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TMI Blog2019 (7) TMI 443X X X X Extracts X X X X X X X X Extracts X X X X ..... ise of sending the matter back to the AO for a fresh assessment pursuant to the impugned order of the PCIT under Section 263 is not warranted. The Revenue has not been able to persuade this Court that the amount received from AAPIL was not converted to share capital and remained in the nature of loans and advances. That fact is reflected as such in the balance sheet. Consequently, the observati ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Appellate Tribunal (ITAT) in ITA No. 2394/Del/2018 for the Assessment Year (AY) 2013-14. 3. The question of law sought to be urged by the Revenue is whether the ITAT was justified in quashing the order passed by the Principal Commissioner of Income Tax (PCIT) under Section 263 of the Income Tax Act, 1961 (the Act ) by holding that the provision of Section 2 (22) (e) of the Act in respec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n completed without proper examination of the verification of the transaction with M/s AMQ Agro India Pvt. Limited (AAIPL). It was observed that Ms. Nasreen Moin Qureshi was having a share holding of 33% in the Assessee company and 73% in AAIPL. There was an advance of ₹ 2.5 crores which was shown as outstanding in the balance sheet of the Assessee as on 31st March, 2013. According to the PC ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cise to be undertaken in the facts and circumstances of the case. 8. The Court having examined the said decision is of the view that in the facts and circumstances of the present case, the exercise of sending the matter back to the AO for a fresh assessment pursuant to the impugned order of the PCIT under Section 263 of the Act is not warranted. The Revenue has not been able to persuade t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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