w w w . L a w y e r S e r v i c e s . i n



Max Ventures Investments Holdings Pvt. Ltd. (Formerly known as Dynavest India Pvt. Ltd.) v/s Income Tax Officer & Another


Company & Directors' Information:- A V S R HOLDINGS PRIVATE LIMITED [Active] CIN = U67120TG2005PTC045117

Company & Directors' Information:- MAX INDIA LIMITED [Active] CIN = L85100PB2015PLC039155

Company & Directors' Information:- MAX INDIA LIMITED [Active] CIN = U85100PB2015PLC039155

Company & Directors' Information:- MAX CORPORATION LIMITED [Amalgamated] CIN = U24231PB1996PLC018766

Company & Directors' Information:- S R HOLDINGS LIMITED [Active] CIN = U65993TN1988PLC083659

Company & Directors' Information:- S R HOLDINGS PRIVATE LIMITED [Active] CIN = U65993TN1988PTC083659

Company & Directors' Information:- A M R INVESTMENTS PRIVATE LIMITED [Under Liquidation] CIN = U65190MH2007PTC171972

Company & Directors' Information:- P V T VENTURES PRIVATE LIMITED [Active] CIN = U74900DL2015PTC288507

Company & Directors' Information:- A B HOLDINGS PRIVATE LIMITED [Active] CIN = U70102KA2006PTC040894

Company & Directors' Information:- K F INVESTMENTS PRIVATE LIMITED [Active] CIN = U74990KA2011PTC059232

Company & Directors' Information:- K S R (J AND K) INVESTMENTS PRIVATE LIMITED [Amalgamated] CIN = U67120JK1991PTC001234

Company & Directors' Information:- L P INVESTMENTS LIMITED [Active] CIN = U65921PB1974PLC003526

Company & Directors' Information:- S K A HOLDINGS LIMITED [Active] CIN = U65993DL1981PLC012592

Company & Directors' Information:- S K A HOLDINGS LIMITED [Active] CIN = L65993DL1981PLC012592

Company & Directors' Information:- G J HOLDINGS PRIVATE LIMITED [Active] CIN = U51100DL2004PTC126687

Company & Directors' Information:- G J HOLDINGS PRIVATE LIMITED [Active] CIN = U65993DL2004PTC126687

Company & Directors' Information:- P P HOLDINGS LTD [Active] CIN = U65993PN1981PLC025916

Company & Directors' Information:- M H M G INVESTMENTS LIMITED [Under Process of Striking Off] CIN = U17232RJ1988PLC057599

Company & Directors' Information:- M H M G INVESTMENTS LIMITED [Active] CIN = U17232RJ1988PLC049708

Company & Directors' Information:- M H M G INVESTMENTS LIMITED [Active] CIN = U17232WB1988PLC044148

Company & Directors' Information:- G S D HOLDINGS PVT LTD [Strike Off] CIN = U70109WB1990PTC048518

Company & Directors' Information:- VENTURES INDIA CORPORATION PRIVATE LIMITED [Strike Off] CIN = U45202MH2008PTC177464

Company & Directors' Information:- S T HOLDINGS PRIVATE LIMITED [Active] CIN = U67120MH1979PTC021588

Company & Directors' Information:- Q VENTURES PRIVATE LIMITED [Active] CIN = U72200TG2012PTC078334

Company & Directors' Information:- M C HOLDINGS PRIVATE LIMITED [Active] CIN = U67190DL2009PTC190957

Company & Directors' Information:- J S K HOLDINGS PVT LTD [Active] CIN = U67120WB1994PTC065660

Company & Directors' Information:- S B M INVESTMENTS PRIVATE LIMITED [Active] CIN = U67120WB1996PTC117347

Company & Directors' Information:- P R HOLDINGS LIMITED [Active] CIN = L27310AS1983PLC007154

Company & Directors' Information:- P R HOLDINGS LIMITED [Active] CIN = L27310DL1983PLC314402

Company & Directors' Information:- G R A HOLDINGS PVT LTD [Active] CIN = U70101WB1992PTC055865

Company & Directors' Information:- B S S HOLDINGS PVT LTD [Active] CIN = U67120WB1992PTC056874

Company & Directors' Information:- H M HOLDINGS PRIVATE LIMITED [Active] CIN = U65993ML2005PTC007956

Company & Directors' Information:- D. D. VENTURES LIMITED [Active] CIN = L50102DL1984PLC017834

Company & Directors' Information:- N P S INVESTMENTS PRIVATE LIMITED [Active] CIN = U67120MP2005PTC017921

Company & Directors' Information:- S M H HOLDINGS PRIVATE LIMITED [Active] CIN = U65993TG2006PTC049309

Company & Directors' Information:- V B INVESTMENTS PRIVATE LIMITED [Active] CIN = U17100GJ1983PTC005999

Company & Directors' Information:- V B INVESTMENTS PRIVATE LIMITED [Active] CIN = U65910GJ1983PTC005999

Company & Directors' Information:- E & G VENTURES PRIVATE LIMITED [Active] CIN = U74999MH2010PTC210947

Company & Directors' Information:- M M HOLDINGS PVT LTD [Active] CIN = U70109WB1993PTC058147

Company & Directors' Information:- Z K INVESTMENTS PRIVATE LIMITED [Active] CIN = U67120MH1996PTC101783

Company & Directors' Information:- D J HOLDINGS PRIVATE LIMITED [Active] CIN = U67120MH1992PTC067448

Company & Directors' Information:- R S M P HOLDINGS PRIVATE LIMITED [Active] CIN = U67190MH1995PTC088443

Company & Directors' Information:- S & S INVESTMENTS LIMITED [Amalgamated] CIN = U65993TN1980PLC008148

Company & Directors' Information:- G. K. INVESTMENTS LTD [Active] CIN = U65993WB1974PLC029382

Company & Directors' Information:- A B T INVESTMENTS (INDIA) PRIVATE LIMITED [Active] CIN = U50101TZ2002PTC010085

Company & Directors' Information:- V A G HOLDINGS PRIVATE LIMITED [Active] CIN = U74899DL1994PTC057817

Company & Directors' Information:- H L A INVESTMENTS PRIVATE LIMITED [Active] CIN = U74899DL1994PTC057224

Company & Directors' Information:- K E HOLDINGS PRIVATE LIMITED [Active] CIN = U70101TN2013PTC089953

Company & Directors' Information:- H A B INVESTMENTS PRIVATE LIMITED [Active] CIN = U70109PB2008PTC031708

Company & Directors' Information:- P K S HOLDINGS & INVESTMENTS PRIVATE LIMITED [Active] CIN = U65993TN2008PTC068202

Company & Directors' Information:- R J HOLDINGS AND INVESTMENTS (INDIA) LIMITED [Strike Off] CIN = U65993KA2006PLC039849

Company & Directors' Information:- R & R VENTURES PRIVATE LIMITED [Active] CIN = U45200MP2007PTC019319

Company & Directors' Information:- T R INVESTMENTS PRIVATE LIMITED [Active] CIN = U67120WB1995PTC110837

Company & Directors' Information:- K D R INVESTMENTS LIMITED [Active] CIN = U65993DL1981PLC012418

Company & Directors' Information:- K U V INVESTMENTS PRIVATE LIMITED [Active] CIN = U65993WB1998PTC086947

Company & Directors' Information:- J S M INVESTMENTS LTD [Active] CIN = L67120WB1981PLC034027

Company & Directors' Information:- B L S INVESTMENTS PRIVATE LIMITED [Active] CIN = U67120WB1990PTC048679

Company & Directors' Information:- R J M INVESTMENTS LTD. [Active] CIN = L67120WB1988PLC044603

Company & Directors' Information:- O K INVESTMENTS PVT LTD [Active] CIN = U51109WB1985PTC039619

Company & Directors' Information:- P G K INVESTMENTS PRIVATE LIMITED [Active] CIN = U65910TG1999PTC032278

Company & Directors' Information:- G M B INVESTMENTS PVT LTD [Amalgamated] CIN = U67120WB1985PTC038868

