PCIT v. Smt. Renu Aggarwal

456 ITR 249Supreme Court of India2023#2004 most cited

What is PCIT v. Smt. Renu Aggarwal authority for?

Additions for alleged bogus long term capital gain from penny stocks are not sustainable if based solely on third-party statements without establishing the assessee's direct nexus to price rigging, especially when share transactions are through banking channels and held for a reasonable period.

57

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2023 to 2026.

Also referred to as

PCIT v. Smt. Renu Aggarwal · Section 68 · Section 10(38) · Section 69C · bogus long term capital gain · penny stock · price rigging · third party statement · deletion of addition · share transactions

Sections most often in play

Section 68Section 10(38)Section 69CSection 147Section 143(3)Section 148Section 131Section 133(6)

Issues it is cited on

price riggingbogus long term capital gainbogus ltcgpenny stocksection 10(38)principal officerfresh tangible materialsection 2(40)period of holdinglong term capital gainsmaterial facts necessary for assessmentsection 111a

Judgments citing PCIT v. Smt. Renu Aggarwal

REEMA AGARWAL,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

ITA 353/HYD/2021[2014-15]Status: DisposedITAT Hyderabad26 Feb 2026AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita No.353/Hyd./2021

For Appellant: CA P Murali Mohan RaoFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 111ASection 139(1)

…ot at all relevant to question the market price prevailing on the relevant dates on the stock exchange. The learned Authorised Representative of the Assessee has relied upon the Judgment of Hon'ble Supreme Court in the case of Pr. CIT vs. Renu Aggarwal [2023] 456 ITR 249 (SC) and submitted that the SLP filed by the Revenue was dismissed by the Hon'ble Supreme Court against the Judgment of Hon'ble Allahabad High Court reported in [2023] 153 taxmann.com 578 (Allahabad-HC). He has also relied upon the Judgment of Hon'ble Supreme Court in the case of Pr. CIT vs. Kishore Kumar Mohapatra [2024] 162 taxmann.com 5 (SC) w…

INCOME TAX OFFICER-16(3)(1), MUMBAI, MUMBAI vs. TEJPRAKASH SOHAN LAL DANGI, MUMBAI

ITA 7624/MUM/2025[2014-15]Status: DisposedITAT Mumbai25 Feb 2026AY 2014-15

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Prakash JhujhunwalaFor Respondent: Shri Hemanshu Joshi, Sr. DR
Section 10(38)Section 131Section 143(3)Section 144Section 68Section 69C

…ly structured with the sole intention to evade tax. Accordingly he contended that the order passed by the learned CIT(A) should be confirmed. 8. In the rejoinder, the A.R further submitted that Hon'ble Supreme Court in the case of PCIT Vs. Smt. Renu Aggarwal (456 ITR 249) has affirmed the decision rendered by Hon'ble Allahabad High Court, wherein the Hon'ble High Court had held that the Assessing Officer could not have made the addition on the basis of the facts pertaining to completely unrelated person. In the instant case also, the Assessing Officer has drawn adverse inference on the basis of the general report…

ARVIND BHAGUJI KANGANE,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE-27(1), MUMBAI, MUMBAI

In the result, ground no. 2 and 3 of appeal are

ITA 4158/MUM/2025[2016-17]Status: DisposedITAT Mumbai22 Jan 2026AY 2016-17

Bench: Shri Pawan Singh & Ms. Padmavathy S(Physical Hearing) Arvind Bhanguji Kangane Dcit, Circle – 27(1), Mumbai Shreyas Building, 11Th Road, Plot No. 4Th Floor, Tower No. 6, Vashi Vs 553, Flat No. 901, 9Th Floor, Opp. Railway Station Building, Navi Heritage Pride Building, Chembur, Mumbai – 400703. Mumbai – 400026. [Pan: Afypk1856R] Appellant / Assessee Respondent / Revenue

