ITA 2172/DEL/2017[2007-08]Status: DisposedITAT Delhi11 Mar 2026AY 2007-08

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2007-08]

Section 143(3)Section 68

…lar route adopted by the assessee to plough back its own undisclosed income into its books could be of no Page 3 of 5 avail without proof. The appellant has also relied on the judgment of the Supreme Court in the case of CIT vs. Lovely Exports Pvt. Ltd. 2008) 216 CTR 195, wherein the decision of the Delhi High Court was upheld that if the share application money was alleged to be received from bogus share holders, the share money could be brought to tax in the hands of the said share holders, but not in the hands of the company on account of bogus share application. I have carefully gone through all the evidences…

JCIT, (OSD), CIRCLE 1(1), RAIPUR, RAIPUR vs. PLATINUM WORLD HOSPITALITY PRIVATE LIMITED, RAIPUR, RAIPUR

In the result appeal filed by the appellant is allowed

ITA 130/RPR/2026[2014-15]Status: DisposedITAT Raipur10 Mar 2026AY 2014-15

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.130/Rpr/2026 "नधा"रण वष" /Assessment Year : 2014-15 The Joint Commissioner Of Income Tax (Osd), Circle-1(1), Raipur (C.G.)

For Appellant: NoneFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 68

…corporation, Memorandum and Articles of Association, audited financial statements and bank statements. The Hon'ble Supreme Court in CIT v. Lovely 4 The JCIT (OSD), Circle-1, Raipur (C.G.) Vs. Platinum World Hospitality Private Limited Exports (P) Ltd. (2008) 216 CTR 195 (SC) has held that once the identity of a share applicant is established, the share capital cannot be treated as unexplained in the hands of the recipient company, and that the Assessing Officer is free to proceed against the investor if he has any doubt. Similarly, the Hon'ble Calcutta High Court in CIT v. Dataware Pvt. Ltd. (ITA 263/2011) held…

DCIT, CC-1(4), KOLKATA, KOLKATA vs. AMBICA DHATU PRIVATE LIMITED, KOLKATA

In the result, the appeal of the Revenue is dismissed

ITA 2389/KOL/2025[2012-13]Status: DisposedITAT Kolkata05 Mar 2026AY 2012-13

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 131Section 133(6)Section 250

…t the six parties also complied to the notices issued under Section 133(6) of the Act by Assessing Officer. Finally, the Ld. CIT(A) deleted the addition by relying on the decision of Hon'ble Supreme Court in the case of CIT Vs. Lovely Exports Pvt. Ltd. (2008) 216 CTR 195 (SC) and CIT Vs. Sophia Finance Ltd. (1993) 70 taxmann.com 69 (1994) 205 ITR 98. The Ld. CIT(A) deleted the addition by holding that the order of Assessing Officer is not sustaining in the eyes of law. 6. After hearing the rival contention and perusing the material on record. We note that the undisputed fact that the assessee filed before the As…

INCOME-TAX OFFICER WARD-3(3)(1),AHMEDABAD, AHMEDABAD vs. FURNISH HOME, AHMEDABAD

The appeal of the asessee is allowed, whereas, Revenue’s appeal is dismissed

ITA 1671/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad30 Jan 2026AY 2017-18

Bench: the Ld. CIT(A), wherein detailed submissions supported by the books of accounts, statutory returns, confirmation and other documentary evidences were filed. A remand report of the AO was sought on the same by the Ld. CIT(A) after considering which, Ld. CIT(A) deleted

For Appellant: Revenue byFor Respondent: Shri Arvind Kumbhare, Sr. DR
Section 250Section 68Section 69

…s. Judicial precedents consistently hold that once the partners are identified and they confirm the transaction in their own tax filings, the firm cannot be penalized for the source of funds in the hands of the partners (CIT v. Lovely Exports Pvt. Ltd. [2008] 216 CTR 195 (SC)). In respect of receipts from Das Hari Hotels Pvt. Ltd., the entries are fully backed by sale invoices, VAT declarations, and customer ledger matching the bank statement. The AO's failure to dispute the sales itself weakens the basis for treating the receipt as unexplained. Similarly, the refund of advances is supported by complete documenta…

FURNISH HOME,AHMEDABAD vs. THE ITO, WARD-3(3)(1) OLD WARD-3(3)(2), AHMEDABAD

The appeal of the asessee is allowed, whereas, Revenue’s appeal is dismissed

ITA 1439/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad30 Jan 2026AY 2017-18

Bench: SHRI SANJAY GARG (Judicial Member), SMT. ANNAPURNA GUPTA (Accountant Member)

For Appellant: Revenue byFor Respondent: Shri Arvind Kumbhare, Sr. DR
Section 250Section 68Section 69

