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“short term capital gain”

Capital GainsSection 2(42A)Section 2(42A)1,986 judgments

The decision most relied on for short term capital gain is CIT v. Ace Builders (P) Ltd. (281 ITR 210), cited in 88 judgments on BharatTax.

Leading authorities on short term capital gain

CIT v. Ace Builders (P) Ltd.
281 ITR 210 · 2005 · High Court
88
citing judgments

The deeming fiction in Section 50, which treats capital gains from depreciable assets as short-term, applies only for the purpose of computing capital gains under that section. For other provisions, such as set-off of losses under Section 74 or deductions under Section 54E/54EC, the asset's original character (long-term or short-term) is to be considered.

CIT, Panji v. Dempo Company Limited
74 Taxmann.com 15 · 2016 · Supreme Court
62
citing judgments

The 20% tax rate under Section 112 applies to capital gains arising from the transfer of a depreciable asset, even if it is deemed a short-term capital gain under Section 50, provided the asset was held for more than 36 months. The fiction created by Section 50 for treating such gains as short-term does not alter the long-term nature of the asset for applying the tax rate under Section 112.

Raja Bahadur Kamakhya Narain Singh v. CIT
77 ITR 253 · 1970 · Supreme Court
49
citing judgments

The Supreme Court clarifies the distinction between income chargeable as capital gains and income taxable as business profits, guiding the assessment of whether a transaction constitutes a transfer of a capital asset or is in the nature of trade.

Indl. Development Co. (P) Ltd., 82 ITR 588 (SC). (ii). CIT v. H. Holck Larsen
288 ITR 641 · 2007 · Reported
41
citing judgments

Surplus received on sale and purchase of shares should be treated as capital gains (short-term or long-term as applicable) and not as business income.

Mrs. Madhu Kaul v. CIT
363 ITR 54 · 2014 · High Court
35
citing judgments

The period of holding a flat for capital gains purposes commences from the date of the allotment letter and the first installment payment, not from the later date of possession or registration.

Gopal Purohit v. JCIT
29 SOT 117 · 2009 · ITAT
33
citing judgments

The revenue is debarred from taking inconsistent stands on similar facts across different assessment years, adhering to the rule of consistency. Short-term capital gains are assessable under the head 'Capital Gains' only.

Raja Bahadur Visheshwar Singh v. CIT
73 ITR 652 · 1969 · Supreme Court
26
citing judgments

The intention of the assessee at the time of purchasing shares is a key criterion to determine capital gains treatment. This intention can be ascertained from how the purchase was treated in the assessee's books.

JCIT v. Montgomery Emerging Marketing Funds,\n
100 ITD 217 · 2006 · ITAT
23
citing judgments

Each transaction can be considered a separate source of income, allowing taxpayers to choose between the Income-tax Act and a Double Taxation Avoidance Agreement (DTAA) for each transaction. Section 70(2) of the Act does not prescribe an order for setting off specific short-term capital losses against specific short-term capital gains, favouring the taxpayer in interpretation.

Judgments citing short term capital gain

Bajaj Holdngs & Investment Ltd ( Erstwhile Bajaj Auto Ltd), Mumbai vs. Addl CIT RG 3(1), Mumbai

In the result, the appeal of the assessee is partly allowed and appeal of the revenue is dismissed

ITA 3043/MUM/2010[2002-013]Status: DisposedITAT Mumbai24 Jun 2024AY 2002-013

Bench: Shri Vikas Awasthy & Shri Amarjit Singhbajaj Holdings & Vs. Additional Commissioner Investment Ltd. Of Income-Tax, Range 3(1) Erstwile Bajaj Auto Ltd.) Aayakar Bhavan, Bajaj Bhavan, 226, M.K. Road, Nariman Point, Mumbai – 400 020 Mumbai – 400 021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacb3370K Appellant .. Respondent Dcit-3(4) Vs. M/S Bajaj Holding & Room No. 481-2, 4Th Floor, Investment Limited Aaykar Bhavan, (Erstwhile Bajaj Auto Ltd) Mumbai – 400020 226, Bajaj Bhavan, 2Nd Floor, Jamnalal Bajaj Marg, Nariman Point Mumbai – 400 021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacb3370K Appellant .. Respondent Appellant By : Percy Pardiwala & Vasanti Patel Respondent By : Ankush Kapoor

