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2015 (5) TMI 125 - DELHI HIGH COURT

2015 (5) TMI 125 - DELHI HIGH COURT - [2015] 376 ITR 576 (Del) - Disallowance of loss on account of alleged share transactions - shares of certain companies purchased and further the loss claimed on account of diminution in value of those shares - whether ITAT accepting the genuineness of the loss as declared in respect of shares purchased and sold or held as stock-in-trade is perverse? - Held that:- The Tribunal proceeded on an erroneous footing that all shares have been “bought through the rec .....

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rs 1997-98 and 1998-99 certified the “traded prices of the shares.. as intimated by a member as off the floor transactions”. This, clearly, indicated that: (a) the transactions were not conducted through the stock exchange but merely reported as off market transactions; and (b) the transaction was reported by a singular member - thus, the transaction did not involve any other broker. Further the dates and quotations certified, clearly pertained to the transactions involving the assessee and or r .....

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which the assessee transacted would, obviously, be reflected as a quotation by the Gauhati Stock Exchange. The AO had found that the assessee and the companies whose shares purchased were related. It was pointed out that those companies were promoted by Mr Modi who had disclosed that he had used his undisclosed funds to promote those companies. The assessee had argued that the fact that undisclosed funds were used in promoting companies did not mean that the companies did not carry on its bu .....

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aspect of inter linked entities and overlooking the perspective outlined by the AO.

Insofar as the loss in relation to shares of Mather & Platt India Ltd. is concerned, there is no allegation that the assessee is related in any manner to the said company. In this view, the losses as claimed by the assessee in respect of Mather & Platt India Ltd. cannot be rejected. The losses claimed by the assessee, except the losses relating to the shares of Mather and Platt India Ltd. i.e. ₹ .....

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JUDGMENT Vibhu Bakhru, J 1. These appeals, preferred by the Revenue under Section 260A of the Income Tax Act, 1961 (hereinafter the Act ), impugn a common order dated 30.06.2009 passed by the Income Tax Appellate Tribunal (hereinafter the Tribunal ) to the extent that the appeals preferred by the Revenue (being ITA 3763/Del/2007, ITA 3764/Del/2007 and ITA 3732/Del/2007) against the orders passed by the Commissioner of Income Tax (Appeals) (hereafter CIT (A) ) in respect of assessment years 1997- .....

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lue of those shares. 3. Briefly stated, the relevant facts leading to the present appeals are as under:- 3.1 The assessee filed its return for the assessment year 1997-98 declaring an income of ₹ 1,05,518/-. The said income was calculated after claiming a loss of ₹ 4,64,82,500/- on account of purchase and sale of shares and diminution in the value of shares held by the assessee. By an assessment order dated 14.03.2000, the Assessing Officer (hereafter AO ) disallowed the said loss of .....

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on account of sale and purchase of shares of certain companies. By an assessment order dated 07.03.2001, the AO disallowed the said loss of ₹ 5,36,23,950/- and assessed the income of the asseesse as ₹ 11,06,81,611/- for the assessment year 1998-99. The assessee preferred an appeal before the CIT(A), which was dismissed by an order dated 13.01.2003. The assessee appealed against this order, being ITA No.2836/Del/2003, before the Tribunal. 3.3 The assessee filed a return for the asses .....

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03. The assessee appealed against this order (ITA No.2837/Del/2003) before the Tribunal. 3.4 The Tribunal, by its order dated 19.10.2004, disposed of the said appeals (being ITA No.2978/Del/2001 for AY 1997-98, ITA No.2836/Del/2003 for AY 1998-99 and ITA No.2837/Del/2003 for AY 1999-2000) along with appeal (ITA No.2835/Del/2003 for AY 1996-97). By the said order, the Tribunal deleted most of the additions made by the AO to the assessed income of the assessee but insofar as the losses claimed by .....

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1999-2000). The Tribunal also held that the documents relied upon by the assessee - confirmation memos/contract notes, bills, letters confirming registration of shares etc. - were required to be considered. 3.5 Pursuant to the order dated 19.10.2004 passed by the Tribunal, the AO considered the question with regard to the loss on account of shares claimed by the assessee in various years and disallowed the same. The AO found that the assessee had purchased most shares of certain companies from o .....

