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2021 (8) TMI 1209 - ITAT KOLKATARevision u/s 263 - as per CIT AO's action in respect of receipt of share capital by the assessee is erroneous as well as prejudicial to the revenue - HELD THAT:- AO had issued notice u/s.142(1) and called for all the details of the share subscribers/share premium and pursuant to the notice of AO, the assessee had filed all the documents to substantiate the identity, creditworthiness and genuineness of the share subscription. The source of source of the share subscription was also brought to the notice of the AO, Assessee company is a private limited company and it is closely held and has raised share subscription from its own directors and their wives who are all income tax assessee's and all the money has come through banking channel and their creditworthiness has also been proved by the documents produced - PCIT erred in finding that the source of share subscribers has not been properly enquired by the AO - since the condition precedent for invoking the revisional jurisdiction has not been satisfied the Ld. PCIT lacks of jurisdiction. - Decided in favour of assessee.
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