34. Granda Investments & Finance Pvt. Ltd. (formerly Granda Energy Systems Pvt. Ltd.) vs. DCIT
TS-693-ITAT-2022 (Mum.) A.Y.: 2011-12
Date of order: 25th August, 2022 Sections: 251, 264
Additional grounds filed by the assessee before the CIT(A) need to be adjudicated by him even though such grounds have been rejected by the PCIT earlier in revisionary proceedings.
FACTSDuring the previous year relevant to the assessment year under consideration, the assessee, a private limited company engaged in the business of facilitating foreign consultancy and business, earned income by way of interest and capital gains.
The assessee, along with three individuals, were promoters of WMI Cranes Ltd. and amongst the four of them (promoters) held the entire paid-up capital of WMI Cranes Ltd. The assessee held 123,800 equity shares of WMI Cranes Ltd. constituting 12.38 per cent of its total equity share capital. Pursuant to a Share Purchase and Subscription Agreement dated 11th October, 2010 entered into by the assessee and three individuals with M/s Konecranes & Finance Corporation, the promoters agreed to sell 48.25 per cent of the total paid-up and issued capital of WMI Cranes Ltd. to Konecranes & Finance Corporation initially at Rs. 302,012.31 per share amounting to Rs. 155 crore. The assessee consented to sell 75,000 out of 123,800 shares held by it. M/s Konecranes also subscribed for additional 56,000 equity shares
