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“buyback of shares”

Capital GainsSection 46A / 115QASection 46A / 115QA51 judgments

ACIT, CHENNAI vs. UPDATER SERVICES LIMITED, CHENNAI

In the result, the grounds of appeal raised by both the assessee and the Revenue, as well as the grounds raised in the cross-objections filed by the assessee, are treated as allowed for statistical...

ITA 1616/CHNY/2025[2017]Status: DisposedITAT Chennai14 Nov 2025

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1339 /Chny/2025 िनधा#रण वष# / Assessment Year: 2017-18 M/S. Updater Services Limited (Formerly Dcit, Known As Updater Services Private Vs. Central Circle -2(3), Limited), No.2/302-A, Uds Salai, Chennai. Off Old Mahabalipuram Road, Thoraipakkam, Chennai – 600 097. [Pan:Aaacu-6845-J] (अपीलाथ%/Appellant) (&'थ%/Respondent)

For Appellant: Shri. K. Prasanna, C.AFor Respondent: Ms. E. Pavuna Sundari, C.I.T
Section 115QSection 250Section 263Section 391Section 77A

learned CIT(A) erred in law in holding that the provisions of Section 77A of the Companies Act, 1956 apply to the buyback of shares undertaken by the Appellant under Section 391-394 of the Companies Act, 1956 without appreciating the fact that the limits, procedure, and compliances prescribed under ... provisions. 3. The Ld. CIT(A) erred in allowing the appeal of the assessee without appreciating that in a case of buyback of shares, shares being the property which exchanges hands from the transferor to the transferee, who had earlier issued the shares either for consideration which if found

M/S. UPDATER SERVICES LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-2(3), CHENNAI

In the result, the grounds of appeal raised by both the assessee and the Revenue, as well as the grounds raised in the cross-objections filed by the assessee, are treated as allowed for statistical...

ITA 1339/CHNY/2025[2017-18]Status: DisposedITAT Chennai14 Nov 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1339 /Chny/2025 िनधा#रण वष# / Assessment Year: 2017-18 M/S. Updater Services Limited (Formerly Dcit, Known As Updater Services Private Vs. Central Circle -2(3), Limited), No.2/302-A, Uds Salai, Chennai. Off Old Mahabalipuram Road, Thoraipakkam, Chennai – 600 097. [Pan:Aaacu-6845-J] (अपीलाथ%/Appellant) (&'थ%/Respondent)

For Appellant: Shri. K. Prasanna, C.AFor Respondent: Ms. E. Pavuna Sundari, C.I.T
Section 115QSection 250Section 263Section 391Section 77A

learned CIT(A) erred in law in holding that the provisions of Section 77A of the Companies Act, 1956 apply to the buyback of shares undertaken by the Appellant under Section 391-394 of the Companies Act, 1956 without appreciating the fact that the limits, procedure, and compliances prescribed under ... provisions. 3. The Ld. CIT(A) erred in allowing the appeal of the assessee without appreciating that in a case of buyback of shares, shares being the property which exchanges hands from the transferor to the transferee, who had earlier issued the shares either for consideration which if found

SILGATE SOLUTIONS LIMITED,MUMBAI vs. DCIT-3(2)(1), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 5367/MUM/2025[2013-14]Status: DisposedITAT Mumbai04 Nov 2025AY 2013-14

Bench: or at the time of hearing of the matter with the Income Tax Appellate Tribunal." 2. The assessee is a company engaged in the business of international call centre. The assessee filed a return of income for AY 2013-14 on 24.10.2013, declaring total income of Rs.92,36,060/-. The case was selected for scrutiny and statutory notices were duly served on the assessee. During the assessment proceedings the AO noticed that there was change in the shareholding pattern of the assessee wherein the ass

