IN THE INCOME TAX APPELLATE TRIBUNAL BENCH-RANCHI VIRTUAL HEARING AT KOLKATA Before Shri Sonjoy Sarma, Judicial Member and Shri Ratnesh Nandan Sahay, Accountant Member Assessment Year: 2008-09 M/s Anjeneya Ispat Ltd.…………….…….…............................……….……Appellant

29, Rain Basera, Sanjay Nagar Colony, Adityapur, Saraikela, Jharkhand – 831013.

[PAN: AAGCA1031N]

vs.

DCIT, Circle-1, Jamshedpur……....….…..….........……........……...…..…..Respondent Appearances by:

Shri Devesh Poddar, AR, appeared on behalf of the appellant.

Shri Kanhaiya Lal Kanak, DR, appeared on behalf of the Respondent.

Date of concluding the hearing : November 11, 2025 Date of pronouncing the order : January 06, 2026

ORDER

Per Sonjoy Sarma, Judicial Member:

This appeal filed by the assessee is directed against the order of the CIT(A), Jamshedpur (hereinafter referred to as “ld. CIT(A)”) dated 21.08.2018 passed under Section 250 of the Income-tax Act, 1961 (hereinafter referred to as the “Act”).

2. Brief facts of the case are that the assessee company is engaged in the manufacturing of pig iron. It filed its return of income declaring total income of ₹1,41,05,250, which was processed under section 143(1). During the assessment proceedings, the Assessing Officer noticed that the assessee had received share capital and share premium aggregating to ₹3,00,00,000 during the relevant previous year. The Assessing Officer issued notices under sections 142(1) and 148 requiring the assessee to furnish complete details of the share applicants, including identity, creditworthiness, and genuineness of the transactions. In response, the assessee furnished complete details in respect of the share capital/share premium received from the following parties:

Name of Share Applicant Amount (₹) Rotomac Vinimay Pvt. Ltd. 45,00,000 Singora Brothers Holding Pvt. Ltd. 20,00,000 Emkay Merchandise Pvt. Ltd. 15,00,000 Polson Tie-up Pvt. Ltd. 75,00,000 Sirodhi Home Products Pvt. Ltd. 70,00,000 Tajaswi Pvt. Ltd. 75,00,000 Uday Singh HUF 4,00,000 Ajit Singh HUF 3,00,000 The assessee submitted complete names and addresses of share applicants, PAN, ITR acknowledgements, Audited financial statements, MCA master data showing active status, Bank statements evidencing transactions through banking channels. Despite the above submissions, the Assessing Officer treated the share capital and share premium amount as unexplained and made an addition of Rs.2,70,00,000 under section 68 of the Act. The Assessing Officer, however, did not conduct any independent enquiry, nor were notices issued under section 133(6) of the Act to the share applicants.

3. Aggrieved by the order of the AO assessee preferred an appeal before the Ld. CIT(A) where the Ld. CIT(A), while disposing of the appeal, initially enhanced the addition at Rs.4,00,00,000 and subsequently enhanced it by 3,07,00,000/- instead of ₹4,00,00,000. Later, rectification order under section 154 of the Act was carried out, resulting in confusion regarding the exact quantum of addition.

4. Dissatisfied with the order of the Ld. CIT(A) the assessee challenged the impugned order before the Tribunal. At the time of hearing the Ld. Counsel for the assessee submitted that all three ingredients of section 68 of the Act, namely identity of share applicants, creditworthiness and genuineness of transactions were fully established through documentary evidence and no independent enquiry was conducted by the Assessing Officer despite availability of complete details on record. Moreover, no material was brought on record to suggest that the share applicants were bogus or non-existent or the assessee routed its own unaccounted money through the transaction. The ld. AR submitted that during the assessment proceedings, the assessee made compliances by submitting necessary documents such as details of the share applicants, complete names and addresses of share applicants, PAN, ITR acknowledgements, Audited financial statements, MCA master data showing active status, Bank statemen