TMI Blog2022 (3) TMI 1437X X X X Extracts X X X X X X X X Extracts X X X X ..... of fact by the Tribunal that the transaction of purchase and sale of the shares of the alleged penny stock of shares of Ramkrishna Fincap Ltd. ( RFL ) is done through stock exchange and through the registered Stock Brokers. The payments have been made through banking channels and even Security Transaction Tax ( STT ) has also been paid. The Assessing Officer also has not criticized the documentati ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... umstances of the case and in law, the Hon ble Tribunal was justified in deleting the addition of Rs.1,03,33,925/- made by AO u/s 68 of the I.T. Act, 1961, ignoring the fact that the shares were bought/acquired from off market sources and thereafter the same was demated and registered in stock exchange and increase in share price of Ramkrishna Fincap Ltd. is not supported by the financials and, the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is no allegation against assessee that it has participated in any price rigging in the market on the shares of RFL. 3. Therefore we find nothing perverse in the order of the Tribunal. 4. Mr. Walve placed reliance on a judgment of the Apex Court in Principal Commissioner of Income-tax (Central)-1 vs. NRA Iron Steel (P.) Ltd. 2019 (103) taxmann.com 48 (SC). but that does not help the revenue ..... X X X X Extracts X X X X X X X X Extracts X X X X
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