Company & Directors' Information:- K C HOLDINGS PRIVATE LIMITED [Active] CIN = U65990MH1981PTC024688

Company & Directors' Information:- A TO Z HOLDINGS PRIVATE LIMITED [Active] CIN = U74899DL1987PTC028294

Company & Directors' Information:- V R HOLDINGS PRIVATE LIMITED [Active] CIN = U70102KA2009PTC051724

Company & Directors' Information:- M. B. VENTURES PRIVATE LIMITED [Active] CIN = U29248WB2010PTC148853

Company & Directors' Information:- J AND S INVESTMENTS PRIVATE LIMITED [Active] CIN = U65993MH1978PTC020524

Company & Directors' Information:- J C K INVESTMENTS PVT LTD. [Active] CIN = U65921WB1989PTC046002

Company & Directors' Information:- J B HOLDINGS LIMITED [Strike Off] CIN = U91110ML1995PLC004396

Company & Directors' Information:- A R K INVESTMENTS LTD [Strike Off] CIN = U65999WB1979PLC032141

Company & Directors' Information:- P N INVESTMENTS PRIVATE LIMITED [Active] CIN = U65993TN1980PTC008346

Company & Directors' Information:- S S INVESTMENTS PVT LTD [Active] CIN = U70109AP1984PTC005156

Company & Directors' Information:- P G T HOLDINGS LIMITED [Strike Off] CIN = U74899DL1994PLC057886

Company & Directors' Information:- T K INVESTMENTS PVT LTD [Active] CIN = U65921PB1983PTC005651

Company & Directors' Information:- MAX INDIA LTD [Amalgamated] CIN = U24232PB1982PLC004841

Company & Directors' Information:- S M HOLDINGS PRIVATE LIMITED [Active] CIN = U65990MH2011PTC225004

Company & Directors' Information:- M S R HOLDINGS LIMITED [Active] CIN = U85110KA1995PLC018599

Company & Directors' Information:- V N C A HOLDINGS PRIVATE LIMITED [Active] CIN = U74999TN2011PTC081684

Company & Directors' Information:- B. K. VENTURES PRIVATE LIMITED [Strike Off] CIN = U70109CT2007PTC020350

Company & Directors' Information:- MAX VENTURES PRIVATE LIMITED [Active] CIN = U55101DL2010PTC207677

Company & Directors' Information:- S C HOLDINGS PRIVATE LIMITED [Strike Off] CIN = U74899DL1986PTC025017

Company & Directors' Information:- T E W INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U65993DL1995PTC064216

Company & Directors' Information:- S G HOLDINGS PVT LTD [Active] CIN = U70109WB1986PTC040839

Company & Directors' Information:- K C A HOLDINGS PRIVATE LIMITED [Active] CIN = U74899DL1995PTC066204

Company & Directors' Information:- E I INVESTMENTS PVT LTD [Active] CIN = U65999WB1990PTC050386

Company & Directors' Information:- O P A INVESTMENTS PVT LTD [Active] CIN = U65993WB1990PTC048178

Company & Directors' Information:- S N J HOLDINGS PRIVATE LIMITED [Active] CIN = U67120DL1997PTC084488

Company & Directors' Information:- H P HOLDINGS LIMITED [Strike Off] CIN = U67120HP1997PLC019474

Company & Directors' Information:- K B INVESTMENTS PRIVATE LIMITED [Active] CIN = U67120MH1978PTC020520

Company & Directors' Information:- R N T INVESTMENTS LIMITED [Active] CIN = U51503WB1982PLC034975

Company & Directors' Information:- S D INVESTMENTS PRIVATE LIMITED [Active] CIN = U65910TG1988PTC008691

Company & Directors' Information:- Y R INVESTMENTS PVT LTD [Active] CIN = U65921PB1989PTC009356

Company & Directors' Information:- C N M P INVESTMENTS PRIVATE LIMITED [Active] CIN = U74899DL1983PTC016061

Company & Directors' Information:- S D INVESTMENTS PRIVATE LIMITED [Active] CIN = U65910AP1988PTC008691

Company & Directors' Information:- P S S INVESTMENTS PRIVATE LIMITED [Active] CIN = U65993TZ1948PTC000143

Company & Directors' Information:- THE INDIA COMPANY PRIVATE LIMITED [Active] CIN = U74999TN1919PTC000911

Company & Directors' Information:- K L N HOLDINGS PRIVATE LIMITED [Active] CIN = U65990TG1986PTC006344

Company & Directors' Information:- I R S INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U67120DL1987PTC027943

Company & Directors' Information:- H P M INVESTMENTS LIMITED [Strike Off] CIN = U67120DL1966PLC004591

Company & Directors' Information:- J & S VENTURES PRIVATE LIMITED [Active] CIN = U70101MN2014PTC008371

Company & Directors' Information:- M R HOLDINGS LIMITED [Active] CIN = U67120MH1978PLC020559

Company & Directors' Information:- J R VENTURES (INDIA) PRIVATE LIMITED [Active] CIN = U65990MH1983PTC029901

Company & Directors' Information:- J G VENTURES PVT LTD [Strike Off] CIN = U27101WB1978PTC031496

Company & Directors' Information:- J T HOLDINGS PRIVATE LIMITED [Active] CIN = U67120MH1979PTC021585

Company & Directors' Information:- B M D HOLDINGS PRIVATE LIMITED [Strike Off] CIN = U51909TN1995PTC031179

Company & Directors' Information:- E INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U65100PY2011PTC002552

Company & Directors' Information:- N V C INVESTMENTS PVT LTD [Active] CIN = U65993TG1982PTC003588

Company & Directors' Information:- A C K INVESTMENTS PVT LTD [Strike Off] CIN = U65910GJ1981PTC004097

Company & Directors' Information:- P B B INVESTMENTS PVT LTD [Strike Off] CIN = U67120CH1995PTC016092

Company & Directors' Information:- H K R HOLDINGS PRIVATE LIMITED [Active] CIN = U74899DL1982PTC013032

Company & Directors' Information:- R J HOLDINGS PRIVATE LIMITED [Active] CIN = U74899DL1982PTC013033

Company & Directors' Information:- A B O INVESTMENTS PRIVATE LIMITED [Active] CIN = U74899DL1995PTC071067

Company & Directors' Information:- K D R HOLDINGS PRIVATE LIMITED [Active] CIN = U74899DL1982PTC013034

Company & Directors' Information:- M & L INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U65993TN1982PTC009322

Company & Directors' Information:- P D R HOLDINGS PVT LTD [Amalgamated] CIN = U67120WB1996PTC077248

Company & Directors' Information:- M S INVESTMENTS PVT LTD [Active] CIN = U67120AS1995PTC004586

Company & Directors' Information:- W A HOLDINGS PRIVATE LIMITED [Active] CIN = U65993DL1997PTC084687

Company & Directors' Information:- M S V INVESTMENTS PVT LTD [Strike Off] CIN = U67120CH1993PTC013768

Company & Directors' Information:- W D HOLDINGS PRIVATE LIMITED [Active] CIN = U65993DL1997PTC084667

Company & Directors' Information:- B P INVESTMENTS LTD [Active] CIN = U65993WB1971PLC028138

Company & Directors' Information:- B P INVESTMENTS LTD [Active] CIN = L65993WB1971PLC028138

Company & Directors' Information:- J R R INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U65993TG1996PTC025639

Company & Directors' Information:- A K HOLDINGS PRIVATE LIMITED [Active] CIN = U74899UP1986PTC037306

Company & Directors' Information:- J R D HOLDINGS PRIVATE LIMITED [Active] CIN = U74899DL1994PTC059769

Company & Directors' Information:- C S HOLDINGS PRIVATE LIMITED [Strike Off] CIN = U85110KA1995PTC018441

Company & Directors' Information:- R A HOLDINGS LIMITED [Strike Off] CIN = U17119GJ1986PLC037333

Company & Directors' Information:- J M INVESTMENTS PRIVATE LIMITED [Active] CIN = U67120DL2000PTC104999