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stion were bogus. 3.6 The assessee filed appeals (being Appeal No.47/2007-08 for AY 1997-98, Appeal No.48/2007-08 for AY 1998-99 and Appeal No.49/2007- 08 for AY 1999-2000), inter alia, against the assessment orders framed with respect to the assessment years 1997-98 to 1999-00. The CIT(A) accepted the contract notes and other documents produced by the assessee as evidence of the genuineness of the transactions of sale and purchase of shares as well as reduction in their value at the end of the .....

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their value could not be set off from business income in view of Section 73 of the Act. These appeals preferred by the Revenue were rejected by the Tribunal by the common order dated 30.06.2009, which is impugned herein. The Tribunal found that the purchase bills for the shares purchased along with brokers contract note and copy of the confirmation from the respective companies indicating the transfer of shares in the name of the assessee evidenced the genuineness of the losses claimed by the as .....

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the companies whose shares were purchased by the assessee were genuine companies and regularly assessed to tax in their respective wards. Since the Tribunal held that the transaction in purchases of the shares were genuine, the decisions of the CIT(A) were upheld. 3.8 The Revenue s contention that the losses claimed by the assessee could not be set off against income by way of interest by virtue of Section 73 of the Act was rejected. The Tribunal held that as the said contention had not been ur .....

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00, on account of sale and purchase of shares of certain companies and on account of diminution in their value were allowable. 5. By an order dated 03.09.2014, this Court had indicated that the following substantial question of law arose for consideration in these appeals:- Whether the finding of the Income Tax Appellate Tribunal accepting the genuineness of the loss as declared in respect of shares purchased and sold or held as stock-in-trade is perverse? 6. The AO had concluded that the transa .....

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, similar. Thus, for the sake of brevity, the transactions relating to the previous year 1996-97 relevant to the assessment year 1997-98 are being referred to for the purpose of appreciating the AO s findings and reasoning. 8. The following shares were reflected as opening stock-in- trade as on 01.04.1996:- Name of the Company No. of shares Rate(Rs.) Value(Rs.) Baba Business Services Ltd. 91300 2.0 1,82,600 Sangrahalaya Timber & Crafts Limited 30800 2.0 61,600 Premier Auto Finance Ltd 50000 .....

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share and, therefore, a profit of ₹ 10,000 was reported in respect of the said transaction. One thousand shares of Mather & Platt India Limited were purportedly sold at ₹ 13.10 each and an aggregate loss of ₹ 400/- was reported with respect to that transaction. As is apparent from the above, the effect of aforesaid transactions was a net profit of ₹ 9,600/-, which is not significant. The paper book filed before this court also does not contain any documents relating .....

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he aforesaid shares, except shares of M/s Doyang Wood Products. Ltd. amounting to ₹ 1,30,000, were purchased from one Shri Nem Chand Jain. Thus, the assessee claimed that it had purchased shares of a value of ₹ 5,34,19,550/- from Shri Nem Chand Jain. These shares were not sold during the year and were reflected as a part of the closing stock of shares as on 31.03.1997. The shares of Doyang Wood Products were stated to be purchased from one Shama Holdings Private Limited at the rate o .....

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39; transactions and not through any stock exchange or through any stock broker. 12. For the previous year ending 31.03.1997, the assessee had claimed a loss of ₹ 4,64,82,500/-. This loss has two components; the first being, loss relating to sale and purchase of shares and the second being loss on account of diminution in value of the stock of shares held by the assessee at the end of the year. Whilst an amount of ₹ 88,900/- was claimed as loss on sale of shares, the bulk of the loss .....

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aid amount is as under:- S. No. Name of the Coy. (M/s) No. of Shares Rate (Rs.) Value (Rs.) Losses (Rs.) 1. M/s Hotahoti Wood Products Ltd. 96125 15.60 2.40 1,26,88,50 2. M/s Purbanchal Prestressed Ltd. 124000 15.60 2.50 1,61,20,000 3. M/s Kamini Finance & Inv. Ltd. 1635000 20.00 2.30 2,89,39,500 Total 4,63,28,350 13. As indicated earlier, the abovementioned shares, which are claimed to have resulted in loss on account of reduction in their value, were claimed to have been purchased by the a .....