Section 10(38)Section 143(1)Section 144BSection 147Section 148Section 151ASection 254(1)Section 68

…d. Assessment in the present case was completed on 23.03.2022, hence such assessment order is bad in law being without legal sanction. To support his submission on merit, the ld. AR of the assessee relied upon following decision:  PCIT vs Smt. Renu Aggarwal 456 ITR 249 (SC)  PCIT vs ParasbenKasturchand Kochar 130 Taxmann.com 177 (SC) & 130 Taxmann.com 176 (Guj-HC)  PCIT-31 vs Indravadan Jain HUF ITA No. 454 of 2018 (Bom-HC)  PCIT-3 vs Ziauddin A Siddique ITA No. 2012 of 2017 (Bom-HC)  CIT vs Shyam R. Pawar 54 taxmann.com 108 (Bom-HC) 7 Arvind Bhaguji Kangane  CIT vs Smt. Jamnadevi Agrawal 20 Taxmann.com…

SINDHUMATI RAMAVTAR PATHAK,BORIVALI MUMBAI vs. ASST COMMISSIONER OF INCOME TAX 32 3 MUMBAI PRESENTLY DY C I T CIRCLE 42 3 1 MUMBAI, MUMBAI

In the result, Assessee’s appeal is allowed

ITA 4914/MUM/2025[2015-16]Status: DisposedITAT Mumbai24 Dec 2025AY 2015-16

Bench: Shri Narender Kumar Choudhry (Jm) & Shri Prabhash Shankar (Am) Sindhumati Ramavtar Pathak Acit-32(3) 4, Shree Bhalchandra Kripa Presently Cit, Circle Building, Daulat Nagar Road Vs. 42(3)(1) No. 3, Borivali East Kautilya Bhavan Bkc, Mumbai-400 066. Mumbai-51. Pan : Agbpp5972D Appellant Respondent

For Appellant: Shri Jitendra Singh, Ld. ADVFor Respondent: Ms. Kavitha Kaushik, Ld. DR
Section 10(38)Section 250Section 68Section 69C

…re is no nexus with the Assessee with price rigging and no adverse observation from stock exchange. The addition simply on third party statement is uncalled for. We respectfully relied on the order of Hon'ble Supreme Court in PCIT vs Smt. Renu Aggarwal [2023] 456 ITR 249 (SC). We respectfully rely on the orders of the Hon'ble Apex Court, Jurisdictional High Court and Coordinate Bench of ITAT Mumbai which has similar in the factual matrix with the impugned issue. The grounds of appeal of the assessee are upheld. We set aside the impugned appeal order. The additions amount to Rs. Rs.47,51,164/- U/s 68 of the Act an…

DEPUTY COMMISSIONER OF INCOME TAX, JALGAON vs. TARADEVI RATANLAL BAFNA, JALGAON

In the result, all the above 6 appeals filed by the Revenue are dismissed and

ITA 497/PUN/2025[2013-14]Status: DisposedITAT Pune27 Oct 2025AY 2013-14

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Suchek Anchaliya andFor Respondent: Shri Amit Bobde, CIT
Section 10(38)Section 132Section 143(3)Section 147Section 148Section 153A

…ital gain on purchase and sale transactions undertaken by the assessee treating the same as bogus in nature and thereby making addition of Rs.80,58,939/-. 31. Referring to the decision of the Hon'ble Supreme Court in the case of PCIT vs. Renu Aggarwal (2023) 456 ITR 249 (SC), he submitted that the Hon'ble Supreme Court dismissed the SLP filed by the Revenue against the order of Hon'ble Allahabad High Court where the Hon'ble High Court has upheld the decision of the Tribunal upholding the order of the Ld. CIT(A) deleting the addition made by the Assessing Officer wherein the Assessing Officer has treated the long…

