ITO v. Shree Banke Bihari Infracon P. Ltd. (2024)115 ITR 223 / 163 taxmann.com 344 (Raipur)(Trib)

S. 68 : Cash credits-Share Capital-Share premium-Explained the source and capacity-Addition is not valid-Assessment jurisdiction-Issue of jurisdiction was not raised within stipulated time-Assessment is valid.[S. 124(3), 142(1) 143(2), 143(3)]

Held that the  assessee discharged the burden cast upon it by filing  confirmation of share applicant, bank statement, return of income, financial statements of investor company, share application forms, Permanent Account Number, memorandum and articles of association, board resolution and return of allotment in Form 2  etc. Order of CIT(A) deleting the addition is affirmed.  As regards the jurisdictional issue the  assessee has not raised the issue within time of one month from date on which it was served with notice under Section 142(1)  hence the  assessment  is valid.   (AY. 2013-14)

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