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DCIT, Central Circle-1(2), Kolkata Vs SiddheshwariVyapaar Pvt Ltd

Case No: ITA No.2280/KOL/2025
Court: INCOME TAX APPELLATE TRIBUNAL “D” BENCH, KOLKATA
Date: 12/23/2025

Parties Involved

appellantDCIT, Central Circle-1(2), Kolkata
respondentSiddheshwariVyapaar Pvt Ltd

Facts Summary

The assessee, SiddheshwariVyapaar Pvt Ltd, is a company incorporated under the Companies Act, 1956 and engaged in the business of Non-Banking Financial Company. The assessee filed its return of income for A.Y.2012-2013 declaring total income amounting to Rs.31,600/-. The case was selected for scrutiny and the Assessing Officer assessed the total income to Rs.4,39,680/-. Subsequently, the assessment was reopened and the Assessing Officer added Rs.6,82,00,000/- as unexplained cash credits received from shell entities in the guise of share capital. The assessee provided detailed documentation to support the genuineness of the transactions, but the Assessing Officer treated the share capital received from seven investors as unexplained cash credit.

Decision in favour of

Partly Assessee / Partly Revenue

Legal Issues

  • 1. Whether the addition of Rs.6,82,00,000/- made u/s.68 of the Act on account of unexplained cash credits received from shell entities in the guise of share capital is valid.

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

16 precedents cited in this judgement.

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