ASSISTANT COMMISSIONER OF INCOME TAX, JALGAON vs. SIDHARTH RATANLAL BAFNA, JALGAON

In the result, all the above 6 appeals filed by the Revenue are dismissed and

ITA 1565/PUN/2024[2018-19]Status: DisposedITAT Pune27 Oct 2025AY 2018-19

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Suchek Anchaliya andFor Respondent: Shri Amit Bobde, CIT
Section 10(38)Section 132Section 143(3)Section 147Section 148Section 153A

…ital gain on purchase and sale transactions undertaken by the assessee treating the same as bogus in nature and thereby making addition of Rs.80,58,939/-. 31. Referring to the decision of the Hon'ble Supreme Court in the case of PCIT vs. Renu Aggarwal (2023) 456 ITR 249 (SC), he submitted that the Hon'ble Supreme Court dismissed the SLP filed by the Revenue against the order of Hon'ble Allahabad High Court where the Hon'ble High Court has upheld the decision of the Tribunal upholding the order of the Ld. CIT(A) deleting the addition made by the Assessing Officer wherein the Assessing Officer has treated the lon…

ASSISTANT COMMISSIONER OF INCOME TAX, JALGAON vs. SIDHARTH RATANLAL BAFNA, JALGAON

In the result, all the above 6 appeals filed by the Revenue are dismissed and

ITA 1555/PUN/2024[2013-14]Status: DisposedITAT Pune27 Oct 2025AY 2013-14

Bench: Shri R. K. Panda & Ms Astha Chandra

For Respondent: S/Shri Suchek Anchaliya and
Section 10(38)Section 132Section 143(3)Section 147Section 148Section 153A

…ital gain on purchase and sale transactions undertaken by the assessee treating the same as bogus in nature and thereby making addition of Rs.80,58,939/-. 31. Referring to the decision of the Hon'ble Supreme Court in the case of PCIT vs. Renu Aggarwal (2023) 456 ITR 249 (SC), he submitted that the Hon'ble Supreme Court dismissed the SLP filed by the Revenue against the order of Hon'ble Allahabad High Court where the Hon'ble High Court has upheld the decision of the Tribunal upholding the order of the Ld. CIT(A) deleting the addition made by the Assessing Officer wherein the Assessing Officer has treated 31 ITA…

INCOME TAX OFFICER, DELHI vs. MEGHA GARG, DELHI

In the result, the appeal filed by the assessee is allowed

ITA 3488/DEL/2025[2013-14]Status: DisposedITAT Delhi27 Oct 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] Income Tax Officer, Megha Garg, 1707 E-2 Block Civic Centre, 160 Saraswati Vihar Vaishali, New Delhi-110002 Vs Pitampura, Delhi-110034 Pan-Aecpg7098C Appellant Respondent

Section 10(38)Section 147Section 68Section 69A

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘E’: NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER AND SHRI AMITABH SHUKLA, ACCOUNTNAT MEMBER [Assessment Year: 2013-14] Income Tax Officer, Megha Garg, 1707 E-2 Block Civic Centre, 160 Saraswati Vihar Vaishali, New Delhi-110002 Vs Pitampura, Delhi-110034 PAN-AECPG7098C Appellant Respondent Assessee by Shri Suresh Kumar Gupta, CA Revenue by Ms. Ankush Kalra, Sr. DR Date of Hearing 14.10.2025 Date of Pronouncement 27.10.2025 ORDER PER AMITABH SHUKLA, AM, This appeal has been preferred by the Revenue against order dated 29.03.2025 of National Faceless App…

DCIT CC-8(4), MUMBAI, MUMBAI vs. OSCAR INFRA PRIVATE LIMITED, NAVI MUMBAI

In the result, the appeal filed by the revenue stands dismissed

ITA 847/MUM/2025[2011-12]Status: DisposedITAT Mumbai13 Oct 2025AY 2011-12

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankardcit, Cc-8(4) Vs. Oscar Infra Pvt Ltd Room No. 659, 6Th Floor, Office No. 707, 7Th Aayakar Bhavan, Mk Road Floor, Everest Nivara, Churchgate, Mumbai – Infotech Park, Plot No. 400020. D/3, Ttc Industrial Area, Midc Pan/Gir No. Aabco0152H (Applicant) (Respondent)

