“share capital and share premium”

Cash Credits & Unexplained ItemsSection 68Section 68694 judgments

The decision most relied on for share capital and share premium is CIT v. Divine Leasing & Finance Ltd. (299 ITR 268), cited in 426 judgments on BharatTax.

Leading authorities on share capital and share premium

CIT v. Divine Leasing & Finance Ltd.

299 ITR 268 · 2008 · High Court

426

citing judgments

The Assessing Officer cannot add share capital or share premium amounts if the assessee provides the identity and creditworthiness of the subscriber and establishes the genuineness of the transaction. The court may admit additional evidence under Rule 46A, such as the PAN identity of the creditor.

CIT v. Gagandeep Infrastructure (P.) Ltd.

394 ITR 680 · 2017 · High Court

303

citing judgments

Under Section 68, an assessee is only required to prove the identity and creditworthiness of the immediate creditor or share subscriber and the genuineness of the transaction. The assessee is not obligated to establish the 'source of the source' of funds or the creditworthiness of sub-lenders, as this information may not be within the assessee's special knowledge.

Vodafone India Services (P.) Ltd. v. Union of India

368 ITR 1 · 2014 · High Court

172

citing judgments

The issue of shares and share premium is a capital account transaction, not an income-generating event, therefore Chapter X (Transfer Pricing) provisions are not attracted to deem notional or hypothetical income from such transactions.

MOD Creation Pvt Ltd. v. Case

354 ITR 282 · 2013 · High Court

154

citing judgments

Under Section 68 of the Income-tax Act, the initial burden is on the assessee to establish the authenticity of transactions for unexplained credits. Once authenticity is proven, this burden shifts, and the assessee is not required to prove the genuineness or source of funds of the creditor beyond this.

CIT v. Ultra Modern Exports (P.) Ltd.

40 Taxmann.com 458 · 2013 · High Court

135

citing judgments

An addition under Section 68 for cash credits like share capital or premium cannot be sustained if the assessee provides the identity, creditworthiness, and genuineness of the transaction, and the Assessing Officer fails to conduct further enquiries into the 'source of source' or the ultimate source of funds of the investor/creditor.

CIT v. Empire Builtech (P.) Ltd.

366 ITR 110 · 2014 · High Court

110

citing judgments

For additions under Section 68 related to share capital and premium, the assessee must prove the genuineness of the transaction and the creditworthiness of the investors, beyond merely disclosing their identities. Additions are permissible for amounts attributable to investors whose particulars remain unverified or who fail to respond to inquiries.

PCIT v. Paradise Inland Shipping Pvt. Ltd.

84 Taxmann.com 58 · 2017 · High Court

citing judgments

In reassessment proceedings initiated on the ground that companies providing share capital were non-existent, if the assessee provides documentary evidence of their existence, the burden shifts to the revenue to establish reasons for reassessment.

Jatia Investment Co. v. CIT

206 ITR 718 · 1994 · High Court

citing judgments

An addition under Section 68 for unexplained cash credits cannot be made when there is no actual cash credit or flow of funds, such as in cases of share swaps or notional credits.

Judgments citing share capital and share premium

Suryavanshi Finlease Private Limited, Delhi vs. ACIT, Central Circle, Karnal

The appeal is allowed

ITA 2900/DEL/2024[2009-10]Status: DisposedITAT Delhi29 Oct 2025AY 2009-10

Bench: Shri Anubhav Sharma & Shri Krinwant Sahayassessment Year : 2009-10 Suryavanshi Finlease Private Ltd., Vs. Acit, C-5/2A, Rana Pratap Bagh, Central Circle, Opp. Cc Colony, Karnal. New Delhi – 110 085. Pan: Aabcs1933N Assessee By : Shri Ved Jain, Advocate; Shri Pawan Garg, Ca & Shri Ishika Dua, Ca Revenue By : Shri Mahesh Kumar, Cit-Dr Date Of Hearing : 25.09.2025 Date Of Pronouncement : 29.10.2025

