SHRI. SRIRAM RUPANAGUNTA,BANGALORE vs. ASISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-5(3)(2), BANGALORE
In the result, the appeal filed by the assessee stands allowed
ITA 31/BANG/2023[2015-15]Status: DisposedITAT Bangalore18 May 2023AY 2015-15
Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2015-16 Shri Sriram Rupanagunta, The Assistant 34 Purva Park Ridge, Commissioner Of Goshala Road, Income Tax, Garudachar Palya, Circle – 5(3)(2), Bangalore – 560 048. Vs. Banglore. Pan: Ahlpr7578N Appellant Respondent Assessee By : Shri Kodhanda Pani, Ca : Shri Kiran .D, Addl. Cit Revenue By (Dr) Date Of Hearing : 13-04-2023 Date Of Pronouncement : 18-05-2023 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Order Dated 24.11.2022 Passed By Nfac For Assessment Year 2015-16 On Following Grounds Of Appeal: “1. The Ld.Assessing Officer Erred In Passing The Assessment Order In The Manner In Which It Is Done On The Basis Of Presumptions, Assumptions & Surmises & Inferences, Conjecture & Hypothetical, Than On The Basis Of The Facts.
For Appellant: Shri Kodhanda Pani, CA
Section 111ASection 143Section 2Section 2(14)Section 2(47)Section 234Section 47Section 54E
gains by the revenue authorities. The Ld.AR submitted as under:
4.1 The Ld.AR submitted that the Ld.AO did not appreciate and consider that the holding period is from the day, the right to acquire shares came into existence in the previous company being the grant followed by vesting, and merely because of exchange of shares consequent to the amalgamation/merger under