For Appellant: Percy Pardiwala &For Respondent: Ankush Kapoor
Section 143(3)Section 2(47)

bills, Ld. AR of the assessee brought to our notice the letter dated 10.03.2000. He submitted that Surplus on redemption was shown as short- term capital gains in the return of income out of abundant caution. Redemption results in total extinguishment of securities other than by way of transfer ... similar to the grounds of appeal raised in Ground No. (K). However, the surplus received on redemption of treasury bills was shown as short term capital gain in the return of income out of abundant caution by the assessee itself and the same was sustained by the Ld.CIT(A). However

Addl CIT RG 3(1), Mumbai vs. Bajaj Auto Ltd, Mumbai

In the result, the appeal of the assessee is partly allowed and appeal of the revenue is dismissed

ITA 2899/MUM/2010[2002-03]Status: DisposedITAT Mumbai24 Jun 2024AY 2002-03

Bench: Shri Vikas Awasthy & Shri Amarjit Singhbajaj Holdings & Vs. Additional Commissioner Investment Ltd. Of Income-Tax, Range 3(1) Erstwile Bajaj Auto Ltd.) Aayakar Bhavan, Bajaj Bhavan, 226, M.K. Road, Nariman Point, Mumbai – 400 020 Mumbai – 400 021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacb3370K Appellant .. Respondent Dcit-3(4) Vs. M/S Bajaj Holding & Room No. 481-2, 4Th Floor, Investment Limited Aaykar Bhavan, (Erstwhile Bajaj Auto Ltd) Mumbai – 400020 226, Bajaj Bhavan, 2Nd Floor, Jamnalal Bajaj Marg, Nariman Point Mumbai – 400 021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacb3370K Appellant .. Respondent Appellant By : Percy Pardiwala & Vasanti Patel Respondent By : Ankush Kapoor

For Appellant: Percy Pardiwala &For Respondent: Ankush Kapoor
Section 143(3)Section 2(47)

bills, Ld. AR of the assessee brought to our notice the letter dated 10.03.2000. He submitted that Surplus on redemption was shown as short- term capital gains in the return of income out of abundant caution. Redemption results in total extinguishment of securities other than by way of transfer ... similar to the grounds of appeal raised in Ground No. (K). However, the surplus received on redemption of treasury bills was shown as short term capital gain in the return of income out of abundant caution by the assessee itself and the same was sustained by the Ld.CIT(A). However

Ares Diversified, New Delhi vs. ACIT Central Intl. Taxation 1(1)(1), New Delhi

The appeals are allowed

ITA 2372/DEL/2023[2015-16]Status: DisposedITAT Delhi24 Jun 2024AY 2015-16

Bench: Dr. B.R.R. Kumar & Sh. Anubhav Sharma

Section 144CSection 144C(2)Section 144C(4)Section 147Section 148Section 151Section 3

detailed reply as to why such income was not offered by them for taxation in India. Additions were made on account of short term capital gains by rejecting benefit of DTAA by holding that assessee was into treaty shopping and there was fiscal evasion. 2.3 The DRP, examined the objections

Ares Diversified, New Delhi vs. ACIT Central Intl. Taxation 1(1)(1), New Delhi

The appeals are allowed

ITA 2371/DEL/2023[2014-15]Status: DisposedITAT Delhi24 Jun 2024AY 2014-15

Bench: Dr. B.R.R. Kumar & Sh. Anubhav Sharma

Section 144CSection 144C(2)Section 144C(4)Section 147Section 148Section 151Section 3

detailed reply as to why such income was not offered by them for taxation in India. Additions were made on account of short term capital gains by rejecting benefit of DTAA by holding that assessee was into treaty shopping and there was fiscal evasion. 2.3 The DRP, examined the objections