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Shri Mahesh Kumar, CIT-DR

Section 153Section 153A

appeal filed by assessee against the Ld. CIT(A) Order dated 27.05.2024, whereby CIT(A) has confirmed the addition of share capital and share premium received by assessee of Rs. 78,00,000/- made by AO via order dated 31.12.2019 passed u/s 153A of the Income ... assessment, same should be reflected in reopening reasons. 3 6. In the present case, the addition were made on account of share capital and share premium received by the assessee which is in the nature of ‘liability’ and would fall beyond the scope of phrase ‘undisclosed asset’ valued

M/S. Emerald Properties Pvt. Ltd. (Successor to Fast Mercantiles Pvt. Ltd.), Kolkata vs. I.T.O., Ward - 5(4), Kolkata

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

ITA 1260/KOL/2024[2012-2013]Status: DisposedITAT Kolkata28 Oct 2025AY 2012-2013

Bench: This Tribunal. The Assessee Has Filed A Petition Along With An Affidavit Explaining The Reasons For The Delay. After Considering The Petition & The Submissions Made, We Are Satisfied That There Was Sufficient Cause For The Delay. Accordingly, The Delay Is Condoned & The Appeal Is Admitted For Adjudication.

Section 131Section 250Section 68

share premium of ₹5,10,13,900 during the financial year 2011–12.In order to verify the genuineness of the share capital and share premium, summons under section 131 of the Income-tax Act, 1961, were issued to the directors and share applicants requiring them ... parties complied with the said notices. The Assessing Officer, therefore, required the assessee to explain the nature and source of the share capital and share premium received. Since the assessee failed to offer any satisfactory explanation or supporting documents, the Assessing Officer treated

Agrawala Finserve Pvt Ltd, Delhi vs. ITO Ward-1(4), Delhi

In the result, appeal of the assessee is allowed

ITA 3503/DEL/2025[2012-13]Status: DisposedITAT Delhi24 Oct 2025AY 2012-13

Bench: SHRI VIKAS AWASTHY (Judicial Member)

For Appellant: S/Shri Mukesh Kumar Jain & Atul DhamaFor Respondent: Ms. Sudha Gupta, Sr.DR

Section 133(6)Section 143(3)Section 147Section 148

hereinafter referred to as ‘the Act’). In 2 original assessment proceedings, the Assessing Officer (AO) examined the issue of share capital and share premium. Notice u/s. 133(6) of the Act was issued to the share applicants. After considering the replies of the investor, the AO completed

Samrat Finvestors Private Limited, Kolkata vs. DCIT, Cent. Cir. 4(2), Kolkata

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

ITA 1038/KOL/2025[2016-2017]Status: DisposedITAT Kolkata16 Oct 2025AY 2016-2017

Bench: Shri Rajesh Kumar, Am & Shrigeorge Mathan, Jm

For Appellant: Shri Soumitra Choudhury, ARFor Respondent: Shri Sanat Kumar Raha, DR

Section 131Section 143(3)Section 263Section 68

genuineness of the transactions by various details/ evidences. The A.O. also issued notices u/s 133(6) to share applicants contributing share capital including share premium of Rs.77,96,70,000/- . All the shareholders subscriptions had submitted their replies along with evidences. Copies of the same are available ... that the ld. AO issued notice u/s 133(6) of the Act, to the share applicants, who subscribed to the share capital including share premium of ₹77,96,70,000/- and all the share subscribers have responded to the said notices by filing the reply along

Samrat Finvestors Private Limited, Kolkata vs. DCIT, Cent. Cir. 4(2), Kolkata

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

ITA 1037/KOL/2025[2015-2016]Status: DisposedITAT Kolkata16 Oct 2025AY 2015-2016

Bench: Shri Rajesh Kumar, Am & Shrigeorge Mathan, Jm

For Appellant: Shri Soumitra Choudhury, ARFor Respondent: Shri Sanat Kumar Raha, DR

