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ACIT, Circle 25 (1) vs. Vipul Limited

Case No: ITA No.2047/Del/2021
Court: Income Tax Appellate Tribunal, Delhi Bench ‘E’, New Delhi
Date: 1/22/2025

Parties Involved

appellantACIT, Circle 25 (1)
respondentVipul Limited

Facts Summary

The assessee, Vipul Limited, filed its return of income for Assessment Year 2007-08 declaring an income of Rs.67,58,29,846/-. Subsequently, the assessee revised its return declaring a total income of Rs.71,13,29,746/-. The assessment was completed under section 143(3) of the Income-tax Act, 1961, determining the total income at Rs.75,86,98,436/-. The case was later reopened under section 147 of the Act by issuing a notice under section 148. During the assessment proceedings, the Assessing Office

Decision in favour of

Partly Assessee / Partly Revenue

Legal Issues

  • 1. Whether the Ld. CIT(A) has erred in deleting the addition of Rs. 4,32,68,666/- out of Rs. 4,38,00,448/- on account of purchasing shares of its sister concern at a high premium.
  • 2. Whether the Ld. CIT(A) has erred in law and facts in holding the reopening of assessment under section 147 r.w.s. 148 of the Income Tax Act, 1961 as valid.

Precedents Relied Upon

6 precedents cited in this judgement.

Judgment Outcome

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