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10. PCIT – 4, Delhi Vs. M/S Ansal Phalak Infrastructure Pvt Ltd (Now Known As New Look Builders And Developers Pvt Ltd)
[ITA No. 770/2025, dated 19/08/2026, (Delhi) (HC)] [AY 2011-12 ]
[Arising from ITA No. 5658/Del/2015 Delhi Bench: ‘E’ dated 18.12.2024]
Section 68 – Cash Credit – Investment - Compulsory Convertible Debentures – details filed to prove genuineness of the transaction – Onus discharged by assessee.
The Assessing Officer (‘AO’) had made an addition of Rs. 55 crores under Section 68 of the Act against the assessee for Assessment Year (AY) 2011-12, alleging that investment made by two companies namely M/s New Dimension Holdings Ltd. of Mauritius and M/s Velford Ventures Ltd. of Cyprus, in the respondent-assessee company was unexplained.
The aforementioned two companies had made investment and subscribed to the assessee’s shares and Compulsory Convertible Debentures (hereinafter referred to as ‘CCDs’) to the tune of Rs. 55 crores, which raised a doubt in the AO’s mind. Since the amount involved an international transaction, he made a reference to the Transfer Pricing Officer (‘TPO’) while also making a reference to the Foreign Tax and Tax