Section 70(2)

…essed raises any substantial question of law. 6. The appeal is devoid of merits and it is dismissed with no order as to costs. 11 Oscar Infra Pvt Ltd, Mumbai. 5.3 We further observe that the Hon'ble Apex Court in the case of Pr. CIT vs. Renu Agarwal (2023) 456 ITR 249(SC) has dismissed the SLP against the judgment passed in ITA No.44 of 2022 on 06.07.2022 by the Hon'ble Allahabad High Court, wherein the Hon'ble High Court has also dealt with the identical issue as involved in the instant case and ultimately affirmed the deletion of identical addition allegedly made on penny stock, by holding as under: "Judgmen…

RATAN BHAUBALI BHALWANKAR ,MUMBAI vs. ACIT-16(3), MUMBAI

In the result, the appeal is partly allowed

ITA 1808/MUM/2024[2014-15]Status: DisposedITAT Mumbai13 Oct 2025AY 2014-15

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarmr. Ratan Bahubali V/S. Assistant Commissioner Of Bhalwankar बनाम Income Tax – 16(3), C/O – 2Nd Floor, Gita Aayakar Bhavan, Mumbai - Building, Sion Circle, 400021, Maharashtra Mumbai - 400 022, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aacpb7285Q Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Margav Shukla, Adv and Shubham ShahFor Respondent: Shri Annavaran Kasuri, (Sr. AR)
Section 10(38)Section 143(2)Section 143(3)Section 68Section 69C

…e was no merit in the appeal. 5. We also find no infirmity in the order passed by the ITAT and no substantial questions of law as proposed in the appeal arises." 7.4 We further observe that the Hon'ble Apex Court in the case of Pr. CIT vs. Renu Agarwal (2023) 456 ITR 249(SC) has dismissed the SLP against the judgment passed in ITA No.44 of 2022 on 06.07.2022 by the Hon'ble Allahabad High Court, wherein the Hon'ble High Court has also dealt with the identical issue as involved in the instant case and ultimately affirmed the deletion of identical addition allegedly made on penny stock, by holding as under: "Judgmen…

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. ASHISH OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

ITA 148/PUN/2024[2012]Status: DisposedITAT Pune17 Jul 2025

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR
Section 10(38)Section 132Section 143(2)Section 143(3)Section 147Section 148Section 151

…o assessee was found in investigation wing report, additions made by AO had rightly been deleted. 22. He submitted that when the Revenue has challenged the above decision, the Hon’ble Supreme Court dismissed the SLP filed by the Revenue as reported in (2023) 456 ITR 249 (SC). 23. Referring to the decision of the Hon’ble Orissa High Court in the case of PCIT vs. Kuntala Mohapatra (2024) 466 ITR 47 (Orissa), he submitted that the Hon’ble High Court in the said decision has held that where shares were purchased via Account Payee Cheques, held in a Demat Account for over 12 months, and assessee was eligible to clai…

INCOME TAX OFFICER, WARD -1, JALNA, JALNA vs. PRAMILA OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

ITA 146/PUN/2024[2012]Status: DisposedITAT Pune17 Jul 2025

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR
Section 10(38)Section 132Section 143(2)Section 143(3)Section 147Section 148Section 151

…o assessee was found in investigation wing report, additions made by AO had rightly been deleted. 22. He submitted that when the Revenue has challenged the above decision, the Hon’ble Supreme Court dismissed the SLP filed by the Revenue as reported in (2023) 456 ITR 249 (SC). 23. Referring to the decision of the Hon’ble Orissa High Court in the case of PCIT vs. Kuntala Mohapatra (2024) 466 ITR 47 (Orissa), he submitted that the Hon’ble High Court in the said decision has held that where shares were purchased via Account Payee Cheques, held in a Demat Account for over 12 months, and assessee was eligible to clai…