Section 131Section 143(3)Section 263Section 68

Samrat Finvestors Private Limited, Kolkata vs. DCIT, Cent. Cir. 4(2), Kolkata

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

ITA 1036/KOL/2025[2014-2015]Status: DisposedITAT Kolkata16 Oct 2025AY 2014-2015

Bench: Shri Rajesh Kumar, Am & Shrigeorge Mathan, Jm

For Appellant: Shri Soumitra Choudhury, ARFor Respondent: Shri Sanat Kumar Raha, DR

Section 131Section 143(3)Section 263Section 68

Samrat Finvestors Private Limited, Kolkata vs. ITO, Ward 5(2) (Now DCIT, Cent.Cir. 4(2)), Kolkata

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

ITA 1035/KOL/2025[2012-2013]Status: DisposedITAT Kolkata16 Oct 2025AY 2012-2013

Bench: Shri Rajesh Kumar, Am & Shrigeorge Mathan, Jm

For Appellant: Shri Soumitra Choudhury, ARFor Respondent: Shri Sanat Kumar Raha, DR

Section 131Section 143(3)Section 263Section 68

DCIT(Central Circle)-3(3), Mumbai vs. Juicy International Pvt. Ltd. (Now Known As Avaada Ventures Pvt. Ltd.), Mumbai

ITA 4388/MUM/2024[2013-14]Status: DisposedITAT Mumbai16 Oct 2025AY 2013-14

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

Section 131Section 250

explain the nature of the credit in its books claims that the credit entry is share application mоnеу, share capital and share premium, then the additional requirement of law as per the proviso to section 68 of the Act kicks in and share subscriber should ... explain the nature of the credit in its books claims that the credit entry is share application mоnеу, share capital and share premium, then the additional requirement of law as per the proviso to section 68 of the Act kicks in and share subscriber should

Adhunik Akshat Udyog Pvt. Ltd., Dumka vs. ACIT, Circle-3(1), Deoghar

In the result, the appeal of the assessee is allowed

ITA 163/RAN/2025[12-13]Status: DisposedITAT Ranchi10 Oct 2025

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.163/Ran/2025 Assessment Year: 2012-13 Adhunik Akshat Udyog Pvt. Ltd……………............................……….……Appellant Industrial Area, Babupur, Muffasil Thana Dumka, Jharkhand – 814101. [Pan: Aabca4896Q] Vs. Acit, Circle-3(1), Deoghar…...…..….…..….........……........……...…..…..Respondent Appearances By: Shri Sushil Pransukha, Ar, Appeared On Behalf Of The Appellant. Shri Khubchand T. Pandya, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 28, 2025 Date Of Pronouncing The Order : October 10, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Nfac, Delhi [“Cit(A)”] Dated 11.03.2025 Under Section 250 Of The Income-Tax Act, 1961 (The “Act”) For The Assessment Year 2012–13. 2. Facts Of The Case Are That The Assessee Company Filed Its Return Of Income For Ay 2012–13 Declaring Total Income Of ₹2,57,551. The Case Was Reopened Under Section 147 On The Ground That The Assessee Had Raised Share Capital & Share Premium From Certain Entities, Whose Financial Capacity & Genuineness Of Investment Remained Unexplained. During Assessment, The Ao Noted That The Assessee Had Introduced Share Capital Of ₹37,50,000 From The Following Four Private Limited Companies:

Section 131Section 147Section 250Section 68

total income of ₹2,57,551. The case was reopened under section 147 on the ground that the assessee had raised share capital and share premium from certain entities, whose financial capacity and genuineness of investment remained unexplained. During assessment, the AO noted that the assessee had introduced

