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Source-of-Source Amendment Not Retrospective: Tribunal Spares Company from₹4.5 Cr Share Application Addition-
Case Law Details
- Case Name
- ITO Vs Sourabh Logistics Pvt.Ltd. (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2013-14
- Courts
- All ITAT, ITAT Delhi
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ITO Vs Sourabh Logistics Pvt.Ltd. (ITAT Delhi)
Source-of-Source Amendment Not Retrospective: Tribunal Spares Company from₹4.5 Cr Share Application Addition-
Background
AO’s Assessment (30.03.2016 u/s 143(3)):
Added ₹6.15 Cr u/s 68 (share application money, unsecured loans & cash deposits).
Disallowed expenses ₹2.90 Lakh.
Assessed income: ₹6.23 Cr vs returned ₹4.8 Lakh.
CIT(A) (10.02.2023, NFAC Delhi):
Deleted ₹4.50 Cr (share application money).
Deleted ₹1.50 Cr (unsecured loans).
Part relief granted.
Revenue’s Appeal before ITAT: Challenged both deletions.
Tribuna...






