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2025 Supreme(Online)(ITAT) 11010

INCOME TAX APPELLATE TRIBUNAL (KOLKATA BENCH)
DEPUTY.COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-4(4) KOLKATA AAYAKAR BHAWAN POORVA – Appellant
Versus
PCJ FINVEST PRIVATE LIMITED SILIGURI WEST BENGAL – Respondent


IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, AM AND SHRI SONJOY SARMA, JM (Assessment Year:2008-09)

PCJ Finvest Private DCIT Limited Aaykar Bhavan Poorva, 5th Floor, 4th Floor, Commercial Block Room No.509, 110-Shanti Pally, Vs. 2nd Mile Metro Heights, Kolkata-700107, West Bengal Sevoke road, Siliguri-734001, West Bengal (Appellant) (

Respondent)

PAN No. AABCP8375R Assessee by : Shri Soumitra Choudhry, AR Revenue by : Shri Guru Bhashyam, CIT DR Date of hearing: 06.02.2025 Date of pronouncement : 28.02.2025

O R D E R

Per Rajesh Kumar, AM:

This is an appeal preferred by the Revenue against the order of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the “Ld. CIT(A)”] dated 20.10.2023 for the AY 2008-09.

02. The only issue raised by the Revenue is against the deletion of addition of ₹25,56,00,000/- by the ld. CIT (A) as made by the ld. AO on account of share capital / share premium being unexplained credit u/s 68 of the Act.

03. The facts in brief are that the assessee filed the return of income on

31.03.2009, declaring total income at ₹16,889/-. The assessment was originally framed u/s 147/143(3) of the Act vide order dated 25.11.2

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