Court held that dismissed the appeal of the Revenue on the ground that no incriminating material was found and the investor companies had ample funds to make investment in share capital. Court also held that opportunity of cross examination was not provided. Court also held that since issue was covered by judgment of Supreme Court in PCIT v. Abhisar Buildwell (P.) Ltd. [2023] 149 taxmann.com 399/293 Taxman 141/454 ITR 212 (SC) (AY. 2008-09 to 2011-12)
PCIT v. Jay Ace Technologies Ltd. (2023) 294 Taxman 602 (SC) Editorial : PCIT v. JPM Tools Ltd (2023) 154 taxmann.com 44 (Delhi)(HC)
S. 153A : Assessment-Search-No incriminating material was found-Share capital-Investor companies had ample funds to make investment in share capital-Opportunity of cross examination was not provided-SLP of Revenue is dismissed. [S. 68, Art. 136]