Company & Directors' Information:- W. M. F. HOLDINGS PRIVATE LIMITED [Active] CIN = U70101CT2011PTC022482

Company & Directors' Information:- A V HOLDINGS PVT LTD [Active] CIN = U51109WB1992PTC054035

Company & Directors' Information:- A P M INVESTMENTS LIMITED [Amalgamated] CIN = U65993TZ1980PLC003978

Company & Directors' Information:- K B R HOLDINGS PRIVATE LIMITED [Active] CIN = U67120TG1998PTC030518

Company & Directors' Information:- E K HOLDINGS PRIVATE LIMITED [Active] CIN = U74899DL1990PTC040323

Company & Directors' Information:- N R HOLDINGS PVT LTD [Strike Off] CIN = U67120WB1993PTC060077

Company & Directors' Information:- B P A HOLDINGS PVT LTD [Strike Off] CIN = U74990DL1982PTC013326

Company & Directors' Information:- J C INVESTMENTS PRIVATE LIMITED [Active] CIN = U67120KA1979PTC003632

Company & Directors' Information:- V V HOLDINGS PRIVATE LIMITED [Active] CIN = U74899DL1994PTC060480

Company & Directors' Information:- D D B HOLDINGS PVT LTD [Strike Off] CIN = U67120WB1992PTC055592

Company & Directors' Information:- C P VENTURES PRIVATE LIMITED [Strike Off] CIN = U55101OR2012PTC016058

Company & Directors' Information:- M D HOLDINGS PRIVATE LIMITED [Active] CIN = U67120DL2001PTC111221

Company & Directors' Information:- P M P INVESTMENTS LTD [Strike Off] CIN = U65993TN1982PLC009601

Company & Directors' Information:- V H A HOLDINGS PRIVATE LIMITED [Converted to LLP and Dissolved] CIN = U65993DL2003PTC120147

Company & Directors' Information:- K E F HOLDINGS LTD [Amalgamated] CIN = U67120WB1988PLC045280

Company & Directors' Information:- J D S VENTURES INDIA LIMITED [Active] CIN = U24200MH2000PLC125107

Company & Directors' Information:- Y AND Z INVESTMENTS PRIVATE LIMITED [Under Process of Striking Off] CIN = U67190TG2006PTC050531

Company & Directors' Information:- K B VENTURES PRIVATE LIMITED [Active] CIN = U15311ML2005PTC007854

Company & Directors' Information:- A P HOLDINGS PVT LTD [Active] CIN = U65993PN1981PTC025915

Company & Directors' Information:- N. R. HOLDINGS PRIVATE LIMITED [Active] CIN = U67120MH1993PTC140612

Company & Directors' Information:- M B HOLDINGS LTD. [Not available for efiling] CIN = U70109WB1986PLC041226

Company & Directors' Information:- U V VENTURES PRIVATE LIMITED [Active] CIN = U51909WB2012PTC181717

Company & Directors' Information:- K. G. VENTURES PRIVATE LIMITED [Active] CIN = U74220DL2011PTC212564

Company & Directors' Information:- J S R HOLDINGS PRIVATE LIMITED [Active] CIN = U45200KA2006PTC040195

Company & Directors' Information:- A V INVESTMENTS PVT LTD [Strike Off] CIN = U65910GJ1981PTC004714

Company & Directors' Information:- K M HOLDINGS PRIVATE LIMITED [Active] CIN = U74899DL1995PTC064343

Company & Directors' Information:- B R L VENTURES PRIVATE LIMITED [Active] CIN = U45205KA2012PTC067184

Company & Directors' Information:- A P S INVESTMENTS PVT LTD [Active] CIN = U67120CH1989PTC008950

Company & Directors' Information:- R K S INVESTMENTS PRIVATE LIMITED [Active] CIN = U65993KA1980PTC003779

Company & Directors' Information:- R L VENTURES PRIVATE LIMITED [Active] CIN = U45202CT2006PTC020117

Company & Directors' Information:- A S H HOLDINGS PRIVATE LIMITED [Active] CIN = U74899DL2004PTC125403

Company & Directors' Information:- D P INVESTMENTS PRIVATE LIMITED [Active] CIN = U65990MH1972PTC016045

Company & Directors' Information:- B P A INVESTMENTS PVT LTD [Strike Off] CIN = U65191WB1995PTC075813

Company & Directors' Information:- G R INVESTMENTS (INDIA) PRIVATE LIMITED [Strike Off] CIN = U74899DL1981PTC012305

Company & Directors' Information:- A K INVESTMENTS LIMITED [Strike Off] CIN = U70101WB1979PLC032240

Company & Directors' Information:- C M HOLDINGS PVT LTD [Strike Off] CIN = U45203WB1986PTC041627

Company & Directors' Information:- E I T INVESTMENTS P. LTD [Strike Off] CIN = U65991TN1991PTC020531

Company & Directors' Information:- M H HOLDINGS PRIVATE LIMITED [Active] CIN = U74899DL1995PTC067392

Company & Directors' Information:- S. B. VENTURES PRIVATE LIMITED [Active] CIN = U15530OR2009PTC011294

Company & Directors' Information:- I K HOLDINGS LTD [Strike Off] CIN = U70101WB1951PLC019703

Company & Directors' Information:- C & R HOLDINGS PVT. LTD. [Active] CIN = U65929WB1991PTC051376

Company & Directors' Information:- V P R S VENTURES PRIVATE LIMITED [Active] CIN = U45309TN2020PTC139603

Company & Directors' Information:- I D S INVESTMENTS PRIVATE LIMITED [Active] CIN = U00000DL1985PTC020287

Company & Directors' Information:- D & O VENTURES PRIVATE LIMITED [Active] CIN = U51900PB2014PTC038533

Company & Directors' Information:- B P VENTURES PRIVATE LIMITED [Active] CIN = U74140TN2002PTC049090

Company & Directors' Information:- R P VENTURES (INDIA) PRIVATE LIMITED [Strike Off] CIN = U51909TN2004PTC052895

Company & Directors' Information:- N. F. VENTURES PRIVATE LIMITED [Active] CIN = U74999UP2016PTC084631

Company & Directors' Information:- R T A VENTURES PRIVATE LIMITED [Strike Off] CIN = U74999TN2012PTC085909

Company & Directors' Information:- J J HOLDINGS LTD [Amalgamated] CIN = U65993WB1980PLC032736

Company & Directors' Information:- K G HOLDINGS PVT LTD [Active] CIN = U65929WB1987PTC042868

Company & Directors' Information:- B & T HOLDINGS PRIVATE LIMITED [Active] CIN = U74920DL2007PTC171796

Company & Directors' Information:- B R M VENTURES PRIVATE LIMITED [Active] CIN = U51909UP2021PTC152492

Company & Directors' Information:- H D HOLDINGS PVT LTD [Amalgamated] CIN = U51109WB1991PTC051415

Company & Directors' Information:- N AND N HOLDINGS PRIVATE LIMITED [Active] CIN = U74899DL1990PTC040846

Company & Directors' Information:- A & A INVESTMENTS INDIA PRIVATE LIMITED [Under Process of Striking Off] CIN = U74999TN2008PTC068491

Company & Directors' Information:- H R INVESTMENTS PVT LTD [Strike Off] CIN = U67120CH1992PTC012458

Company & Directors' Information:- S AND N VENTURES LIMITED [Active] CIN = U24117MH2007PLC166639

Company & Directors' Information:- INDIA CORPORATION PRIVATE LIMITED [Active] CIN = U65990MH1941PTC003461

Company & Directors' Information:- A L B INVESTMENTS PVT LTD [Strike Off] CIN = U67120DL1973PTC006943

Company & Directors' Information:- M P HOLDINGS PRIVATE LIMITED [Under Process of Striking Off] CIN = U67120DL1997PTC088350

Company & Directors' Information:- L R K INVESTMENTS PRIVATE LIMITED [Active] CIN = U74899DL1981PTC012892

