Reopening Quashed Due to Borrowed Satisfaction in Share Capital Case

DCIT Vs Siddheshwari Vyapaar Pvt. Ltd. (ITAT Kolkata) Borrowed Satisfaction Dooms Reopening: Pre-2013 Share Capital Case: No Proviso to 68, No Cross-Examination, No Addition Kolkata ITAT ‘D’ Bench in DCIT vs Siddheshwari Vyapaar Pvt Ltd (ITA No.2280/Kol/2025, AY 2012-13, order dated 23-12-2025) dismissed Revenue’s appeal and upheld the CIT(A)’s order quashing reassessment and deleting ₹6.82 crore addition u/s 68 relating to alleged shell-entity share capital. The assessee, an NBFC, had originally been assessed u/s 143(3). Reopening was initiated on the basis of Investigation Wing inf...