Case Law Details
PCIT Vs Surya Agrotech Infrastructure Limited (Delhi High Court)
Introduction: The Delhi High Court recently delivered a significant judgment in the case of PCIT (Principal Commissioner of Income Tax) vs. Surya Agrotech Infrastructure Limited. This legal battle revolves around the taxation of undisclosed income and the potential issue of double taxation. In this article, we delve into the details of the case and provide a comprehensive analysis.
Detailed Subheading Wise Analysis
1. Background of the Case: The case comprises three appeals filed by the revenue under Section 260A of the Income Tax Act, which share a common factual and legal context. These appeals were consolidated for adjudication by the Delhi High Court.
2. Unearthing Undisclosed Income: The assessees in question are companies associated with the Priya Gold Group of Companies. In December 2014, the Income Tax authorities conducted search and seizure operations under Section 132 of the Income Tax Act in the premises of Priya Gold Group of Companies. During this operation, Shri Shekhar Aggarwal, the Director of Surya Food & Agro Limited (the flagship company of the group), made a statement under Section 132(4) of the Act. In this statement, he confessed that the group had earned unaccounted income, which had been funneled as bogus share capital during specific financial years.
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