Company & Directors' Information:- K. B. INVESTMENTS PRIVATE LIMITED [Amalgamated] CIN = U67120OR1983PTC001163

Company & Directors' Information:- V S B INVESTMENTS PVT LTD [Active] CIN = U67120MH1995PTC164589

Company & Directors' Information:- R & J VENTURES PRIVATE LIMITED [Strike Off] CIN = U45200OR2013PTC017450

Company & Directors' Information:- B P HOLDINGS PRIVATE LIMITED [Active] CIN = U74899DL1989PTC038274

Company & Directors' Information:- P G MAX PRIVATE LIMITED [Strike Off] CIN = U22219KL2012PTC031856

Company & Directors' Information:- K P R HOLDINGS PRIVATE LIMITED [Active] CIN = U74900TZ2011PTC017467

Company & Directors' Information:- S K VENTURES PRIVATE LIMITED [Strike Off] CIN = U45201OR2010PTC012858

Company & Directors' Information:- A & N VENTURES PRIVATE LIMITED [Active] CIN = U70100MH1982PTC027985

Company & Directors' Information:- U AND V HOLDINGS PRIVATE LIMITED [Strike Off] CIN = U65999TN2005PTC057659

Company & Directors' Information:- H M VENTURES PRIVATE LIMITED [Active] CIN = U67120TZ2013PTC019237

Company & Directors' Information:- C D M VENTURES PRIVATE LIMITED [Strike Off] CIN = U74120UP2015PTC074278

Company & Directors' Information:- C F C INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U65993WB1997PTC085444

Company & Directors' Information:- B AND B HOLDINGS PRIVATE LIMITED [Active] CIN = U70101AS1999PTC005674

Company & Directors' Information:- H A INVESTMENTS PRIVATE LIMITED [Active] CIN = U67120DL1996PTC076439

Company & Directors' Information:- M. G. HOLDINGS PRIVATE LIMITED [Strike Off] CIN = U67120DL2010PTC198226

Company & Directors' Information:- D G HOLDINGS PRIVATE LIMITED [Active] CIN = U65110DL1998PTC094466

Company & Directors' Information:- I R HOLDINGS PRIVATE LIMITED [Strike Off] CIN = U74120DL2008PTC185743

Company & Directors' Information:- S I HOLDINGS PRIVATE LIMITED [Strike Off] CIN = U74120DL2008PTC186043

Company & Directors' Information:- C. I. INVESTMENTS PRIVATE LIMITED [Active] CIN = U70101MP2007PTC019874

Company & Directors' Information:- C J G HOLDINGS INDIA PRIVATE LIMITED [Active] CIN = U70101KL2010PTC038559

Company & Directors' Information:- G F C INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U65993WB1997PTC085433

Company & Directors' Information:- S G P INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U65990MH1999PTC122024

Company & Directors' Information:- U P L HOLDINGS PVT LTD [Strike Off] CIN = U67120OR1990PTC002414

Company & Directors' Information:- N N HOLDINGS PVT LTD [Strike Off] CIN = U65999WB1990PTC048493

Company & Directors' Information:- O M K HOLDINGS PVT LTD [Strike Off] CIN = U67120WB1995PTC072914

Company & Directors' Information:- M K HOLDINGS (INDIA) PRIVATE LIMITED [Strike Off] CIN = U65993TN1996PTC036985

Company & Directors' Information:- D D INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U74899DL1990PTC042362

Company & Directors' Information:- K I HOLDINGS PVT LTD [Strike Off] CIN = U67120MH1981PTC024069

Company & Directors' Information:- MAX INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U99999MH1939PTC003002

Company & Directors' Information:- D R HOLDINGS PRIVATE LIMITED [Active] CIN = U65993DL1982PTC013031

Company & Directors' Information:- R R HOLDINGS PRIVATE LIMITED [Active] CIN = U74899DL1983PTC017127

Company & Directors' Information:- G J HOLDINGS PVT LTD [Not available for efiling] CIN = U65993PB1985PTC006327

Company & Directors' Information:- MAX I. LIMITED [Active] CIN = U74999PB2016PLC045450

Company & Directors' Information:- R G INVESTMENTS PRIVATE LIMITED [Active] CIN = U67120MH1979PTC021933

Company & Directors' Information:- M G L HOLDINGS PRIVATE LIMITED [Active] CIN = U65993TN1994PTC029354

Company & Directors' Information:- G T V INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U65993TZ1989PTC002543

Company & Directors' Information:- T-VENTURES PRIVATE LIMITED [Active] CIN = U70200TG2016PTC110607

Company & Directors' Information:- P R INVESTMENTS PVT LTD [Strike Off] CIN = U67190WB1995PTC069706

Company & Directors' Information:- D & A VENTURES (INDIA) PRIVATE LIMITED [Active] CIN = U14200KA2015PTC081349

Company & Directors' Information:- K V R HOLDINGS PRIVATE LIMITED [Active] CIN = U65191KA2012PTC063353

Company & Directors' Information:- M C G INVESTMENTS PRIVATE LIMITED [Active] CIN = U45400GJ2000PTC038748

Company & Directors' Information:- N N D INVESTMENTS PRIVATE LIMITED [Amalgamated] CIN = U65993GJ1981PTC004702

Company & Directors' Information:- R N M HOLDINGS P LTD. [Active] CIN = U65921WB1990PTC050174

Company & Directors' Information:- C L V INVESTMENTS PVT LTD [Strike Off] CIN = U45205WB1980PTC032572

Company & Directors' Information:- M D HOLDINGS PVT LTD [Strike Off] CIN = U67120CH1983PTC005399

Company & Directors' Information:- R V HOLDINGS PRIVATE LIMITED [Strike Off] CIN = U74899DL1989PTC036577

Company & Directors' Information:- B J HOLDINGS PRIVATE LIMITED [Active] CIN = U67120MH1982PTC028820

Company & Directors' Information:- P N P INVESTMENTS P LTD [Strike Off] CIN = U65993KL1985PTC004193

Company & Directors' Information:- R S HOLDINGS PVT LTD [Active] CIN = U70109WB1986PTC040255

Company & Directors' Information:- V A INVESTMENTS P LTD. [Active] CIN = U65991TN1990PTC019915

Company & Directors' Information:- A D HOLDINGS PVT LTD [Strike Off] CIN = U65993WB1976PTC030525

Company & Directors' Information:- S P HOLDINGS PVT LTD [Strike Off] CIN = U65993WB1988PTC044540

Company & Directors' Information:- R A HOLDINGS PVT LTD [Strike Off] CIN = U70200WB1986PTC040138

Company & Directors' Information:- L J INVESTMENTS PVT LTD [Strike Off] CIN = U51909WB1983PTC035635

Company & Directors' Information:- A HOLDINGS PVT LTD [Strike Off] CIN = U70101WB1962PTC025617

Company & Directors' Information:- K R S HOLDINGS & INVESTMENTS PVT LTD [Strike Off] CIN = U67120WB1991PTC053572

Company & Directors' Information:- K T R HOLDINGS PVT LTD [Strike Off] CIN = U67120WB1993PTC059078

Company & Directors' Information:- B I HOLDINGS PVT LTD [Strike Off] CIN = U65922WB1988PTC043690

Company & Directors' Information:- P A INVESTMENTS LTD [Strike Off] CIN = U65993WB1981PLC033620

Company & Directors' Information:- K P INVESTMENTS PVT LTD [Amalgamated] CIN = U65993MH1988PTC048956

Company & Directors' Information:- E TO E HOLDINGS INDIA PRIVATE LIMITED [Active] CIN = U65999KA2008PTC047780

Company & Directors' Information:- K S INVESTMENTS PRIVATE LIMITED [Converted to LLP] CIN = U50100TN1984PTC010634

Company & Directors' Information:- A. K. VENTURES PRIVATE LIMITED [Under Process of Striking Off] CIN = U51109MH2008PTC178815

Company & Directors' Information:- K S INVESTMENTS PRIVATE LIMITED [Active] CIN = U65993TN1984PTC010634

