2023 (9) TMI 794 - ITAT PANAJI

Addition u/s 56(2)(vii) - shares of the company were purchased for a consideration which is less than the fair market value of the shares - year of purchases of the shares - facade to convert unaccounted money by way of shell companies and putting them into a series of transactions to give a legitimate colour of converting of unaccounted cash available with the individuals - HELD THAT:- Appellant had nowhere contested the applicability of the provisions of sec.56(2)(vii)(b) of the Act to the transactions

Challenge for year of transaction was rightly dislodged by the Ld. CIT(A) as well as the Assessing Officer by bringing the cogent material on record to show that the assessee-appellant had purchased the shares during the year under consideration. The assessee also had failed to controvert the findings of the lower authorities that it is a device adopted to bring into books the unaccounted money of the assessee-appellant. Thus, we do not see any reason to interfere with the orders of the lower authorities. Decided against assessee.