Sanjay Kumar Singh, Kolkata vs. ACIT, E-Assessment Centre, Delhi

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 453/KOL/2024[2020-21]Status: DisposedITAT Kolkata21 Jun 2024AY 2020-21

Bench: Shri Rajpal Yadav & Shri Rakesh Mishraassessment Year: 2020-21

For Appellant: Shri P. K. Ray, Advocate, Shri S. N. Patra & ShriFor Respondent: Shri B. K. Singh, Addl. CIT
Section 250Section 56(2)(x)

That, the Ld. Commissioner of Income Tax (Appeals) erred in upholding the addition of Rs.49,00,000/- in respect of short-term Capital Gain as information gathered from system of Income Tax Portal, it has not applied to the facts as the Appellant is a developer for constructing House Building ... nature and do not require any adjudication. 4. Ground no. 2 relates to the Ld. CIT(A) confirming the addition on account of short term capital gain amounting to Rs.49,00,000/-. 4.1. Brief facts of the case are that the assessee is an individual engaged in the business

Late Radha Kishin Bhatia (Through Leagl Heir Kishin M Bhatia), Mumbai vs. ITO, Int Tax Ward 1(2)1, Mumbai

In the result, ITA No.1084/Mum/2024 is allowed for statistical purposes

ITA 1084/MUM/2024[2012-13]Status: DisposedITAT Mumbai21 Jun 2024AY 2012-13

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: NoneFor Respondent: Shri Anil Sant – Addl.CITDR
Section 144Section 250

passed by the Income Tax Officer – (IT)-1(2)(1), Mumbai (The A.O) by making addition of Rs. 70,85,657/- of short term capital gains based on sales of shares as per AIR data: - a. The addition was made of total sale value of shares, ignoring the purchase cost ... months, which was admitted and mentioned in the order by CIT (A). Therefore, Appellant therefore prays that addition of Rs.70,85,657/- of short-term capital gains based on sales of shares as per AIR data may please be deleted. Ground 3 On the facts and circumstances of the case

Jitendra Udaylal Jain, Maharashtra vs. National Faceless Appeal Centre (NFAC), Delhi

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

ITA 4543/MUM/2023[2011-12]Status: DisposedITAT Mumbai21 Jun 2024AY 2011-12

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawal

Section 10(38)Section 143(1)Section 234ASection 271(1)(c)Section 68Section 69C

perusal of the details, the Assessing Officer found that the assessee has disclosed the income from salary, income from house property, business income, short term capital gains and income from other sources. Further the assessee has disclosed and claimed the exemption U/sec10(38) of the Act being long term capital

Naresh Vasantrai Trivedi, Nagpur vs. ACIT, Central Circle 1(3), Nagpur

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

ITA 108/NAG/2021[2014-15]Status: DisposedITAT Nagpur20 Jun 2024AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Kapil HiraniFor Respondent: Shri Kailash C. Kanojiya
Section 132Section 271(1)(c)

deleted in the interest of justice. 3) The Ld. CIT(A) grossly erred in assessing the capital gains from sale of jewellery as short-term capital gains. The capital gains on the sale of jewellery ought to be assessed based on the period of holding and in accordance with ... Thus, ground no.2, is hereby allowed. 11. Ground no.3, relates to the addition on account of capital gain from sale of jewellery as short term capital gain. Naresh Vasantrai Trivedi ITA no.108/Nag./2021 12. During the course of hearing, the learned Counsel for the assessee argued that the authorities below