Company & Directors' Information:- S & P VENTURES PRIVATE LIMITED [Under Process of Striking Off] CIN = U67120TN2004PTC052758

Company & Directors' Information:- M A HOLDINGS PRIVATE LIMITED [Active] CIN = U26106UP2003PTC027990

Company & Directors' Information:- S C F INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U74899DL1991PTC044238

Company & Directors' Information:- G L HOLDINGS PRIVATE LIMITED [Dormant under section 455] CIN = U74996KA2008PTC044867

Company & Directors' Information:- J V VENTURES PRIVATE LIMITED [Strike Off] CIN = U63040KL2006PTC019157

Company & Directors' Information:- M P INVESTMENTS PVT LTD [Strike Off] CIN = U64991MP1974PTC001292

Company & Directors' Information:- S M B INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U65921UP1994PTC016536

Company & Directors' Information:- R J INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U65993MH1988PTC049997

Company & Directors' Information:- A AND M HOLDINGS PRIVATE LIMITED [Strike Off] CIN = U67190TG1995PTC021464

Company & Directors' Information:- K V S HOLDINGS PVT LTD [Strike Off] CIN = U65993WB1993PTC060850

Company & Directors' Information:- V K HOLDINGS PRIVATE LTD [Strike Off] CIN = U27924DL1987PTC027924

Company & Directors' Information:- U A INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U63090DL1987PTC030052

Company & Directors' Information:- M V K INVESTMENTS PVT LTD [Strike Off] CIN = U99999MH1980PTC022879

Company & Directors' Information:- R J INVESTMENTS PRIVATE LIMITED [Not available for efiling] CIN = U99999MH1988PTC049997

Company & Directors' Information:- L B INVESTMENTS PVT LTD [Strike Off] CIN = U67120MH1981PTC024692

Company & Directors' Information:- Q AND A HOLDINGS PRIVATE LIMITED [Strike Off] CIN = U67120MH2000PTC127319

Company & Directors' Information:- K N S INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U65993TN1984PTC011072

Company & Directors' Information:- K A R INVESTMENTS PVT LTD [Strike Off] CIN = U65993TG1985PTC005344

Company & Directors' Information:- S K HOLDINGS PVT. LTD [Strike Off] CIN = U99999UP1988PTC010231

Company & Directors' Information:- M M VENTURES PRIVATE LIMITED [Strike Off] CIN = U45100TG2005PTC048357

Company & Directors' Information:- R R J INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U65993KL2000PTC014084

Company & Directors' Information:- S K S INVESTMENTS PVT LTD [Strike Off] CIN = U65910GJ1981PTC004730

Company & Directors' Information:- M G INVESTMENTS PVT LTD [Active] CIN = U70109WB1949PTC017761

Company & Directors' Information:- V A HOLDINGS PVT LTD [Strike Off] CIN = U67120KL1986PTC004442

Company & Directors' Information:- B L INVESTMENTS PVT LTD [Strike Off] CIN = U65990GJ1982PTC005349

Company & Directors' Information:- H S INVESTMENTS PRIVATE LIMITED [Active] CIN = U74899DL1979PTC009573

Company & Directors' Information:- AND INVESTMENTS PRIVATE LTD [Strike Off] CIN = U65923DL1981PTC012382

Company & Directors' Information:- T. P. K. INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U67120DL1986PTC023028

Company & Directors' Information:- S R HOLDINGS PRIVATE LIMITED [Strike Off] CIN = U65993TN1980PTC008388

Company & Directors' Information:- M T R HOLDINGS PRIVATE LIMITED [Active] CIN = U67110KA2007PTC042600

Company & Directors' Information:- T. T. INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U67120UP1994PTC017279

Company & Directors' Information:- H T S INVESTMENTS PVT LTD [Strike Off] CIN = U65921PB1986PTC006934

Company & Directors' Information:- F C P INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U99999MH1981PTC023913

Company & Directors' Information:- R D INVESTMENTS PVT LTD [Not available for efiling] CIN = U51909PB1985PTC006323

Company & Directors' Information:- J & K VENTURES INDIA PRIVATE LIMITED [Strike Off] CIN = U80903OR2013PTC016477

Company & Directors' Information:- D H VENTURES PRIVATE LIMITED [Active] CIN = U70109PB2013PTC037223

Company & Directors' Information:- D S VENTURES PRIVATE LIMITED [Active] CIN = U70109PB2013PTC037432

Company & Directors' Information:- B A Y VENTURES PRIVATE LIMITED [Strike Off] CIN = U70109PB2014PTC038443

Company & Directors' Information:- D P VENTURES PRIVATE LIMITED [Active] CIN = U45209PB2011PTC035612

Company & Directors' Information:- B Y INVESTMENTS PVT LTD [Active] CIN = U65990MH1980PTC022770

Company & Directors' Information:- C S A HOLDINGS PRIVATE LIMITED [Strike Off] CIN = U65990MH1995PTC092555

Company & Directors' Information:- A G S A VENTURES PRIVATE LIMITED [Strike Off] CIN = U51101MH2012PTC230980

Company & Directors' Information:- M R VENTURES PRIVATE LIMITED [Strike Off] CIN = U70102MH2012PTC230577

Company & Directors' Information:- K N Z HOLDINGS PRIVATE LIMITED [Strike Off] CIN = U67120MH1998PTC117331

Company & Directors' Information:- S H HOLDINGS PRIVATE LIMITED [Active] CIN = U67120MH2001PTC131041

Company & Directors' Information:- A T 9 VENTURES PRIVATE LIMITED [Active] CIN = U74999MH2013PTC240212

Company & Directors' Information:- J INVESTMENTS PRIVATE LIMITED [Active] CIN = U65993TN1979PTC007776

Company & Directors' Information:- C B M INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U65993TZ1984PTC001467

Company & Directors' Information:- D L HOLDINGS PRIVATE LIMITED [Strike Off] CIN = U67100TN2012PTC083929

Company & Directors' Information:- P C T HOLDINGS PRIVATE LIMITED [Active] CIN = U70101TZ2004PTC010971

Company & Directors' Information:- T & D VENTURES PRIVATE LIMITED [Active] CIN = U93000TN2016PTC104302

Company & Directors' Information:- M J P HOLDINGS PRIVATE LIMITED [Active] CIN = U74900TG2015PTC098835

Company & Directors' Information:- 4 R INVESTMENTS PRIVATE LIMITED [Active] CIN = U65922TG2010PTC071820

Company & Directors' Information:- J A VENTURES PRIVATE LIMITED [Under Process of Striking Off] CIN = U52100UP2014PTC066450

Company & Directors' Information:- G & T VENTURES PRIVATE LIMITED [Strike Off] CIN = U74999TN2012PTC088485

Company & Directors' Information:- R & D VENTURES PRIVATE LIMITED [Active] CIN = U37100WB2014PTC199636

Company & Directors' Information:- P H HOLDINGS PVT LTD [Active] CIN = U67120WB1985PTC039369

Company & Directors' Information:- J D S HOLDINGS PRIVATE LIMITED [Active] CIN = U65993DL1993PTC053637

Company & Directors' Information:- M R S HOLDINGS PRIVATE LIMITED [Strike Off] CIN = U67120DL2001PTC113197

Company & Directors' Information:- A T INVESTMENTS PRIVATE LTD [Active] CIN = U74899DL1986PTC024983

Company & Directors' Information:- V AND V VENTURES PRIVATE LIMITED [Strike Off] CIN = U50100DL2014PTC274493

Company & Directors' Information:- L & H VENTURES PRIVATE LIMITED [Active] CIN = U74140DL2012PTC232700

Company & Directors' Information:- J S M S HOLDINGS PRIVATE LIMITED [Strike Off] CIN = U45201DL2002PTC117110

Company & Directors' Information:- V VENTURES PRIVATE LIMITED [Active] CIN = U70200AP2015PTC096366

Company & Directors' Information:- R M G HOLDINGS PVT LTD [Active] CIN = U67120MP1987PTC004209

