Manjula Finance Ltd Vs ITO

Last updated: 29 December 2020

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This Income Tax Appellate Tribunal case involves Manjula Finance Ltd appealing against an Income Tax Officer's order. The primary dispute concerns the addition of over ₹219 crore as business income arising from the transfer of shares in O.P. Jindal Group companies. Manjula Finance Ltd argues that the CIT(A) erred in confirming this addition and also claims their appeal was dismissed without a proper hearing, violating natural justice principles.

Court :
ITAT New Delhi

Brief :
This is an appeal filed by Manjula Finance Ltd (the assessee/appellant) against the order of the Commissioner Of Income Tax (Appeals) – 15, New Delhi ( ld CIT(A)) dated 29.12.2017 for the Assessment Year 2014-15wherein he dismissed appeal filed by the assessee against the order of The Income Tax Officer, Ward – 16 (2), New Delhi (the learned AO) passed u/s 143 (3) of The Income Tax Act (The Act) on 30 December 2016 assessing thetotal income of the assessee at ₹ 2,196,633,589 against returned income of ₹ 1,104,580/–

Citation :
ITA No. 3727/Del/2018

(INCOME TAX APPELLATE TRIBUNAL
DELHI BENCH “E”: NEW DELHI
BEFORE SHRI H. S. SIDHU, JUDICIAL MEMBER
AND
SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER
(Through Video Conferencing)

ITA No. 3727/Del/2018
(Assessment Year: 2014-15)

Manjula Finance Ltd,
28, Najafgarh Road,
New Delhi
PAN: AAACM6990N
(Appellant)

Vs.

ITO,
Ward-16(2),
New Delhi
(Respondent)

Assessee by : Shri V. K. Bindal, CA
Ms. Sweety Kothari, CA
Revenue by: Shri Ajay Kumar, Sr. DR
Date of Hearing 19/11/2020
Date of pronouncement 18th/12/2020

O R D E R

PER PRASHANT MAHARISHI, A. M.

1. This is an appeal filed by Manjula Finance Ltd (the assessee/appellant) against the order of the Commissioner Of Income Tax (Appeals) – 15, New Delhi ( ld CIT(A)) dated 29.12.2017 for the Assessment Year 2014-15wherein he dismissed appeal filed by the assessee against the order of The Income Tax Officer, Ward – 16 (2), New Delhi (the learned AO) passed u/s 143 (3) of The Income Tax Act (The Act) on 30 December 2016 assessing thetotal income of the assessee at ₹ 2,196,633,589 against returned income of ₹ 1,104,580/–.

2. The assessee has raised the following grounds of appeal:-

“1. That the Commissioner of Income-tax (Appeals) [in short “CIT(A)”] erred on facts and in law in confirming the addition of Rs. 219,55,29,009/- made by the assessing officer, being the alleged business income arising on transfer of shares held in companies of O.P. Jindal Group.

2. That the CIT(A) erred in dismissing the appeal of the appellant, without affording adequate opportunity of being heard, in gross violation of principles of natural justice.

To know more in details find the attachmen tfile

FAQ :

The main issue was the addition of ₹219,55,29,009/- as business income by the Assessing Officer, which Manjula Finance Ltd alleged arose from the transfer of shares in O.P. Jindal Group companies.

The assessee returned an income of ₹1,104,580/-, while the Assessing Officer assessed the total income at ₹2,196,633,589/-.

The Commissioner of Income-tax (Appeals) [CIT(A)] confirmed the addition of ₹219,55,29,009/- made by the Assessing Officer.

Manjula Finance Ltd's second ground of appeal was that the CIT(A) dismissed their appeal without providing an adequate opportunity to be heard, which they claim is a violation of natural justice.

The assessment year for this appeal is 2014-15.