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Ravilochanah Mercantile Pvt. Ltd. vs. ITO Wad 4(1)

Case No: ITA No. 800/KOL/2017
Court: INCOME TAX APPELLATE TRIBUNAL “C” BENCH, KOLKATA
Date: 3/12/2025

Parties Involved

appellantRavilochanah Mercantile Pvt. Ltd.
respondentITO Wad 4(1)

Facts Summary

The assessee, Ravilochanah Mercantile Pvt. Ltd., filed its return of income on 08.09.2012, declaring a total income of ₹427. The return was selected for scrutiny under Computer Assisted Scrutiny Selection (CASS) due to the large share premium received by the assessee. The assessee provided detailed information and documents to the Assessing Officer (AO) during the assessment proceedings, including names, addresses, PANs, audited accounts, copies of bank statements of allottees, and its own audited accounts, allotment return, form No. 18, Board Resolutions, and bank statements. Despite this, the AO treated the share capital/share premium of ₹1,02,00,000/- as unexplained income and added it to the assessee's income, relying on precedents set by the Supreme Court. The Commissioner of Income Tax (Appeals) [CIT (A)] upheld the AO's order. The assessee appealed to the Income Tax Appellate Tribunal (ITAT).

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the addition of ₹1,02,00,000/- as share capital/share premium by the AO is justified.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

4 precedents cited in this judgement.

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Version 2.0.1Last updated: October 2025
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