Company & Directors' Information:- B R HOLDINGS PRIVATE LIMITED [Amalgamated] CIN = U74899HR1994PTC064054

Company & Directors' Information:- S K N J INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U74140KA2007PTC042764

Company & Directors' Information:- 4 L C VENTURES PRIVATE LIMITED [Active] CIN = U51909KA2015PTC084413

Company & Directors' Information:- P R S HOLDINGS PRIVATE LIMITED [Strike Off] CIN = U67120KA2010PTC052295

Company & Directors' Information:- R VENTURES PRIVATE LIMITED [Converted to LLP] CIN = U50200GJ2015PTC083598

Company & Directors' Information:- J B VENTURES PRIVATE LIMITED [Strike Off] CIN = U74900KL2013PTC033913

Company & Directors' Information:- J N VENTURES PRIVATE LIMITED [Active] CIN = U15543KL2013PTC033815

Company & Directors' Information:- INCOME INVESTMENTS PVT LTD [Active] CIN = U65910GJ1975PTC002779

Company & Directors' Information:- V P INVESTMENTS PVT LTD [Dormant under section 455] CIN = U65910GJ1981PTC004115

Company & Directors' Information:- A P INVESTMENTS PVT LTD [Dormant under section 455] CIN = U65910GJ1981PTC004116

Company & Directors' Information:- A J INVESTMENTS PVT LTD [Active] CIN = U65910GJ1981PTC004847

Company & Directors' Information:- K J A INVESTMENTS PRIVATE LIMITED [Amalgamated] CIN = U65910GJ1981PTC004849

Company & Directors' Information:- R N V INVESTMENTS PVT LTD [Strike Off] CIN = U65910GJ1982PTC005514

Company & Directors' Information:- D K INVESTMENTS PVT LTD [Strike Off] CIN = U65910GJ1982PTC005518

Company & Directors' Information:- A R D VENTURES PRIVATE LIMITED [Active] CIN = U74999MP2020PTC052221

Company & Directors' Information:- M AND D HOLDINGS PRIVATE LIMITED [Strike Off] CIN = U67120MH1981PTC025882

Company & Directors' Information:- MAX HOLDINGS PVT. LTD. [Strike Off] CIN = U65923RJ1995PTC009326

Company & Directors' Information:- P P G INVESTMENTS PRIVATE LIMITED [Under Process of Striking Off] CIN = U65993GJ1981PTC004631

Company & Directors' Information:- C AND M INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U65993RJ1995PTC010922

Company & Directors' Information:- V. V. INVESTMENTS PRIVATE LIMITED. [Strike Off] CIN = U65993JK1984PTC000665

Company & Directors' Information:- A T HOLDINGS PRIVATE LIMITED [Under Process of Striking Off] CIN = U74899DL1994PTC057216

Company & Directors' Information:- A R INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U99999MH1978PTC020588

Company & Directors' Information:- R. S. D. INVESTMENTS PVT LTD [Strike Off] CIN = U99999MH1982PTC028731

Company & Directors' Information:- D S B INVESTMENTS PVT. LTD [Strike Off] CIN = U65993RJ1994PTC008072

Company & Directors' Information:- J AND S HOLDINGS PVT LTD [Strike Off] CIN = U67120RJ1996PTC012114

Company & Directors' Information:- J R B B INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U67120TN1990PTC019840

Company & Directors' Information:- O P INVESTMENTS PVT. LTD. [Strike Off] CIN = U67120HR1995PTC032595

Company & Directors' Information:- S K V HOLDINGS PRIVATE LIMITED [Strike Off] CIN = U65993DL1981PTC012910

Company & Directors' Information:- S M K S HOLDINGS PVT LTD [Strike Off] CIN = U45400WB1990PTC048498

Company & Directors' Information:- U P K INVESTMENTS PVT LTD [Not available for efiling] CIN = U65993WB1974PTC029672

Company & Directors' Information:- B D K INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U99999MH1979PTC021782

Company & Directors' Information:- A M L INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U65910GJ1981PTC004180

Company & Directors' Information:- S J P HOLDINGS PRIVATE LIMITED [Strike Off] CIN = U99999GJ1981PTC004682

Company & Directors' Information:- S H P INVESTMENTS PRIVATE LIMITED [Strike Off] CIN = U65910GJ1981PTC004675

Company & Directors' Information:- R D INVESTMENTS PVT LTD [Strike Off] CIN = U65990MH1978PTC020590

Company & Directors' Information:- P P S INVESTMENTS COMPANY. [Strike Off] CIN = U31200GA1978ULL000325

    W.P. (C) No. 11572 of 2017 & CM No. 47153 of 2017

    Decided On, 27 March 2019

    At, High Court of Delhi

    By, THE HONOURABLE MR. JUSTICE S. RAVINDRA BHAT & THE HONOURABLE MR. JUSTICE PRATEEK JALAN

    For the Petitioner: Ajay Vohra, Sr. Advocate, Gaurav Jain, Aniket. D. Agrawal, Deepika Agarwal, Advocates. For the Respondents: Asheesh Jain, Sr. Standing Counsel, Sanjay Kumar, Jr. Standing Counsel, Dushyant Sarna, Advocate.



Judgment Text


S. Ravindra Bhat, J.

1. This petition under Article 226 of the Constitution of India, challenges a reassessment notice under Sections 147/148 of the Income Tax Act, 1961 (“the Act” hereafter) issued to the writ petitioner.

2. The petitioner (hereafter “assessee”) is a private limited company incorporated in India under the provisions of the Companies Act, 1956 is inter alia engaged in the business of rendering financial services. During F.Y.2009-10, the assessee received share application money of Rs. 87,00,00,000/- from its promoter/founder Sh. Analjit Singh towards fresh allotment of equity shares. On 25.09.2010, the assessee filed its return of income for the AY 2010-11 declaring a total income Rs. 37,746/. On 06.04.2011, as a part of the exercise of reorganization of the group and consolidation of shareholding, the right to receive allotment of shares against the said share application money of Rs. 87 crores, was transferred by Shri Analjit Singh to his family trust, i.e. Neeman Family Foundation through a gift. The assessee’s return for AY 2012-13 was selected for scrutiny, because a substantial amount was received against unallotted shares. On 16th February, 2015, the AO issued a questionnaire querying the assessee why share application money of Rs. 87 crores received should not be added to its income.

3. The assessee’s reply was that the share application money was received during the A.Y. 2012-13 and that it was holding 5% of paid up share capital of Max India Limited as promoter group entity. The allotment of equity shares by assessee to Neeman Family Foundation, would have resulted in change in ownership status of assessee from individual promoters to Trust. The said allotment of shares to trust would then have triggered the requirement of Public Offer/Announcement finder SEBI Takeover Code, 2011. The assessee also stated that trusts already sought an exemption from SEBI under the applicable provisions during the F.Y. 2014-15 for allotment of shares against pending share application money, which clarified that it would issue equity shares to Neeman Family Foundation, after obtaining necessary approvals from SEBI in accordance with statutory compliances. Therefore, the assessee stated that the addition of income under Section 68 of the Act was not justified. The assessing officer (AO) however, by an order dated 06.03.2015 added said outstanding amount of share application money to the declared income of the assessee as unexplained income in its hands, also holding that the benefit had been taken by the assessee till date and in future as shares were not allotted even after the expiry of 4 yeaRs. It was also held that the family trust did not get any benefit having regard to the purpose it was created which showed that it is just shifting tax burden on deemed income of trust by this route. The AO further held that the assessee had not taken any step to increase the authorized share capital to meet out the requirement of issue of shares as the present authorized share capital was of Rs. 20 lakhs against share application money of Rs. 87 crores, which was pending for allotment till the year 2015. Further, the assessee filed application to get exemption from SEBI in the year 2014-15 only after questionnaire/notice was issued by the AO. The assessee appealed to the Commissioner. The CIT(A)’s order dated 09.12.2016 deleted the aforesaid addition made by the ld. AO, inter alia, on the ground that since the aforesaid share application money was not received in the relevant AY i.e. 2012-13, the provisions of Section 68 of the Act were not applicable in that year.