Naresh Vasantrai Trivedi, Nagpur vs. ACIT, Central Circle 1(3), Nagpur

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

ITA 107/NAG/2021[2013-14]Status: DisposedITAT Nagpur20 Jun 2024AY 2013-14

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Kapil HiraniFor Respondent: Shri Kailash C. Kanojiya
Section 132Section 271(1)(c)

deleted in the interest of justice. 3) The Ld. CIT(A) grossly erred in assessing the capital gains from sale of jewellery as short-term capital gains. The capital gains on the sale of jewellery ought to be assessed based on the period of holding and in accordance with ... Thus, ground no.2, is hereby allowed. 11. Ground no.3, relates to the addition on account of capital gain from sale of jewellery as short term capital gain. Naresh Vasantrai Trivedi ITA no.108/Nag./2021 12. During the course of hearing, the learned Counsel for the assessee argued that the authorities below

Naresh Vasantrai Trivedi, Nagpur vs. ACIT, Central Circle 1(3), Nagpur

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

ITA 106/NAG/2021[2011-12]Status: DisposedITAT Nagpur20 Jun 2024AY 2011-12

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Kapil HiraniFor Respondent: Shri Kailash C. Kanojiya
Section 132Section 271(1)(c)

deleted in the interest of justice. 3) The Ld. CIT(A) grossly erred in assessing the capital gains from sale of jewellery as short-term capital gains. The capital gains on the sale of jewellery ought to be assessed based on the period of holding and in accordance with ... Thus, ground no.2, is hereby allowed. 11. Ground no.3, relates to the addition on account of capital gain from sale of jewellery as short term capital gain. Naresh Vasantrai Trivedi ITA no.108/Nag./2021 12. During the course of hearing, the learned Counsel for the assessee argued that the authorities below

Naresh Vasantraj Trivedi, Nagpur vs. ACIT, Central Circle 1(3), Nagpur

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

ITA 105/NAG/2021[2010-11]Status: DisposedITAT Nagpur20 Jun 2024AY 2010-11

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Kapil HiraniFor Respondent: Shri Kailash C. Kanojiya
Section 132Section 271(1)(c)

deleted in the interest of justice. 3) The Ld. CIT(A) grossly erred in assessing the capital gains from sale of jewellery as short-term capital gains. The capital gains on the sale of jewellery ought to be assessed based on the period of holding and in accordance with ... Thus, ground no.2, is hereby allowed. 11. Ground no.3, relates to the addition on account of capital gain from sale of jewellery as short term capital gain. Naresh Vasantrai Trivedi ITA no.108/Nag./2021 12. During the course of hearing, the learned Counsel for the assessee argued that the authorities below

Srk Dev Build Pvt Ltd., Indore vs. DCIT/ACIT 5(1), Indore

Appeal is allowed

ITA 471/IND/2023[2016-17]Status: DisposedITAT Indore20 Jun 2024AY 2016-17

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2016-17 Srk Dev Build Pvt. Ltd, Dcit/Acit-5(1) 18/2, Lasudia Mori, Indore बनाम/ A.B. Road, Vs. Indore (Assessee/Appellant) (Revenue/Respondent) Pan: Aaqcs3387P Assessee By Shri Pranay Goyal & S.N. Goyal, Cas Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 15.04.2024 Date Of Pronouncement 20.06.2024

Section 143(3)Section 271(1)(c)Section 274Section 32Section 32(1)Section 37Section 37(1)Section 40

from the record we found that the AO has accepted the income declared by the assessee. However, nature of income so offered as short term capital gain was not accepted by the AO and he changed the head of income to business income. Under the provisions of section ... income. However, both the conditions are absent in this case, since whatever income was declared was accepted and assessee declared full details of short term capital gains in shares with each script, period of holding etc. The transactions were through electronics system and assessee is also having a Demat account

Bay Capital India Fund Limited, Mauritius vs. Assistance Commissioner of Income Tax, Air India, Nariman Point, Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 4475/MUM/2023[2021-22]Status: DisposedITAT Mumbai20 Jun 2024AY 2021-22