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. PRAMILA OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

ITA 145/PUN/2024[2011]Status: DisposedITAT Pune17 Jul 2025

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR
Section 10(38)Section 132Section 143(2)Section 143(3)Section 147Section 148Section 151

…o assessee was found in investigation wing report, additions made by AO had rightly been deleted. 22. He submitted that when the Revenue has challenged the above decision, the Hon’ble Supreme Court dismissed the SLP filed by the Revenue as reported in (2023) 456 ITR 249 (SC). 23. Referring to the decision of the Hon’ble Orissa High Court in the case of PCIT vs. Kuntala Mohapatra (2024) 466 ITR 47 (Orissa), he submitted that the Hon’ble High Court in the said decision has held that where shares were purchased via Account Payee Cheques, held in a Demat Account for over 12 months, and assessee was eligible to clai…

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. ATUL OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

ITA 143/PUN/2024[2012]Status: DisposedITAT Pune17 Jul 2025

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR
Section 10(38)Section 132Section 143(2)Section 143(3)Section 147Section 148Section 151

…o assessee was found in investigation wing report, additions made by AO had rightly been deleted. 22. He submitted that when the Revenue has challenged the above decision, the Hon’ble Supreme Court dismissed the SLP filed by the Revenue as reported in (2023) 456 ITR 249 (SC). 23. Referring to the decision of the Hon’ble Orissa High Court in the case of PCIT vs. Kuntala Mohapatra (2024) 466 ITR 47 (Orissa), he submitted that the Hon’ble High Court in the said decision has held that where shares were purchased via Account Payee Cheques, held in a Demat Account for over 12 months, and assessee was eligible to clai…

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. ATUL OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

ITA 142/PUN/2024[2011]Status: DisposedITAT Pune17 Jul 2025

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR
Section 10(38)Section 132Section 143(2)Section 143(3)Section 147Section 148Section 151

…o assessee was found in investigation wing report, additions made by AO had rightly been deleted. 22. He submitted that when the Revenue has challenged the above decision, the Hon’ble Supreme Court dismissed the SLP filed by the Revenue as reported in (2023) 456 ITR 249 (SC). 23. Referring to the decision of the Hon’ble Orissa High Court in the case of PCIT vs. Kuntala Mohapatra (2024) 466 ITR 47 (Orissa), he submitted that the Hon’ble High Court in the said decision has held that where shares were purchased via Account Payee Cheques, held in a Demat Account for over 12 months, and assessee was eligible to clai…

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. OMPRAKASH ASARAM MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

ITA 141/PUN/2024[2012]Status: DisposedITAT Pune17 Jul 2025

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR
Section 10(38)Section 132Section 143(2)Section 143(3)Section 147Section 148Section 151

…o assessee was found in investigation wing report, additions made by AO had rightly been deleted. 22. He submitted that when the Revenue has challenged the above decision, the Hon’ble Supreme Court dismissed the SLP filed by the Revenue as reported in (2023) 456 ITR 249 (SC). 23. Referring to the decision of the Hon’ble Orissa High Court in the case of PCIT vs. Kuntala Mohapatra (2024) 466 ITR 47 (Orissa), he submitted that the Hon’ble High Court in the said decision has held that where shares were purchased via Account Payee Cheques, held in a Demat Account for over 12 months, and assessee was eligible to clai…

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. OMPRAKASH ASARAM MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

ITA 140/PUN/2024[2011]Status: DisposedITAT Pune17 Jul 2025

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR
Section 10(38)Section 132Section 143(2)Section 143(3)Section 147Section 148Section 151