Golden Goenka Commerce Pvt. Ltd., Kolkata vs. ACIT Circle-2(1), Jamshedpur

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

ITA 11/RAN/2024[2011-12]Status: DisposedITAT Ranchi10 Oct 2025AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.11/Ran/2024 Assessment Year: 2011-12 Golden Goenka Commerce Pvt. Ltd. (Earlier Known As Rajgaj Traders Pvt. Ltd.)............................……….……Appellant 25A, S.P Mukherjee Road, 4Th Floor, Bhawanipore, Kol-25, [Pan: Aabcr7503F] Vs. Acit, Circle-2(1), Jamshedpur..…..….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Ar, Appeared On Behalf Of The Appellant. Shri Kumar Pranab, Cit- Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 4, 2025 Date Of Pronouncing The Order : October 10, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Learned Commissioner Of Income Tax (Appeals) [“Cit(A)”], Dated 21.12.2018, Arising Out Of Assessment Framed Under Section 147 Read With Section 143(3) Of The Income-Tax Act, 1961 (The “Act”) For The Assessment Year 2011–12. 2. The Assessee Has Raised Multiple Grounds, The Sum & Substance Of Which Is That The Learned Cit(A) Erred In Upholding The Addition Of ₹4,73,00,000 Made By The Assessing Officer (“Ao”) Under Section 68 Of The Act Towards Share Capital & Share Premium, Ignoring The Documentary Evidences Placed On Record & Without Conducting Any Independent Enquiry. 3. Brief Facts Of The Case Are That The Assessee Company Filed Its Return Of Income For The Assessment Year 2011–12 Declaring Total Income Of ₹16,67,088. Subsequently, The Case Of The Assessee Was Reopened

Section 131Section 143(3)Section 147Section 148Section 68

upholding the addition of ₹4,73,00,000 made by the Assessing Officer (“AO”) under section 68 of the Act towards share capital and share premium, ignoring the documentary evidences placed on record, and without conducting any independent enquiry. 3. Brief Facts of the case are that

ITO Ward - 1(2)(4), Meerut vs. Livros Publishing Pvt Ltd, Meerut

In the result, the appeal of the Revenue is dismissed

ITA 1971/DEL/2020[2012-13]Status: DisposedITAT Delhi08 Oct 2025AY 2012-13

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2012-13 Income Tax Officer, Vs. M/S. Livros Publishing Pvt. Ward-1(2)(4). Ltd., 37, Chippi Tank, Meerut (U.P) Meerut Pan: Aabcl7313B (Appellant) (Respondent)

For Appellant: Shri Lalit Mohan, Adv. & Shri AnkitFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR

Section 142(1)Section 143(1)Section 143(2)Section 250Section 68

Rs.4,00,00,000/- was invested by M/s. Apoorva Leasing Finance and Investment Company Ltd. in the appellant company, as the share capital and share premium. The invested was credited in the books of account of the appellant. The appellant was legally required to prove the same ... required the appellant to explain the credit of share capital and share premium and after considering the evidences filed before him, reached a conclusion that the appellant could not prove the identity and creditworthiness of the share investor and genuineness of the transaction with

Kataria Snack Pellets Private Limited, Rajkot vs. Assistant Commissioner of Income Tax, Circle-1(1), Rajkot

In the result, appeal of the assessee is dismissed

ITA 468/RJT/2024[2015-16]Status: DisposedITAT Rajkot07 Oct 2025AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.468/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2015-16 Kataria Snack Pellets Pvt. Ltd. The Acit, Circle-1(1) बनाम 510, Gidc, Metoda Kalawad Road Rajkot Rajkot-360021, Gujarat Vs. Pan : Aafck2028L (अपीलाथ"/Appellant) (""यथ"/Respondent) :

For Appellant: Shri Nishit B. Jesur, ld.ARFor Respondent: Shri Sanjay Punglia, CIT-DR

Section 143(2)Section 143(3)Section 147Section 148Section 250Section 56(2)(vii)

premium of Rs. 4990 per share. The details of share allotment were furnished. The entire amount of share capital and share premium of Rs. 4,00,00,000/-, was received during the relevant previous year. As regards valuation of shares, it was submitted that assessee

Evolution Golf Pvt Ltd, Mumbai vs. Deputy Commissioner of Income Tax -6(3)(2), Mumbai

In the result the appeal filed by the assessee stands partly allowed for statistical purposes