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Ltd. to one Shri Ram Lal Ashoka of Chandni Chowk, Delhi; e) copy of the ledger accounts; and f) certificate dated 12.02.2000 from Gauhati Stock Exchange indicating the prices at which the shares of the companies involved were traded. 15. The assessee further asserted that Shri Nem Chand Jain was a broker with the Gauhati Stock Exchange and the memos of confirmation as well as the bills produced evidenced the genuineness of the purchase transactions. In addition, the assessee also produced a cer .....

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d that search and seizure operations were conducted in the case of Shri Nem Chand Jain on 14.10.1996. During the course of the said search and further proceedings, statement of Shri Nem Chand Jain was recorded under Section 132(4) and Section 131 of the Act and the same were forwarded to the AO. Shri Nem Chand Jain had stated that he was a Director/Managing Director of M/s Doyang Wood Products Ltd., M/s Kamini Finance & Investment Ltd., M/s Hotahoti Wood Products Ltd. in addition to other co .....

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td. 4. Manipur Pharmaceuticals Ltd. 5. Pulp Products Ltd. 6. M/s Raksha Audio Ltd. 7. Sangrahalaya Timber & Crafts Ltd. 8. M/s Doyang Wood Products Ltd. 9. M/s North Eastern Publishing & Advertising Co. Ltd. 10. Hotahoti Wood Products Ltd. 11. Purbanchal Presstressed Ltd. 12. Kamini Finance & Investment Co. Ltd. Mr R.R. Modi had further admitted that the companies mentioned at serial no. 7 to 12 above were not genuine companies. 19. The AO took note of the above statements received f .....

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including shares of a value of ₹ 5,34,19,550/- from Shri Nem Chand Jain. And, the said consideration was shown as credit in the name of the sellers. b) Although Shri Nem Chand Jain had financed almost the entire purchase of shares, there was no agreement with Shri Nem Chand Jain for this financing arrangement. He had also not charged any interest on the amounts outstanding. c) Shri Nem Chand was not a person of means and his creditworthiness was not established. The report of the Income Ta .....

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Exchange. e) The AO further noted that the shares of the companies which were involved were not actively traded and thus the quotations indicating the value of the shares could not be accepted. No material was produced to controvert the finding that the shares of the companies were not actively traded. f) The assessee and the companies in question were interlinked. Shri R. R. Modi had floated certain number of companies by introducing his undisclosed capital and he was also a Director on the Boa .....

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hand Jain continued to sell shares to the assessee even in the following year, i.e., year ended 31.3.1998. No explanation was provided as to why Shri Nem Chand Jain, inspite of being an unpaid seller would physically deliver the shares sold by him. 20. In the first round, the Tribunal remanded the matter to the AO ( by an order dated 19.10.2004) principally on the ground that the assessee had not been confronted with the material relied upon by the AO and further to examine the effect of contrac .....

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ransaction done by assessee, the shares in question were not quoted and thus, they did not reflect the true value of the shares in question. It was held that the documents produced by the assessee were only for the purpose of misleading the authorities and could not establish that the transactions were genuine. 21. The nature of transactions relating to the assessment years 1998-99 and 1999-2000 are not materially different. 22. During the year ended 31.03.1998, 30800 number of shares of Sangrah .....

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sis. Thereafter, on 15.05.1997 the assessee is stated to have purchased 27,50,000 shares of Sangrahalaya Timber and Crafts Limited @ ₹ 10/- each. These shares were also purchased from Mr N.C. Jain and the memo of confirmation also indicates that the transaction between assessee and Mr N.C. Jain was on principal to principal basis. The said shares were valued at the rate of ₹ 2.25/- each at the end of the year and on this basis the assessee claimed a loss of ₹ 2,13,12,500/-. 23. .....

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vertising Company Limited. The memos of confirmation relied upon by the assessee reflect that the shares of the abovementioned companies were purchased from Mr N.C. Jain on a principal to principal basis. These transactions were not through stock exchange; the certificate produced by the assessee from the Gauhati Stock Exchange indicates that these transactions were off the floor transactions and were merely informed to the said stock exchange. The assessee valued these shares at a fraction of i .....

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amp; Advertising Company Ltd. 3500000 10.00 35000000 26250000 Total 52362500 25. In addition to the above, the assessee also claimed a loss of ₹ 1,12,500/- on account of diminution in the value of 37,500 shares of Mather & Platt India Ltd. as on 31.03.1998. Thus, the total loss claimed by the assessee for the year ended 31.03.1998 was ₹ 5,36,23,950/- out of which ₹ 11,48,950/- was loss on account of sale of shares and ₹ 5,24,75,000 on account of diminution in value of .....

