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Reopening Quashed Due to Borrowed Satisfaction in Share Capital Case
Case Law Details
- Case Name
- DCIT Vs Siddheshwari Vyapaar Pvt. Ltd. (ITAT Kolkata)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2012-2013
- Courts
- All ITAT, ITAT Kolkata
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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...
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