DCIT v. NCR Business Park (P.) Ltd. (2022) 196 ITD 678 (Delhi) (Trib.)

S. 68 : Cash credits-Share capital-Share premium-Shares allotment-Converted fully convertible debentures (FCDs) into equity shares on same price of FCDs-No credit entry during the year.

The assessee converted fully convertible debentures (FCDs) into equity shares at same price of FCDs and showed share capital and share premium.  Assessing Officer made addition  as unexplained cash credit. CIT (A) held that no money was actually received or credited during year but only amount which was already received in past years on issuing FCDs was converted into equity shares,   since  there was no credit entry of cash made in relevant year and there was mere dressing of accounts, addition was deleted. Tribunal affirmed the order of  Commissioner (Appeals). (AY. 2014-15)