No Room for Double Assessment: ITAT Deletes ₹45 Crore Bogus-Loss Addition

JCIT (OSD) Vs H B Leasing & Finance Company Ltd. (ITAT Delhi)

A search u/s 132 was conducted on the assessee-company (engaged in share trading) on 07.08.1997.  AO completed block assessment u/s 158BC on 03.02.2017, determining undisclosed income of ₹45.03 crore by disallowing losses on sale of shares as “bogus.”

CIT(A) deleted the entire addition holding that all transactions were recorded in regular books &  duly disclosed in returns filed prior to the search. Revenue appealed before ITAT, while assessee filed a cross-objection.

Tribunal’s Key Ob

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