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri Sukhsagar SyalFor Respondent: ShriAnil Sant – Addl.CIT DR
Section 143(3)Section 144C(5)

during the year, out of which brought forward capital losses of Rs.4,60,73,065/- have been adjusted. Similarly, the assessee had earned short term capital gains of Rs.8,15,63,722/- during the year out of which brought forward capital losses of Rs.3,26,08,435/- have been adjusted ... This has resulted in net short term capital gains of Rs.4,89,55,286/- during the impugned assessment year, which has been offered to tax at the rate of 15%.It is to be noted that even though the assessee has earned both types of gains during the year

Ankita Brijesh Patel, Ahmedabad vs. The Income Tax Officer, Ward-4(2)(1), Ahmedabad

In the result, appeal of the assessee is partly allowed for statistical purpose

ITA 101/AHD/2024[2010-11]Status: DisposedITAT Ahmedabad14 Jun 2024AY 2010-11

Bench: Ms. Suchitra Kambleassessment Year: 2010-11

Section 143(3)Section 147Section 263Section 50CSection 69C

order of assessing officer passed u/s. 147 r.w.s. 263 of the Act and thereby confirming the addition of Rs.2,18,894/- for short term capital gain and Rs.66,088/- U/s. 69C of the Act. 2. That the various reasons advanced by Id. CIT(A) in confirming the additions are contrary ... order under Section 263 of the Act, the Assessing Officer passed order dated 09.08.2021 making an addition of Rs.2,18,894/- in Short Term Capital Gain and Rs.66,088/- under Section 69C of the Act. 4. Being aggrieved by the Assessment Order, the assessee filed appeal before

P. Ravichandran, Chennai vs. DCIT, Central Circle 1(3), Chennai

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

ITA 582/CHNY/2024[2007-08]Status: DisposedITAT Chennai14 Jun 2024AY 2007-08

Bench: Shri Mahavir Singhand Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 582/Chny/2024 िनधा"रण वष"/Assessment Year: 2007-08 Dr. P. Ravichandran, The Deputy Commissioner No.3, Second Link Street, Vs. Of Income Tax, Raghava Reddy Colony, Central Circle – 1(3), Jaffarkhanpet, Chennai. Chennai – 600 083. Pan: Aahpr 0455M (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri G. Baskar, Advocate Shri I. Dinesh, Advocate ""यथ" क" ओर से/Respondent By : Shri N. Sanjay Gandhi, Jcit सुनवाई क" तारीख/Date Of Hearing : 11.06.2024 घोषणा क" तारीख/Date Of Pronouncement : 14.06.2024

For Appellant: Shri G. Baskar, AdvocateFor Respondent: Shri N. Sanjay Gandhi, JCIT
Section 132Section 143(3)Section 147Section 148Section 153ASection 54B

r.w.s. 148 of the Act by issuing notice u/s.148 of the Act dated 13.10.2010 on the reason that the assessee failed to disclose short term capital gain arising out of sale of property admeasuring 10.5 acres at Janakipuram, Maduranthakam. The reassessment order was passed vide order dated 26.12.2011 by making ... furnished by assessee during remand proceedings and AO in remand proceedings remanded by CIT(A) has shown the gain from land both as short term capital gain and profit from sale of land but now, was taken diametrically opposite stand during this proceeding. The ld.counsel for the assessee stated that

Jhaveri Trading and Investment Pvt.Ltd., Ahmedabad vs. The DCIT, Cent. Cir. 1(1), Ahmedabad

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

ITA 403/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad13 Jun 2024AY 2014-15

Bench: Shri Waseem Ahmed & Shri Tr Senthil Kumarआयकर अपील सं./Ita Nos. 401 To 403/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2012-2013 To 2014-2015) & आयकर अपील सं./Ita Nos. 399 & 400/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2010-2011 & 2011-12)

