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DELHI HIGH COURT
RAJIV SAHAI ENDLAW, SANJEEV NARULA
Principal Commissioner of Income Tax – Appellant
Versus
Anand Kumar Jain (HUF) – Respondent
| Table of Content |
|---|
| 1. factual background of the share transaction. (Para 2 , 3) |
| 2. arguments challenging itat's order and evidence. (Para 4 , 5) |
| 3. court's observations on evidence required for assessment. (Para 6 , 7 , 8 , 9 , 10) |
| 4. conclusion dismissing the appeals. (Para 11) |
JUDGMENT
[VIA VIDEO CONFERENCING]
Sanjeev Narula, J, (ORAL):--The present appeals under Section 260A of the INCOME TAX ACT [hereinafter referred to as the `Act'] are directed against the common order dated 30th July, 2019 [hereinafter referred to as the `impugned order'] passed by the Income Tax Appellate Tribunal [hereinafter referred to as the `ITAT'] in ITA 5947/Del./2018, ITA No. 4723/Del./2018, ITA No. 5954/Del./2018, ITA No. 5950/Del./2018, ITA No. 5948/Del./2018, ITA No. 5947/Del./2018 and ITA No. 5955/Del./2018.
2. Briefly, the facts of the case are that the Assessee purchased shares of an unlisted private company in 2010. This unlisted company then merged with another unlisted company, M/s Focus Industrial Resources Ltd. and shares of this merged entity were allotted to the Assessee. Subsequently, the merged entity allotted further bonus shares to the Assessee and thereafter it was listed on the Bo
A statement under Section 132(4) cannot solely justify tax assessments without corroborating evidence, emphasizing the legal necessity of in-person cross-examination of witnesses.
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