4. On 28th March, 2017, the AO issued a notice of reassessment, under Section 148 of the Income Tax. The relevant extracts of the “reasons to believe” issued to the assessee, in support of the notice are reproduced below:

“3.1 The assessee during the course of stay proceedings for recovery of outstanding demand raised for A.Y. 2012-13 filed certain documents as piece of evidence that share application money has been received from Sh. Analjit Singh during F.Y. 2009-10. In support of its claim the assessee filed copies of extracts of the minutes of the meeting of the Board of Directors of M/s Max Venture Investment Holdings Pvt. Ltd.

It was quite surprising that the meeting of board of director was held on 06.01.2010 and 20.04.2010 under the name of M/s Max Venture Investment Holdings Pvt Ltd. and Sh. Sanjiv Malik has signed the Board meeting. While on 06.01,2010 and 20.04.2010 neither M/s Max Venture Investment Holdings Pvt. Ltd. was in existence nor Sh. Sanjeev Malik was the director of that company. The name of company was M/s Dynavast India Pvt. Ltd. and this name was subsequently changed to Max Venture Investment Holdings Pvt. Ltd. Sh. Sanjiv Malik was appointed as director of the company on 28.12.2013. Which mean that the assessee has submitted the document which was created after the happening of events thus it does not support its theory of share application money provided by Sh. Analjit Singh.

3.2 It is observed that the authorized share capital of the assessee company was Rs. 20 lakh as on 31.03.2009 and issued capital was Rs 1,00,000/-. The balance capital to be issued was Rs. 19 lakh. The assessee company is receiving Rs. 87 crore as Share application money against the pending share capital of Rs. 19 lakh meaning by that assessee is getting a premium of Rs. 4568947/- on the face value of share of Rs. 10 i.e. 457 times the face value. While the financials of the assessee company does not support such high valuation.

Summary of evidences relating to the assessee

4.1 The claim of the assessee was that an amount of Rs 87 Crore was received from Sh. Analjit Singh in F.Y. 2009-10 while documentary evidences does not support the claim of the assessee for the reasons discussed below:-

i. The submission of the assessee that it has received share application money was not backed by any evidence as these facts were never intimated to the department during the course of assessment proceedings for A.Y. 2012-13. The assessee merely relied upon its submission that it has riot received any Share application money during the relevant year i.e. 2012-13.

ii. The assessee failed to submit any evidence that Sh. Analjit Singh has provided any share application money during 2009-10, 2010-11 & 2011-12. Contrary to this the evidences submitted, by the assessee to support its claim of Share application money provided by Sh. Analjit Singh does not stand the scrutiny of the law;

iii. During the course of recovery proceeding, it has been observed that the assessee has submitted documents in support of its claim that money has been provided by Sh. Analjit Singh in 2009. But these evidences cannot be relied upon for the following reasons:-

(a) The assessee submitted the copies of extract of minutes of meeting of Board of Directors of M/s Max Venture Investment Holdings Pvt. Ltd. From examination of the copies of extracts of the minutes of the meeting, of the Board of Directors It. was observed that the meeting of board of director was held on 06.01.2010 and 20.04.2010 under the name of M/s Max. Venture Investment Holdings Pvt. Ltd. and Sh. Sanjiv Malik has signed the Board meeting. While on 06.01.2010 and 20.04.2010 neither M/s Max Venture Investment Holdings Pvt. Ltd. was in existence nor Sh. Sanjeev Malik was the director of that company. The name of company was M/s Dynavast India Pvt. Ltd. and this name was subsequently changed to Max Venture Investment Holdings Pvt. Ltd. -and Sh. Sanjiv Malik was appointed as director of the company on 28.12.2011.

(b) The above fact means that the assessee has submitted the document which was created after the happening of events. Thus it does not support its theory of share application money provided by Sh. Analjit Singh.

iv. Further, the contradictory submission of the assessee and M/s Neeman Family Foundation further strengthens the view that the credits of Rs. 87 Crore were not genuine. As per the submission filed by the assessee dated 13.7.2016 "Sh. Analjit Singh had vide gift dated 6.4.2011 conveyed the rights to allotment of shares against the aforesaid application money to Neeman Family foundation without consideration. As per assessee version Sh. Analjit Singh has given gift to M/s Neeman Family Foundation, while M/s Neeman Family Foundation vide its reply dated 9.12.2014 has submitted the copy of balance sheet as on 31.03.2012 and income and expenditure account for the year ended on 31.03.2012. As per this balance sheet Neeman Family Foundation has submitted that Donation received till 31.3.2012 was Rs. 89.16 crores. M/s Neeman Family foundation has never, stated that it has received gift. Hence M/s Neeman Family foundation in its return of income provided receipt of donation and no gift was declared by it. This clearly indicates that there is contradiction between, the submission of the assessee and documents submitted before the income tax department.

4.2 The assessee failed to prove that whether that share application money has ever been returned by the assessee or not to Sh. Analjit Singh.

Reason for formation of belief:

5.1. I have carefully perused and considered the return of income of the assessee, various information provided by the assessee and various documents submitted by the assessee before the department from time to time. It has been observed that various contradictions were observed leading to credits of Rs. 87 crores being share application money received by the assessee during financial year 2009-10. On the basis of material available with the undersigned it was clear that the transactions with respect to credits of Rs. 87 crores is not genuine and thus can be basis of reason-for formation of belief that the income has been escaped assessment.

5.2. From the documents submitted by the assessee during various proceedings for A.Y. 2012-13 and return of income for A.Y. 2010-11 it was clear that the transaction entered by the assessee relating to receipt of share application of Rs. 87 crore is under doubt. Section 68 of the Act provides that if the identity and creditworthiness of person and genuine of the transaction is not proved than the sum has to be treated as income. Prima facie on the basis of information available on records and findings of the Ld. CIT(A)-3’s order dated 09.12.2016, it was clear that the income of Rs. 87 crore being receipt of share application money has escaped assessment.

5.3. All the documents relied upon while forming the belief has been annexed and the detail of which is as under:

i. Copy of extract of minute of meeting of Board dated 6.1.2010 as Annexure 1

ii. Copy of extract of minute of meeting of Board dated 06.1.2010 as annexure 2

iii. Copy of letter dated 9.12.2014 of M/s Neeman Family Foundation including balance sheet and income and expenditure account addressed to ITO w 7(4) in response to notice u/s 133(6) as annexure 3

iv. Copy of assessee's letter dated 13.7,2016 application for stay as annexure 4

Income Chargeable to tax escaping assessment

6.1. Keeping in view all above, I have reason to believe that an amount of Rs 87,00,00,000/- has escaped assessment in case the of M/s Max Ventures Investment Holdings Pvt. Ltd. for the A/Y 2010-11 within the meaning of Section 147/148 of Income-tax Act, 1961.”

5. Mr. Ajay Vohra, learned senior counsel appearing for the assessee, impugned the reassessment notice and urged that when the scrutiny assessment for AY 2011-12 had examined the matter and the addition made, on the same ground, was deleted on appeal, the revenue could not resuscitate the same issue, without any new material. It was submitted that the revenue’s argument that the CIT (A) had issued directions to re-examine the accounts, is an ill-founded submission, unsupported by any such observation in the Appellate Commissioner’s order.

6. It is urged that in the facts of the present case, the assessee received share application money from its founder and promoter, i.e., Shri. Analjit Singh, whose identity and creditworthiness is admittedly not in doubt, including by the AO. The reasons recorded doubt the source of receipt of said share-application money from Mr. Singh on various paltry and erroneous reasons explained above, which are factually incorrect and illegal, made on mere pretence with an intent to reopen the concluded assessment; to conduct roving and fishing enquiries and treat the receipt of share application money as unexplained income under Section 68 through reassessment proceedings under section 147 of the Act which is impermissible in law.