For Appellant: Shri. SwapnilChoudhary Sr. AR
Section 234ASection 250Section 56(2)Section 56(2)(viia)

confirming the addition of Rs. 1,44,75,000/- u/s 56(2) (viia) of the Income tax Act, 1961, on account of buyback of shares during the year. 4.Interest u/s 234A, 234B and 234C On merits, the Appellant denies its liability to the levy of penal interest u/s. 234A, 234B ... wanted to discontinue their investments. The ld. AR also submitted that since there were no buyers for the shares the assessee offered to buyback the shares at face 4 Silgate Solutions limited value. The ld. AR argued that the financial and cash flow position of the company was deteriorating

NV PROJECTS PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 1(2)(2), MUMBAI

In the result, appeal of the assessee is allowed and appeal of the\nrevenue is dismissed

ITA 1418/MUM/2025[2017-18]Status: DisposedITAT Mumbai18 Sept 2025AY 2017-18

Bench: SHRI SAKTIJIT DEY, HON'BLE VICE PRESIDENT\n&\nSHRI NARENDRA KUMAR BILLAIYA, HON'BLE ACCOUNTANT MEMBER\nI.T.A. No. 1418/Mum/2025\nAssessment Year: 2017-18\nN V Projects Private Limited\nGround Floor, Block D\nS. No. 30/3, 31/1 & 2A\nWeikfield IT Citi Info Park\nViman Nagar\nPune - 411041\n[PAN: AACCD2669P]\nअपीलार्थी/ (Appellant)\nVs\nDeputy Commissioner of\nIncome Tax, Circle 1(2)(2),\nMumbai\nप्रत्यर्थी / (Respondent)\nI.T.A. No. 1025/Mum/2025\nAssessment Year: 2017-18\nDeputy Commissioner

For Appellant: Shri Vijay Mehta, A/RFor Respondent: Shri Satyaprakash R. Singh, CIT, D/R
Section 36(1)(iii)

Income-fax\nAct, 1961, on the capital reduction undertaken by the assessee, failing to appreciate\nthat the said transaction amounts to buyback of shares and distribution of profits,\nand is therefore liable to tax as per the provisions of the said section 115QA of the\nAct?\"\n2. \"Whether ... that the substance of a transaction must he considered over its form, and\nthereby overlooking that the capital reduction was, in effect, a buyback of shares?\"\n4.\n\"Whether on the facts and in the circumstances of the case and in law, the\nLd. CIT(A) erred in disregarding

DCIT-5(2)(1), MUMBAI vs. N V PROJECT PRIVATE LIMITED, MUMBAI

In the result, appeal of the assessee is allowed and appeal of the\nrevenue is dismissed

ITA 1025/MUM/2025[2017-18]Status: DisposedITAT Mumbai18 Sept 2025AY 2017-18

Bench: SHRI SAKTIJIT DEY, HON'BLE VICE PRESIDENT\n&\nSHRI NARENDRA KUMAR BILLAIYA, HON'BLE ACCOUNTANT MEMBER\nI.T.A. No. 1418/Mum/2025\nAssessment Year: 2017-18\nN V Projects Private Limited\nGround Floor, Block D\nS. No. 30/3, 31/1 & 2A\nWeikfield IT Citi Info Park\nViman Nagar\nPune - 411041\n[PAN: AACCD2669P]\nअपीलार्थी/ (Appellant)\nVs\nDeputy Commissioner of\nIncome Tax, Circle 1(2)(2),\nMumbai\nप्रत्यर्थी / (Respondent)\nI.T.A. No. 1025/Mum/2025\nAssessment Year: 2017-18\nDeputy Commissioner

For Appellant: Shri Vijay Mehta, A/RFor Respondent: Shri Satyaprakash R. Singh, CIT, D/R
Section 36(1)(iii)

Income-fax\nAct, 1961, on the capital reduction undertaken by the assessee, failing to appreciate\nthat the said transaction amounts to buyback of shares and distribution of profits,\n8\nand is therefore liable to tax as per the provisions of the said section 115QA of the\nAct?\"\n2. \"Whether ... that the substance of a transaction must he considered over its form, and\nthereby overlooking that the capital reduction was, in effect, a buyback of shares?\"\n4.\n\"Whether on the facts and in the circumstances of the case and in law, the\nLd. CIT(A) erred in disregarding