ITA 754/MUM/2025[2010-12]Status: DisposedITAT Mumbai30 Sept 2025AY 2010-12

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

application and share premium even though providing all documentary evidences as given questionnaire. The Assessing Officer did not understand the share capital and share premium amount. As per audited balance sheet and details provide d during the time of assessment, share capital a mount received during

Brand India Real Estate Private Limited, Jaipur vs. Income Tax Officer Ward 6(1), Jaipur

In the result, appeal of the assessee is allowed

ITA 514/JPR/2025[2012-2013]Status: DisposedITAT Jaipur29 Sept 2025AY 2012-2013

For Appellant: Shri Siddharth Ranka, Adv. &For Respondent: Shri Dharam Singh Meena, JCIT

Section 132Section 139(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 250

efforts to prove the financial transaction, the nature of work done by the companies and the creditworthiness of the companies giving share capital and share premium, but it has not been done in the submission of the appellant. Hon. Delhi High Court in famous decision of PCIT ... decision of PCIT vs. NRA Iron & Steel has confirmed the addition made by the Revenue in the cases of bogus share capital and share premium from the Shell Companies. Hence, relying upon two decisions as mentioned above, the addition of the AO is confirmed and appeal

Nks Holdings P.Ltd, New Delhi vs. ACIT, Central Circle-32, New Delhi

ITA 6690/DEL/2018[2011-12]Status: DisposedITAT Delhi24 Sept 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Amitabh Shuklaassessment Year: 2011-12 Nks Holdings Pvt. Ltd., Vs Acit, 3198/15, 4Th Floor, Gali No.1, Central Circle-32, Sangatrashan, New Delhi. Paharganj, New Delhi – 110 055. Pan: Aakcs7827C (Appellant) (Respondent) Assessee By : Shri Amol Sinha, Advocate & Shri Ankit Kumar, Advocate Revenue By : Ms Rajinder Kaur, Cit-Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 24.09.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Order Dated 10.08.2018 Of The Commissioner Of Income-Tax (Appeals)-30, New Delhi (Hereinafter Referred To As The Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeal No.317/17-18/2980 Arising Out Of The Appeal Before It Against The Order Dated 28.12.2017 Passed U/S 144/147 Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) By The Acit, Central Circle-32, New Delhi (Hereinafter Referred To As The Ld. Ao).

For Appellant: Shri Amol Sinha, Advocate &For Respondent: Ms Rajinder Kaur, CIT-DR

Section 143(1)Section 143(2)Section 144Section 147Section 148Section 68

assessment order merely based on investigation reports with no independent evidences, we find that the impugned addition arise out of share capital and share premium received by assesse from three companies namely Avail Financial Services [Rs. 300 Cr.], Carewell Exim Pvt. Ltd. [Rs. 350 Cr.] and Solomon Holdings ... assessee company and the other eight companies. In one company i.e. Carewell Exim Pvt. Ltd. From whom the assessee had received share capital and share premium no reassessment proceedings have been initiated. In the other two of the remaining seven companies i.e. KDG Properties & Construction

Avon Containners Pvt. Ltd., Faridabad vs. ACIT, Circle-1, Faridabad

In the result, the appeal of the assessee is allowed as above

ITA 5161/DEL/2024[2012-13]Status: DisposedITAT Delhi23 Sept 2025AY 2012-13

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 143(3)Section 147Section 148Section 151

copies of entire material used by him before drawing the inferences have been given to the assessee. Assessee have received bogus share capital and share premium of Rs.30,00,000 from M/s. Rising Portfolio India P. ltd. controlled and managed by Sh. Himanshu Verma and Rs.25

