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Joint Commissioner of Income Tax, OSD vs. AFP Manufacturing Co. P. Ltd.

Case No: ITA No. 3107/DEL/2025 (A.Y. 2018-19)
Court: Income Tax Appellate Tribunal, Delhi Bench 'C'
Bench: Delhi Bench 'C'
Date: 2/19/2026

Parties Involved

appellantJoint Commissioner of Income Tax, OSD
respondentAFP Manufacturing Co. P. Ltd.

Facts Summary

The Revenue has appealed against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, dated 29.03.2025, for AY 2018-19. The Revenue challenges the deletion of an addition of Rs.1,44,34,290/- made under Section 68 of the Income Tax Act, 1961. The assessee received share capital and share premium aggregating to Rs.2,10,00,000/- during the year under consideration. The assessee furnished the names, PAN, and amounts of premium received but failed to prove the creditworthiness of the investors. The CIT(A) deleted the addition without ascertaining the creditworthiness of the investors. The assessee had allotted shares to Anil Kumar Agarwal, Raj Bala, and Puneet Agarwal against unsecured loans received in preceding years, hence no fresh funds were infused.

Decision in favour of

Assessee

Legal Issues

  • 1. Deletion of addition of Rs.1,44,34,290/- made under Section 68 of the Income Tax Act, 1961.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

6 precedents cited in this judgement.

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