NIELSEN (INDIA) P.LTD,MUMBAI vs. DCIT RG 6(1), MUMBAI

The appeal is dismissed as withdrawn

ITA 3581/MUM/2015[2009-10]Status: DisposedITAT Mumbai31 Jul 2025AY 2009-10

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhriआयकर अपील सुं./Ita No. 3581/Mum/2015 (नििाारण वर्ा / Assessment Year: 2009-10) M/S. Nielsen (India) V/S. Deputy Private Limited बिाम Commissioner Of (Formerly Known As Income Tax Range– Acnielsen Org-Marg 6(1), Mumbai Private Limited) Aaykar Bhavan, Mumbai 6Th Floor, Block C, Godrej It 400020 Park, 02, Godrej Business District, Lbs Marg, Phirojshanagar, Vikhroli (W), Mumbai 400079 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaacm9279L Appellant/अपीलार्थी .. Respondent/प्रनिवादी निर्ााररती की ओर से /Assessee By: Shri Paras S. Savla राजस्व की ओर से /Revenue By: Ms. Neena Jeph, Cit Dr

For Appellant: Shri Paras S. SavlaFor Respondent: Ms. Neena Jeph, CIT DR
Section 250Section 43B

learned CIT(A) erred in confirming learned AO's action of holding that the payment towards buyback of shares of Rs. 154,386,000 same ought to be treated as dividend under section 115-0 of the Act. He erred in confirming the observation of the learned AO that ... buyback of shares was a colourable device. 3. General 3.1. Each one of the above grounds of appeal is without prejudice to one another. 3.2. The appellant craves leave to add, alter or amend the grounds of appeal.” P a g e | 4 ITA NO. 3581/Mum/2015

ACIT, CIRCLE-46(1), NEW DELHI vs. DABUR INVEST CORP., DELHI

In the result, appeals of the Revenue are dismissed and appeal

ITA 2454/DEL/2022[2018-19]Status: DisposedITAT Delhi04 Jun 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraिनधा"रणवष"/Assessment Year: 2017-18 बनाम Acit, Dabur Invest Corp., 4Th Floor, Punjab Bhawan, Circle-46(1), Room No.106, Vs. Drum Shape Building, I.P. Estate, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent िनधा"रणवष"/Assessment Year: 2018-19 बनाम Acit, Dabur Invest Corp., 4Th Floor, Punjab Bhawan, Circle-46(1), Room No.106, Vs. Drum Shape Building, I.P. Estate, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent िनधा"रणवष"/Assessment Year: 2017-18 बनाम Dabur Invest Corp., Jcit, 4Th Floor, Punjab Bhawan, Vs. Range-46, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent िनधा"रणवष"/Assessment Year: 2018-19 बनाम Dabur Invest Corp., Jcit, 4Th Floor, Punjab Bhawan, Vs. Range-46, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent

presented to the shareholders by the board. Further as per clause number 9 of agreement before the coordinate bench, with respect to the buyback of shares, the buyback of Mahindra shares shall be equal to the option price. That means whatever is the option price already received by the assessee

ACIT, CIRCLE-46(1), NEW DELHI vs. DABUR INVEST CORP , DELHI

In the result, appeals of the Revenue are dismissed and appeal\nof the assessee for the AY 2017-18 is partly allowed as indicated\nabove and appeal of the assessee for the AY 2018-19 is dismissed

ITA 2453/DEL/2022[2017-18]Status: DisposedITAT Delhi04 Jun 2025AY 2017-18

presented to the shareholders by the board.\nFurther as per clause number 9 of agreement before the\ncoordinate bench, with respect to the buyback of shares,\nthe buyback of Mahindra shares shall be equal to the option\nprice. That means whatever is the option price already\nreceived by the assessee

