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“round trip financing”

GAARSection 97(2)Section 97(2)3 judgments

M/S. DIACH CHEMICALS & PIGMENTS PVT. LTD.,HOWRAH vs. D.C.I.T., CENTRAL CIRCLE - 4(2), KOLKATA, KOLKATA

In the result, both the appeals of the assessee are allowed

ITA 1643/KOL/2024[2021-2022]Status: DisposedITAT Kolkata20 Dec 2024AY 2021-2022

Bench: Shri Sanjay Garg, Jm & Shri Rajesh Kumar, Am

For Appellant: Shri S.M. Surana &For Respondent: Shri Prakash Nath Barnwal, DR
Section 132Section 142(1)Section 143(3)Section 147Section 148Section 148A

amalgamation is done with a sole intention of avoiding tax liability and that the transactions were independently verified to be nothing but ‘round trip financing lacking commercial substance and not for bonafide purposes’. This finding is clearly well beyond what is contained in the notice issued under Section 148A

M/S. DIACH CHEMICALS & PIGMENTS PVT. LTD.,HOWRAH vs. D.C.I.T., CENTRAL CIRCLE - 4(2), KOLKATA, KOLKATA

In the result, both the appeals of the assessee are allowed

ITA 1642/KOL/2024[2018-2019]Status: DisposedITAT Kolkata20 Dec 2024AY 2018-2019

Bench: Shri Sanjay Garg, Jm & Shri Rajesh Kumar, Am

For Appellant: Shri S.M. Surana &For Respondent: Shri Prakash Nath Barnwal, DR
Section 132Section 142(1)Section 143(3)Section 147Section 148Section 148A

amalgamation is done with a sole intention of avoiding tax liability and that the transactions were independently verified to be nothing but ‘round trip financing lacking commercial substance and not for bonafide purposes’. This finding is clearly well beyond what is contained in the notice issued under Section 148A

WATCHOOD PROPERTIES PVT LTD,NEW DELHI vs. ITO WARD - 27(2), NEW DELHI

In the result, appeal of the assessee is dismissed

ITA 8394/DEL/2019[2015-16]Status: DisposedITAT Delhi27 Jun 2023AY 2015-16

Bench: Shri Kul Bharat & Shri M. Balaganesh

For Appellant: NoneFor Respondent: Shri Gurpreet Shah Singh, Sr. DR
Section 143(3)Section 14ASection 69C

transactions other than benefit and funds are merely transferred amongst parties to the arrangement & the transaction having the above characteristics have Round trip financing. The AO has further noted that M/s BRR Securities Pvt Ltd is a dummy company has not undertaken any genuine business activity and is merely involved