M/S. Hhp Hospital Pvt. Ltd., Kolkata vs. DCIT, Circle 11(1), Kolkata

In the result, appeal of the assessee is allowed

ITA 280/KOL/2025[2012-13]Status: DisposedITAT Kolkata19 Sept 2025AY 2012-13

Bench: Shri Manjunatha G & Shri Sonjoy Sarmam/S Hhp Hospital Private Ltd, Vs Dcit, Circle-11(1), Kolkata 2406, Garia Main Road, Kolkata-700084 Pan No. Aabch 2642 B (अपीलधर्थी /Appellant) (प्रत्यर्थी / Respondent) .. निर्धाररती की ओर से /Assessee By : Shri Sunil Surana, Ar रधजस्व की ओर से /Revenue By : Shri Kapil Mandal, Addl.Cit-Sr. Dr सुनवाई की तारीख / Date Of Hearing : 18/09/2025 घोषणा की तारीख/Date Of Pronouncement : 19/09/2025 आदेश / O R D E R Per Manjunatha G, Am: This Appeal Filed By The Assessee Is Directed Against The Order Passed By The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Dated 04.01.2024 Pertaining To Assessment Year 2012-2013. 2. At The Outset, We Note That The Appeal Of The Assessee Is Barred By Limitation By 313 Days, For Which Condonation Petition Is Filed. At The Time Of Hearing The Counsel Of The Assessee Explained The Reason For Delay In Filing The Appeal. The Ld. A.R Did Not Raise Any Objection In Condoning The Delay.

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Kapil Mandal, Addl.CIT-Sr. DR

Section 131Section 68

selected for scrutiny and during 2 ITANo.280/Kol/2025 the course of assessment proceedings, the Assessing Officer noticed that the assessee has received share capital including share premium from Bircot Tracom Pvt. Ltd., Omnitech Industries Ltd. and Utpal Trading Pvt. Ltd. to the tune of Rs.1 ... submissions of the assessee and made additions of Rs.1,92,00,000/- u/s.68 of the Act as unexplained cash credit towards share capital and share premium received from the above three companies. 5. Aggrieved by the assessment order, the assessee preferred an appeal before the ld.CIT(A). Before

Deputy Commissioner of Income Tax, Circle 2(1)(1), Vadodara vs. Truform Techno Products Private Limited, Nagpur

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

ITA 1776/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad18 Sept 2025AY 2012-13

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2009-10

Section 143(2)Section 143(3)Section 147Section 148Section 151Section 68Section 78(2)

face value of Rs.10/- at a premium of Rs.40/- per share, thereby bringing in Rs.2,99,50,000/- as share capital and share premium during the year. In the course of assessment, the Assessing Officer had made enquiry about the share capital received during the year ... Assessment Years: 2009-10 & 2012-13) DCIT vs. Truform Techno Products Pvt. Ltd. Page 5 of 22 transactions. Therefore, the entire share capital and share premium of Rs.2,99,50,000/- was considered as unexplained and added under Section 68 of the Income Tax Act, 1961 (hereinafter referred

Deputy Commissioner of Income Tax, Circle 2(1)(1), Vadodara vs. Truform Techno Products Private Limited, Nagpur

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

ITA 1775/AHD/2024[2009-10]Status: DisposedITAT Ahmedabad18 Sept 2025AY 2009-10

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2009-10

Section 143(2)Section 143(3)Section 147Section 148Section 151Section 68Section 78(2)

Amritabhagwati Tradewing Pvt. Ltd., Mumbai vs. DCIT, Central Circle - 2(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 4802/MUM/2025[2012-13]Status: DisposedITAT Mumbai17 Sept 2025AY 2012-13

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Shri Neeraj Mangla (virtually appear)For Respondent: Shri Surendra Mohan (SR DR)

Section 143(3)Section 250Section 271(1)(c)Section 274Section 68

submitted that the addition was confirmed by the Ld. AO and further upheld by the ITAT in respect of the share capital and share premium received by the assessee. It was noted that a sum of Rs. 3.63 crore was received during F.Y. 2011-12, while ... merits also, we find that the quantum addition of Rs. 9.27 crores under section 68 of the Act, relating to share capital and share premium, has been upheld by the coordinate Bench of the Tribunal. However, the confirmation of the addition in 10 Amritabhagwati Tradewing Pvt Ltd quantum