DABUR INVEST CORP,NEW DELHI vs. JCIT, RANGE-46, NEW DELHI

In the result, appeals of the Revenue are dismissed and appeal\nof the assessee for the AY 2017-18 is partly allowed as indicated\nabove and appeal of the assessee for the AY 2018-19 is dismissed

ITA 2448/DEL/2022[2018-19]Status: DisposedITAT Delhi04 Jun 2025AY 2018-19

presented to the shareholders by the board.\nFurther as per clause number 9 of agreement before the\ncoordinate bench, with respect to the buyback of shares,\nthe buyback of Mahindra shares shall be equal to the option\nprice. That means whatever is the option price already\nreceived by the assessee

DABUR INVEST CORP,NEW DELHI vs. JCIT, RANGE-46, NEW DELHI

In the result, appeals of the Revenue are dismissed and appeal

ITA 2447/DEL/2022[2017-18]Status: DisposedITAT Delhi04 Jun 2025AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraिनधा"रणवष"/Assessment Year: 2017-18 बनाम Acit, Dabur Invest Corp., 4Th Floor, Punjab Bhawan, Circle-46(1), Room No.106, Vs. Drum Shape Building, I.P. Estate, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent िनधा"रणवष"/Assessment Year: 2018-19 बनाम Acit, Dabur Invest Corp., 4Th Floor, Punjab Bhawan, Circle-46(1), Room No.106, Vs. Drum Shape Building, I.P. Estate, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent िनधा"रणवष"/Assessment Year: 2017-18 बनाम Dabur Invest Corp., Jcit, 4Th Floor, Punjab Bhawan, Vs. Range-46, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent िनधा"रणवष"/Assessment Year: 2018-19 बनाम Dabur Invest Corp., Jcit, 4Th Floor, Punjab Bhawan, Vs. Range-46, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent

presented to the shareholders by the board. Further as per clause number 9 of agreement before the coordinate bench, with respect to the buyback of shares, the buyback of Mahindra shares shall be equal to the option price. That means whatever is the option price already received by the assessee

EATON TECHNOLOGIES PRIVATE LIMITED,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PUNE

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

ITA 1160/PUN/2024[2017-18]Status: HeardITAT Pune03 Mar 2025AY 2017-18

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

For Appellant: Smt. Vishal KalraFor Respondent: Shri Amol Khairnar
Section 10ASection 143(2)Section 143(3)Section 14ASection 263Section 40

routed back to the parent AE. Although the FAO as well as the assessee has not brought on record any details of buyback of shares during the year and that it is not possible to verify the same since the assessee has not furnished the relevant notes to the audited ... still remain the same i.e. the agreement between the assessee and the AE dated 19/04/2007 and as noted by the CIT(A), the buyback of shares was involved in earlier years as well. The FAO has not verified this aspect of the case and allowed the deduction under section 10AA

ACIT CIRCLE-58(1), DELHI vs. MAGICAL ENTERPRISES L.L.P , DELHI

In the result, the appeal of the Revenue is dismissed

ITA 1059/DEL/2022[2016-17]Status: DisposedITAT Delhi20 Dec 2024AY 2016-17

Bench: Shri Pradip Kumar Kedia & Shri Vimal Kumar[Assessment Year : 2016-17] Acit Vs Magical Enterprises L.L.P Circle-58(1) 80, Kiran Vihar Delhi. New Delhi-110092. Pan-Abafm4809Q Appellant Respondent

Section 10Section 112Section 115QSection 143(3)

contended that there was no violation of any provisions of the Companies Act or the Income-tax Act in the process of buyback of shares by the related parties as per 115QA and claim of exemption u/s. 10(34A) by the appellant. The appellant has also referred to several other

BHAVANA LALIT JAIN,NAVI MUMBAI vs. INCOME TAX OFFICER, WD-15(1)(1), MUMBAI

The appeals are allowed

ITA 1016/MUM/2024[2014-15]Status: DisposedITAT Mumbai15 Oct 2024AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shriraj Kumar Chauhan, Jm