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00 shares of Hotahoti Wood Products Ltd. at the rate of ₹ 10/- each, the details of which are as under:- Name of Seller No. of shares Date Value Purbanchal Prestressed Ltd. 50,00,000 14.05.1998 5,00,00,000 Sangrahalaya Timber and Crafts Limited 36,85,000 13.05.1998 3,68,50,000 28. Out of the aforementioned, 82,16,750 shares of Hotahoti Wood Products Ltd. were purportedly sold for an aggregate amount of ₹ 2,46,50,250/- thus resulting in a loss of ₹ 5,75,17,250/-. Out of these sh .....

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in respect of which losses were booked were floated by Mr R.R. Modi by introducing his undisclosed income. The assessee had not only purchased shares of the companies floated by Mr Modi but had also purchased and sold shares of the said companies. In addition, the said companies also held substantial shares of the assessee. 30. In our view, the facts as outlined by the AO clearly indicate an established link between the companies floated by Shri R. R. Modi and the assessee. This fact has also n .....

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The only inference that can be drawn is that there was no trading on other dates and this confirms the view that there was hardly any trading on the shares of the company in question. Since the shares in question are not actively traded, their quotations at the Stock Exchange could easily be manipulated by showing transaction in small number of shares. And, in any case would not be reflective of their value. The stock certificates of Gauhati Stock Exchange for the assessment years 1998-99 and 1 .....

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t he owned/controlled a good part of the share holding. The shares, which are alleged to have been purchased by the assessee, were not paid for and only book entries were passed. Although, it is stated that the shares were through a broker of the Guwhati Stock Exchange. There is no evidence to show that the transaction of purchase of shares was done through the Gauhati Stock Exchange. On the contrary, the certificates issued by the Gauhati stock exchange put it beyond any pail of doubt that the .....

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g decisions:- CIT Vs Dhawan Investment and Trading Co. Ltd. (1999) 238 ITR 486 (Cal); CIT Vs Currency Investment Co. Ltd. (2000) 244 ITR 494 (Cal); CIT Vs Carbo Industrial Holdings Ltd. (2000) 244 ITR 422 (Cal); CIT Vs Kundan Investment Ltd. (2003) 263 ITR 626: & CIT Vs Janki Textiles & Industries Ltd.(2003) 132 Taxman 231 (Gau). 33. The CIT(A) failed to consider any of the reasons provided by the AO for holding the transactions to be not genuine; CIT(A) did not address any of the follow .....

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shares were not actively traded and the transactions were amongst inter related parties. Thus, the quotations reflected on the Gauhati Stock Exchange could not be relied upon to reflect their value. c) There was no evidence produced to show that Shri Nem Chand Jain who is stated to have funded the purchase of shares by the assessee, had any means to do so. The AO had found that Shri Nem Chand Jain was not a man of means. The assessee had produced no evidence to contradict this. d) Admittedly, th .....

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isions referred to by CIT(A) are also, plainly, not applicable. In case of Janki Textiles and Industries Ltd. (supra), there was no allegation that payments for the shares in question had not been made and the transaction consisted of only book entries. On the contrary, the Court found that all payments had been made and received through account payee cheques and/or drafts. In that case, the Court specifically noted that no evidence was placed by the Revenue to indicate that the disputed share t .....

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was not a person of means and his declared income was only ₹ 40,000/- by way of salaries. The assessee sought to dispute this by producing a balance sheet of Mr N.C. Jain. However, that also indicated that he owed a large sum of money - ₹ 7.5 crores to his creditors. There was no finding as to the net worth of Mr. N.C. Jain. In addition to the above, no payment had been made for the purchase of shares during the relevant period. Mr N.C. Jain was stated to be a broker. No explanation .....

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ee to be financially constrained. Shri NC Jain is stated to have sold shares for ₹ 6,89,00,000/- in the year ended 31.03.1998 thus swelling his outstanding credit to ₹ 12,22,57,950/- as on 31.03.1998 after adjusting ₹ 60,600/- on account of shares purportedly purchased by Sh. N. C. Jain. 36. In our view, the CIT(A) completely ignored the aforesaid facts and merely cited the judgments where contract notes had been accepted as evidence of genuine transaction. Undoubtedly, contrac .....

