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Accordingly, the appeal fails and is dismissed
Bench: : The Hon’Ble The Chief Justice T.S. Sivagnanam & The Hon’Ble Justice Chaitali Chatterjee (Das) Dated : 1St July, 2025 Appearance: Mr. Vipul Kundalia, Sr. Adv. Mr. Prithu Dudhoria, Adv. ..For Appellant Mr. Saurabh Bagaria, Adv. Mr. Rites Goel, Adv. Ms. Samrita Das, Adv. ..For Respondent
68 of the Act could have been invoked in the facts and circumstances of the assessee’s case for the assessment year under consideration. The learned Tribunal has taken note of the factual position that the assessee has issued equity shares to two group companies and the two group companies have common directors. According to the Assessing Officer, those companies