Section 10Section 143Section 147Section 148Section 68

statements, rate publication of Bombay stock exchange and advertisement issued by the seller in the newspaper. He further referred that open offer for buyback of shares and other documents are also submitted before the learned assessing officer. 16. He further submitted that the contention of the learned departmental representative that

ITO-28.3.1, NAVI MUMBAI vs. SEEMA NARENDRA BAPNA, NERUL

In the result both the grounds of appeal are dismissed

ITA 1120/MUM/2024[2014-15]Status: DisposedITAT Mumbai10 Oct 2024AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Raj Kumar Chauhan, Jm A.Y.2014-15 Ito,28.3.1, Seema Narendra Bapna, Mumbai Flat No.A 2701, Plot No. R3 B Emerald Bay, Sector Vs. 14 Nerul, Navi Mumbai, Thane 400706

Section 143Section 147Section 148

statements, rate publication of Bombay stock exchange and advertisement issued by the seller in the newspaper. He further referred that open offer for buyback of shares and other documents are also submitted before the learned assessing officer. 16. He further submitted that the contention of the learned departmental representative that

DEPUTY COMMISSIONER OF INCOME TAX, MUMBAI vs. TECK CONSULTANCY AND SERVICES PRIVATE LIMITED, KOLKATA

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

ITA 675/MUM/2024[2012-13]Status: DisposedITAT Mumbai26 Aug 2024AY 2012-13

Bench: Shri Amarjit Singh & Shri Anikesh Banerjee

For Appellant: Shri Vijay MehtaFor Respondent: Shri Solgy Jose T Kottaram, CIT, DR
Section 132(4)Section 139(1)Section 143(3)Section 153ASection 153DSection 250Section 68Section 69C

seized material Annexure-A4 (from FY 2010-11 TO On perusal of the said sized pages, the issue of buyback of shares by the assessee from the shell entities was found. M/s BSR Finance and Construction Ltd was found one of the above said shell entities. On perusal

DEPUTY COMMISSIONER OF INCOME TAX, AURANGABAD vs. SANDEEP BIPINCHANDRA JHAVERI, MUMBAI

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

ITA 1185/PUN/2023[2013-14]Status: DisposedITAT Pune14 Aug 2024AY 2013-14

Bench: Shri R. K. Panda & Shri Vinay Bhamoresl.

For Appellant: Shri Deepak ShahFor Respondent: Shri Sourabh Nayak
Section 132Section 143(3)Section 153ASection 153C

erred in deleting the addition of Rs.2,35,00,000/- (50% of Rs.4.7 crores) on account of cash paid on buyback of shares which was made by the A.O. on the basis of facts and based on certain loose papers and documents found and seized as per bundle No.2, page ... Jhaveri, wherein as per certain noting it was inferred that an amount of Rs.4,70,00,000/- was paid to investors during buyback of shares of Jhaveri Flexo India Ltd. During the course of search action statement of Abhishek Jhaveri was also recorded under oath, wherein he admitted that