For Appellant: Shri Deepak Shah, ARFor Respondent: Shri Sudhendu Das, CIT.DR
Section 132(4)Section 68

maintaining 212 companies which were utilized for layering the funds, generating bogus share application money, unsecured loans, long-term capital gain, short term capital gain. The “cash and cheque sheets” contained the information of the intermediaries who were engaged in introducing the clients to SCS for providing the accommodation entries

Jhaveri Trading and Investment Pvt.Ltd., Ahmedabad vs. The DCIT, Cent. Cir. 1(1), Ahmedabad

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

ITA 402/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad13 Jun 2024AY 2013-14

Bench: Shri Waseem Ahmed & Shri Tr Senthil Kumarआयकर अपील सं./Ita Nos. 401 To 403/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2012-2013 To 2014-2015) & आयकर अपील सं./Ita Nos. 399 & 400/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2010-2011 & 2011-12)

For Appellant: Shri Deepak Shah, ARFor Respondent: Shri Sudhendu Das, CIT.DR
Section 132(4)Section 68

maintaining 212 companies which were utilized for layering the funds, generating bogus share application money, unsecured loans, long-term capital gain, short term capital gain. The “cash and cheque sheets” contained the information of the intermediaries who were engaged in introducing the clients to SCS for providing the accommodation entries

Jhaveri Trading and Investment Pvt.Ltd., Ahmedabad vs. The DCIT, Cent. Cir. 1(1), Ahmedabad

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

ITA 401/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad13 Jun 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Tr Senthil Kumarआयकर अपील सं./Ita Nos. 401 To 403/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2012-2013 To 2014-2015) & आयकर अपील सं./Ita Nos. 399 & 400/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2010-2011 & 2011-12)

For Appellant: Shri Deepak Shah, ARFor Respondent: Shri Sudhendu Das, CIT.DR
Section 132(4)Section 68

maintaining 212 companies which were utilized for layering the funds, generating bogus share application money, unsecured loans, long-term capital gain, short term capital gain. The “cash and cheque sheets” contained the information of the intermediaries who were engaged in introducing the clients to SCS for providing the accommodation entries

Jhaveri Trading and Investment Pvt.Ltd., Ahmedabad vs. The DCIT, Cent. Cir. 1(1), Ahmedabad

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

ITA 400/AHD/2023[2011-12]Status: DisposedITAT Ahmedabad13 Jun 2024AY 2011-12

Bench: Shri Waseem Ahmed & Shri Tr Senthil Kumarआयकर अपील सं./Ita Nos. 401 To 403/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2012-2013 To 2014-2015) & आयकर अपील सं./Ita Nos. 399 & 400/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2010-2011 & 2011-12)

For Appellant: Shri Deepak Shah, ARFor Respondent: Shri Sudhendu Das, CIT.DR
Section 132(4)Section 68

maintaining 212 companies which were utilized for layering the funds, generating bogus share application money, unsecured loans, long-term capital gain, short term capital gain. The “cash and cheque sheets” contained the information of the intermediaries who were engaged in introducing the clients to SCS for providing the accommodation entries

Jhaveri Trading and Investment Pvt.Ltd., Ahmedabad vs. The DCIT, Cent. Cir. 1(1), Ahmedabad

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

ITA 399/AHD/2023[2010-11]Status: DisposedITAT Ahmedabad13 Jun 2024AY 2010-11

Bench: Shri Waseem Ahmed & Shri Tr Senthil Kumarआयकर अपील सं./Ita Nos. 401 To 403/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2012-2013 To 2014-2015) & आयकर अपील सं./Ita Nos. 399 & 400/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2010-2011 & 2011-12)

For Appellant: Shri Deepak Shah, ARFor Respondent: Shri Sudhendu Das, CIT.DR
Section 132(4)Section 68

maintaining 212 companies which were utilized for layering the funds, generating bogus share application money, unsecured loans, long-term capital gain, short term capital gain. The “cash and cheque sheets” contained the information of the intermediaries who were engaged in introducing the clients to SCS for providing the accommodation entries