2017 (11) TMI 503

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... areholder is the daughter of one of the directors of the company. It is, therefore, not a transaction between two strangers. We have also noticed that the earning statements of Smt. Pammi Sandesara’s husband and her bank accounts show prima facie evidence of the means of the shareholder. The amounts have been received through the banking channels. Bearing in mind all these factors, in our consider .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... are application money received from Smt. Pammi Sandesara, daughter of one of the directors of the assessee-company. 3. To adjudicate on this appeal, a few material facts need to be taken note of. During the course of assessment proceedings, the Assessing Officer noted that the assessee-company has received share capital subscription of ₹ 19,00,000/- from one Smt. Pammi Sandesara. When the .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... has invited our attention to a copy of passport of Smt. Pammi Sandesara which shows that she is a resident of USA, as also earning statements of her husband issued by NetApp Inc, USA. It is also pointed that Smt. Pammi Sandesara is the daughter of one of the directors of the company a fact which is not in dispute by the authorities below. Learned Counsel also invited our attention to the facts .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X