7. It is argued that since the transfer of right to be allotted with equity shares against share application money by Mr. Singh to Neeman Family Foundation was subject to permission from SEBI under the Takeover Code regulations, the entire facts relating to aforesaid investment of Rs. 87 cores by Mr. Singh in the assessee were even disclosed to SEBI. Reference in this regard is made to the application dated 26.11.2014 filed by Neeman Trust for exemption from SEBI Takeover Code Regulations, which was allowed by SEBI by order dated 04.10.2016. Accordingly, the factum of investment of Rs. 87 crores by Mr. Singh in the Petitioner company has been disclosed at several places and therefore the impugned re-assessment proceedings initiated raising doubt on the source of such receipt are erroneous and illegal grounds, which deserves to be quashed.

8. It is urged that that validity of the assumption of jurisdiction under Section 147 has to be tested on the basis of ‘reasons to believe’ formed before issuing notice under Section 148 of the Act. In other words, valid ‘reasons to believe’ is sine qua non for assuming jurisdiction under Section 147 of the Act. If the ‘reasons to believe’ are not valid or are mere pretense or lack due application of mind by the assessing officer, the re-assessment proceedings initiated under Section 147 of the Act would not be valid. Learned counsel relied on Sheo Nath Singh vs. ACIT, 82 ITR 148 (SC); Income Tax Officer vs. Lakhmani Mewal Das, 103 ITR 437 (SC) and Ganga Saran & Sons (P) Ltd. vs. ITO, 130 ITR 1. The following observations in Laksmani Mewal Das, are relied upon:

“The grounds or reasons which lead to the formation of the belief contemplated by section 147(a) of the Act must have a material bearing on the question of escapement of income of the assessee from assessment because of his failure or omission to disclose fully and truly all material facts. Once there exist reasonable grounds for the Income tax Officer to form the above belief that would be sufficient to clothe him with jurisdiction to issue notice. Whether the grounds are adequate or not is not a matter for the court to investigate. The sufficiency of the grounds which induce the Income-tax Officer to act is, therefore, not a justiciable issue. It is, of course, open to the assessee to contend that the Income-tax Officer did not hold the belief that there had been such non-disclosure. The existence of the belief can be challenged by the assessee but not the sufficiency of the reasons for the belief. The expression "reason to believe" does not mean a purely subjective satisfaction on the part of the Income-tax Officer. The reason must be held in good faith. It cannot be merely a pretence. It is open to the court to examine whether the reasons for the formation of the belief have a rational connection with or a relevant bearing on the formation of the belief and are not extraneous or irrelevant for the purpose of the section. To this limited extent, the action of the Income-tax Officer in starting proceedings in respect of income escaping assessment is open to challenge in a court of law.”

9. The revenue contests the writ petition; urging that the reassessment notice is valid and within the bounds of law. It is submitted that the reasoning of the CIT (A) and the documents furnished during miscellaneous proceedings, became a starting point for examining the assessee’s returns. In this regard, it is submitted that contradictions were clearly noticed by the AO while reopening the case of assessee thereby doubting not only the identity of the share applicant but also the genuineness of the transactions. In the opening part of the reason recorded, the AO demonstrated that assessee was in receipt of share application money of Rs. 87 crore against the authorized share capital of Rs. 20,00,000/-. The assessee had issued capital of Rs. 1,00,000/- thereby assessee had option to issue share capital of Rs. 19,00,000/- only. Against this Rs. 19,00,000/-, it received Rs. 87 crores meaning thereby that it might have issued the shares at a premium of Rs. 4568.95/- against the face value of Rs. 10 each thereby issuing the share at 457 times the face value of shares. But the valuation of the assessee did not justify such a high valuation. Even its Net Asset Value at the time of receipt of share application money as per Rule 11UA of the Income Tax Rule, 1962 comes at Rs. 318/-per share against the receipt of share application money at a price of Rs. 4570/- per shares.

10. It is submitted that the assessee gave various contradictory evidences to prove the genuineness of the credits of Rs. 87 crores in its books during the course of assessment proceedings for A.Y 2012-13 and also during the course of stay proceedings. It is argued that no evidence to prove the source of receipt of share application money was ever produced by the assessee. The assessee has for the first time filed the "gift deed" dated 06.04.2011 as “Annexure G” to the Writ Petition before this court. This gift deed was not filed by the assessee before Ld. A.O. Further a gift is one which is out of natural love and affection and not out of any compulsion. But the gift deed dated 06.04.2011 between Sh. Analjit Singh and Neeman Family Foundation was devoid of all these ingredients of gift, as it was made for furthering the family arrangements and was thus out of compulsion. In such circumstances, doubting the genuineness of the transactions cannot be stated to be out of context. It is also an admitted fact that the assessee has not issued the shares even till date and the reason stated by the assessee is that permission would be required from the SEBI. But it is relevant to note that the share application money was received in F.Y. 2009-10 and it was only on 26.11.2014, when the assessee filed a Petition before SEBI. The assessee failed to elaborate as to why no shares were issued from F.Y. 2009-10 to 2014-15. The contradiction itself established that the transaction pertaining to credit of Rs. 87 crores was not genuine.

11. Commissioner of Income Tax v. Kelvinator, (2010) 320 ITR 561 (SC) is now the ruling precedent on what are valid considerations that would justify issuance of a reassessment notice, under Section 147/148. These are briefly, when full disclosure of material facts is not made during the original assessment (such as when essential documents are not produced or shown); etc. The Supreme Court held that the A.O. has power to re-open the assessment if there is tangible material to conclude, prima facie that there has been escapement of income. However, the court cautioned that the power of reassessment is not one of review and that it does not admit of formation of a second opinion. The scope of the phrase “reason to believe” was examined by the Supreme Court previously in M/s. Phool Chand Bajrang Lal and Anr. v. Income Tax Officer and Anr., (1993) 203 ITR 456 (SC). In Phool Chand, the court made observations which remain undisturbed in Kelvinator:

“Thus, where the transaction itself on the basis of subsequent information, is found to be a bogus transaction, the mere disclosure of that transaction at the time of original assessment proceedings, cannot be said to be disclosure of the “true” and “full” facts in the case and the I.T.O. would have the jurisdiction to reopen the concluded assessment in such a case. It is correct that the assessing authority could have deferred the completion of the original assessment proceedings for further enquiry and investigation in

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to the genuineness to the loan transaction but in our opinion his failure to do so and complete the original assessment proceedings would not take away his jurisdiction to act under Section 147 of the Act, on receipt of the information subsequently”. 12. Clearly therefore, when the Revenue gets hold of information or material which tends to or has the potential of undermining its findings (previously made in the assessment proceedings) and have an important bearing, invocation of the power to reassessment is warranted. Now in the present case, the Revenue presses several such circumstances: one, that the SEBI application was made in 2014 after a questionnaire was issued by the AO; two there was nothing to justify the premium of 457 per cent over the face value of the shares – even the market value of the share according to the Revenue on the date of issue of the shares was only Rs. 318/- per share. Three, the SEBI approval was given much later; four, when the authorized capital of company was Rs. 20 lakhs (mostly paid) the necessity for issuing shares worth Rs. 87 crores remained unanswered. 13. In the opinion of this court, the reassessment notice in this case was clearly warranted. Though the assessee had sought to explain that the share application amounts were received and later the shareholding rights were transferred by Mr. Analjit Singh to his family trust. The identity of Shri Analjit Singh was known; however, looking at the transaction (i.e. allotment of shares vastly in excess of the authorized capital, in the absence of any SEBI approval and retention of that money by the assessee which did not show any reason for issuing the shares) the other ingredients of Section 68 (i.e. genuineness of the transaction or credit and the credit worthiness of the individual providing the money) were apparently not established. In the light of these circumstances, and on an application of the law in Phool Chand Bajrang Lal, the Revenue was justified in issuing the impugned notice. 14. As a result of the foregoing discussion, the writ petition has to fail; the interim order is hereby vacated; the revenue is at liberty to issue the final reassessment order, within two weeks. The writ petition is dismissed in these terms.
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