…s. Judicial precedents consistently hold that once the partners are identified and they confirm the transaction in their own tax filings, the firm cannot be penalized for the source of funds in the hands of the partners (CIT v. Lovely Exports Pvt. Ltd. [2008] 216 CTR 195 (SC)). In respect of receipts from Das Hari Hotels Pvt. Ltd., the entries are fully backed by sale invoices, VAT declarations, and customer ledger matching the bank statement. The AO's failure to dispute the sales itself weakens the basis for treating the receipt as unexplained. Similarly, the refund of advances is supported by complete documenta…

SRI RAM HEALTH CARE PRIVATE LIMITED,BADDI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - PARWANOO, PARWANOO

In the result, all the appeal of the Assessee stand allowed for statistical purposes

ITA 850/CHANDI/2025[2010-11]Status: DisposedITAT Chandigarh20 Jan 2026AY 2010-11

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 850/Chd/2025 "नधा"रण वष" / Assessment Year : 2010-11 Sri Ram Health Care Private The Dcit, Limited, बनाम Circle. 81C/2 Epip Phase I, Parwanoo Vs. Jharmajari, Baddi, Himachal Pradesh 173205 "थायी लेखा सं./ Pan No: Aamcs5840H अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Manoj Kumar, Ca राज"व क" ओर से/ Revenue By : Dr.Ranjit Kaur, Addl. Cit, Sr. Dr

For Appellant: Sh. Manoj Kumar, CAFor Respondent: Dr.Ranjit Kaur, Addl. CIT, Sr. DR
Section 143(2)Section 143(3)Section 147Section 148Section 151(2)Section 68

…3. 5. The Id. CIT(A) is wrong in confirming the addition of Rs. 64,14,000/- under section 68 in the hands of the assessee company on account of share application money, contravening the binding judgment of Hon'ble SC in case of CIT vs Lovely Exports (P) Ltd.: 216 CTR 195, wherein it was clearly held that if the share application money is received by the assessee company from the shareholders, then the department is free to proceed to reopen their individual assessment. Since the said judgment was applicable to the assessee for the relevant assessment year 2010-11, so 850-Chd-2025 4 question of addition under sec…

AMPLEX PROJECTS PRIVATE LIMITED,AGARTALA vs. DCIT/ACIT, CIRCLE SILCHAR, SILCHAR

In the result, appeal of the assessee is allowed in above terms

ITA 333/GTY/2025[2013-14]Status: DisposedITAT Guwahati19 Jan 2026AY 2013-14

Bench: the Ld. CIT(A).

For Respondent: Shri Santosh Kumar Karnani, Addl. CIT
Section 1Section 139(1)Section 143(3)Section 153ASection 245DSection 245D(4)Section 250

…of the shareholders' register, share application forms, share transfer register, etc., it would constitute acceptable proof or acceptable explanation by the assessee. SLP filed by the Revenue against the aforesaid judgment was dismissed by the Supreme Court (216 CTR 195) and it was held that if the share application money is received by the assessee company from alleged bogus shareholders, whose names are given to the AO, then the Department is free to proceed to reopen their individual assessments in accordance with law, hut it cannot be regarded as undisclosed income of assessee company CIT vs Steller Investme…

MRS. RANJANA,MRIZAPUR vs. ASSESSING OFFICER, NFAC, DELHI

In the result, the appeal of the assessee is partly allowed

ITA 505/LKW/2025[2015-16]Status: DisposedITAT Lucknow31 Dec 2025AY 2015-16

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2015-16 Mrs Ranjana V. The Assessing Officer Village Dewapur Pachwal Nafc Post Rajapur, Aamghat Mirzapur (U.P) Tan/Pan:Aoxpr7130M (Applicant) (Respondent) Applicant By: Shri Narendra Kumar Sahu, Advocate Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 31.03.2025, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2015-16. 2.0 The Brief Facts Of The Case Are That The Assessee Had Not Filed Her Return Of Income For The Year Under Consideration. The Income Tax Department Was In Possession Of Information That The Assessee Had Purchased An Immovable Property Valued At Rs.60,00,000/- . The Case Of The Assessee Was Reopened Under Section 147 Of The Income Tax Act, 1961 (Hereinafter Called “The Act’) After Issuing Notice To The Assessee Under Section 148 Of The Act. However, The Assessee Neither Responded To The Notice Under Section 148 Of The Act Nor Filed Any Return Of Income For The Year Under Consideration. The Assessing Officer (Ao)

For Respondent: Shri R.R.N. Shukla, D.R
Section 142(1)Section 147Section 148Section 250Section 69

…ished the source of funds. 5. The addition of ₹1,00,000/-, received from Shri Dhananjay Singh as a friendly loan, was unjustified, as the transaction was fully explained. The addition is contrary to the law laid down in CIT vs. Lovely Exports (P) Ltd. [(2008) 216 CTR 195 (SC)]. 6. The addition of ₹30,000/-, being the TDS amount, was treated as unexplained without calling for any explanation from the appellant. Relevant supporting documents were available and could have been furnished if a proper opportunity had been provided. ITA No.505/LKW/2025 Page 5 of 9 7. The assessment order passed under Section 147 read…

Showing 1–20 of 772 · Page 1 of 39

...