…o assessee was found in investigation wing report, additions made by AO had rightly been deleted. 22. He submitted that when the Revenue has challenged the above decision, the Hon’ble Supreme Court dismissed the SLP filed by the Revenue as reported in (2023) 456 ITR 249 (SC). 23. Referring to the decision of the Hon’ble Orissa High Court in the case of PCIT vs. Kuntala Mohapatra (2024) 466 ITR 47 (Orissa), he submitted that the Hon’ble High Court in the said decision has held that where shares were purchased via Account Payee Cheques, held in a Demat Account for over 12 months, and assessee was eligible to clai…

JAYESH SOJPAR KARNIA HUF,MUMBAI vs. INCOME TAX OFFICER-WARD 30(1)(5), MUMBAI

In the result, the appeal filed by the Assessee is allowed

ITA 4034/MUM/2023[2014-15]Status: DisposedITAT Mumbai01 May 2025AY 2014-15

Bench: Shri Narender Kumar Choudhryassessment Year: 2014-15

For Appellant: Shri Shashank Mehta, Ld. A.RFor Respondent: Shri Srinivas P., Ld. Sr.D.R
Section 10(38)Section 250Section 68Section 69C

…re is no nexus with the Assessee with price rigging and no adverse observation from stock exchange. The addition simply on third party statement is uncalled for. We respectfully relied on the order of Hon'ble Supreme Court in PCIT vs Smt. Renu Aggarwal [2023] 456 ITR 249 (SC). We respectfully rely on the orders of the Hon'ble Apex Court, Jurisdictional High Court and Coordinate Bench of ITAT Mumbai which has similar in the factual matrix with the impugned issue. The grounds of appeal of the assessee are upheld. We set aside the impugned appeal order. The additions amount to Rs. Rs.47,51,164/- U/s 68 of the Act a…

SHRI RAJENDRA M. JAIN,MUMBAI vs. ITO WD 19(3) (11), MUMBAI

In the result, all the three appeals filed by the assessee are allowed

ITA 775/MUM/2022[2015-16]Status: DisposedITAT Mumbai09 Apr 2025AY 2015-16

Bench: Shri B.R. Baskaran & Shri Narender Kumar Choudhry

For Appellant: Ms. Ridhisha Jain a/wFor Respondent: Shri R.R. Makwana, Sr. DR
Section 10(38)Section 68

…find the buyers of shares in the online mode. He submitted that the report given by the investigation wing is related to some other persons and not that of the assessee. She submitted that the Hon'ble Supreme Court in the case of PCIT Vs. Smt. Renu Aggarwal (456 ITR 249) has affirmed the decision rendered by Hon'ble Allahabad High Court, wherein the Hon’ble High Court had held that the Assessing Officer could not have made the addition on the basis of the facts pertaining to completely unrelated person. 9. We heard the parties and perused the record. We notice that the assessing officer has primarily placed reli…

SHRI RAJENDRA M. JAIN,MUMBAI vs. ITO WD 19(3) (11), MUMBAI

In the result, all the three appeals filed by the assessee are allowed

ITA 774/MUM/2022[2014-15]Status: DisposedITAT Mumbai09 Apr 2025AY 2014-15

Bench: Shri B.R. Baskaran & Shri Narender Kumar Choudhry

For Appellant: Ms. Ridhisha Jain a/wFor Respondent: Shri R.R. Makwana, Sr. DR
Section 10(38)Section 68

…find the buyers of shares in the online mode. He submitted that the report given by the investigation wing is related to some other persons and not that of the assessee. She submitted that the Hon'ble Supreme Court in the case of PCIT Vs. Smt. Renu Aggarwal (456 ITR 249) has affirmed the decision rendered by Hon'ble Allahabad High Court, wherein the Hon’ble High Court had held that the Assessing Officer could not have made the addition on the basis of the facts pertaining to completely unrelated person. 9. We heard the parties and perused the record. We notice that the assessing officer has primarily placed reli…

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PCIT v. Smt. Renu Aggarwal (456 ITR 249) — Cited in 57 Judgments | BharatTax