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accepting the transactions in shares to be genuine as the assessee had furnished the names and addresses of brokers and also shown payments made to them by account payee cheques. The companies whose shares were subject matter of transaction were blue chip companies and extensively traded on the stock exchange. The Revenue had rejected the transactions only on the ground that the assessee could not produce certain brokers. The Court held that even if the share brokers did not appear the claim of .....

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and made through registered brokers. There was no allegation that the consideration for the sale and purchase was not paid through banking channels or that the transactions in question concerned related companies. 39. In Kundan Investment Co. Ltd. (supra), the Court found that the sale and purchase transactions, which were questioned by the Revenue, were in respect of shares of reputed companies which were quoted on the stock exchange. The transactions were supported by contract notes and bills .....

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in issue. The Tribunal proceeded on an erroneous footing that all shares have been bought through the recognised stock exchange through the main broker of the exchange . There was no evidence to indicate that all shares were bought through the stock exchange. The assessee also did not claim this; the assessee had claimed before the AO that all shares were bought from the broker of Gauhati Stock Exchange . In the submissions filed before the AO, the assessee contended that the transaction for pu .....

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hasing brokers are required to pay the consideration on the pay in date . The consideration for the shares transacted through the stock exchange is paid to the selling broker on the pay out date . Thus, in cases of transaction through a stock exchange a purchasing broker is required to deposit the consideration with the clearing system of the stock exchange. However, in the present case bulk of the shares in question were claimed to have been sold/purchased by Mr N.C. Jain. The memos of confirma .....

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Jain had purchased the shares through the stock exchange for the assessee, in the normal course, he would have issued a contract note indicating the shares bought for the assessee. The assessee had also produced bills from Mr N.C. Jain evidencing sale of shares to the assessee. These documents produced by the assessee clearly indicated that the transactions for purchase of shares were not being claimed as transactions done through the stock exchange. The AO had, therefore, found and in our view .....

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hat all shares were transacted through Gauhati stock exchange, is not supported by any material and is perverse. The Tribunal held that All documentary evidences itself prove that assessee had bought/sold these shares at the prevailing market price and based on the same, the genuineness of the transactions could not be doubted . This finding is also patently erroneous. 44. None of the material produced by the assessee could be relied upon to indicate the market value of the shares. The certifica .....

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ertained to the transactions involving the assessee and or related companies as parties. The dates of the memos of confirmation and the date of transaction reported to the stock exchange are the same in almost all instances. Thus, these certificates, which only certify the prices at which transactions in question were reported cannot prove that the transactions were executed at market value. Since these transactions in question were not done in open market, but between related concerns and no ot .....

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sal of the said order indicates that the Tribunal had noted the following submission on behalf of the assessee:- Shri Vohra also drew our attention to the audited balance sheet of Shri N.C. Jain (Pages 64 to 67 of the Paper Book) to show that Mr. Jain was man of means having a closing stock of shares worth ₹ 1.70 crores and a liability of ₹ 7.50 crores to its creditors. However the Tribunal did not return any finding on the question of Mr N.C. Jain s creditworthiness. In our view, th .....

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.R. Modi had created several entities which were involved or connected with the transactions in question. In the circumstances, the payment of money to Mr N.C. Jain was required to be investigated further to ascertain as to the ultimate recipient of those funds. No such exercise has been done in this case. Thus, in our view, the fact that certain payments were shown to have been made to Mr N.C. Jain in 2005-06, would not be sufficient to conclude that the transactions in question were genuine. 4 .....

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estion. The assessee had booked losses in respect of shares of certain companies. The close link between the said companies and the assessee was clearly established. In our view, the link established between the assessee and these companies was important in considering the question whether the transactions of shares were genuine or not. It is relevant to take note of the following:- (a) That the assessee had booked losses in respect of shares of the following companies:- (i) Sangrahalaya Timber .....

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oney was introduced in different names by Mr R.R. Modi indicates that although there may have been a number of shareholders, the de facto control of the companies as well as its shares vested with Mr R.R. Modi. (c) Sh. R.R. Modi was also a Director of the assessee company. (d) The aforesaid companies also held substantial shares of the assessee. (e) The assessee had not only dealt with shares of the aforementioned companies but also had purchased certain shares from some of the companies. (f) Al .....

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