Section 68 Inapplicable to Sale Proceeds of Disclosed Investments: ITAT Delhi

ITO Vs Jatin Investment Pvt. Ltd. (ITAT Delhi) The Revenue filed two appeals before the ITAT Delhi challenging the order of the Commissioner of Income Tax (Appeals) deleting additions made under Section 68 of the Income-tax Act on account of alleged unexplained sale proceeds of shares and consequential commission. The Assessing Officer (AO) had reopened the assessment under Section 147 on the basis of information received from the Investigation Wing alleging that the assessee had received accommodation entries amounting to Rs. 93,45,000. The AO issued notices under Section 131 to the persons f...