KEEP LEARNING RESOURCES PRIVATE LIMITED,MUMBAI vs. INCOME TAX OFFICER WARD-12(1)(4), MUMBAI

In the result, the appeal is allowed for statistical purpose

ITA 1692/MUM/2023[2014-2015]Status: DisposedITAT Mumbai25 Jun 2024AY 2014-2015

Bench: Shri Pavan Kumar Gadale & Shri Ratnesh Nandan Sahayassessment Year: 2014-15 M/S. Keep Learning Income Tax Officer, Resources Private Ward 12(1)(4) Limited Aayakar Bhawan, D –Wing, Maharishi Karve Road, Chanakya Chs, Vs. Mumbai- 400020. Link Road, Mahavir Nagar, Kandivali (West), Mumbai- 400067. Pan: Aadcc6594R (Appellant) (Respondent) Present For: Assessee By : Shri Kapil Sanghvi, C.A. Revenue By : Shri P. D. Chougule (Addl. Cit), S.R. D.R. Date Of Hearing : 05 . 06 . 2024 Date Of Pronouncement : 25 . 06 . 2024 O R D E R Per : Ratnesh Nandan Sahay: 1. This Appeal Has Been Filed Against The Order Of The Ld. Cit Appeal Passed U/S 250 Of The Income Tax Act [The ‘Act’ In Short] Vide Din & Order No.Itba/Nfac/S/250/2022-23/1050750385(1) Dated 14/03/2023 For The Assessment Year 2014-15. 2. The Following Grounds Of Appeal Have Been Raised:

For Appellant: Shri Kapil Sanghvi, C.AFor Respondent: Shri P. D. Chougule (Addl. CIT), S.R. D.R
Section 250Section 56Section 56(2)(viib)

course of assessment proceedings. a. Copy of Addendum to Valuation Report b. Copy of offer letter of the promoters has first offered for buyback of shares. 4. It is found that the Hon'ble Coordinate Bench of Hon'ble ITAT, Mumbai”H” Bench, Mumbai in the case of assessee itself

ACIT CIRCLE-1(3)(1) INT. TAXATION, NEW DELHI vs. ANAND SWARUP GUPTA, NEW DELHI

ITA 2371/DEL/2022[2018-19]Status: DisposedITAT Delhi14 Mar 2024AY 2018-19

Bench: Dr. Brr Kumar & Ms. Astha Chandraasstt. Year: 2018-19 Acit Circle-1(3)(1), Vs. Sh. Anand Swarup Gupta, (Intl. Tax), Ibc M-38/1 Middle Circle, Room No. 501, Connaught Place, D-Block,Civic Centre, New Delhi – 110 001 New Delhi 110 002 Pan Aappg3467Q (Appellant) (Respondent)

For Appellant: NoneFor Respondent: Shri Sanjay Kumar, Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 144C(3)Section 68

doubted the creditworthiness of the company. Page 4 of 8 ITA no.-2371/Del/2022 ACIT vs. Anand Swarup Gupta 9.4 For effecting the buyback of shares, it has been shown that UMS duly complied with the provisions of the Companies Act for buy back of shares. Accordingly, the company

THE ACIT, (CENTRAL)-1, INDORE vs. M/S. PRAKASH ASHPHLTING & TOLL HIGHWAY LTD., INDORE

Appeals are dismissed

ITA 805/IND/2019[2014-15]Status: DisposedITAT Indore31 Jan 2024AY 2014-15

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 269SSection 271DSection 271E

from M/s Agroh Infrastructure Developers Pvt. Ltd (In short AIDPL) and on other hand accepts the same to be cash- buyback of shares. The AO has also held that interest amounting to Rs. 14,83,394/- was charged by AIDPL. Whereas the said document only records some purported cash received ... appellant and the impugned loose papers were not found from premises of the appellant. Therefore, the AO is not justified in presuming buyback of shares as cash loan and interest on a loan was equally hypothetical. The statement given which has to be used against the assesse

THE ACIT, (CENTRAL)-1, INDORE vs. M/S. PRAKASH ASHPHLTING & TOLL HIGHWAY LTD., INDORE

Appeals are dismissed

ITA 804/IND/2019[2013-14]Status: DisposedITAT Indore31 Jan 2024AY 2013-14

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 269SSection 271DSection 271E

from M/s Agroh Infrastructure Developers Pvt. Ltd (In short AIDPL) and on other hand accepts the same to be cash- buyback of shares. The AO has also held that interest amounting to Rs. 14,83,394/- was charged by AIDPL. Whereas the said document only records some purported cash received ... appellant and the impugned loose papers were not found from premises of the appellant. Therefore, the AO is not justified in presuming buyback of shares as cash loan and interest on a loan was equally hypothetical. The statement given which has to be used against the assesse

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