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The AO (Respondent No. 2) picked up their returns for scrutiny and on 25th Sept., 2014 issued notices to each of the petitioners under s. 143(2) of the Act. One of the contentions of the Department was that PRGCPL had introduced bogus share capital of Rs. 5.30 crores with hefty a premium from various fictitious concerns.

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Section 245C and 245D of the Income Tax Act, 1961 — Settlement Commission — There was adequate justification for the decision of the ITSC to conclude that there has not been full and true disclosure by the assessee of all the relevant facts; impugned order of the ITSC calls for no interference — Rohit Kumar Gupta vs. Principal Commissioner of income tax [2019] 310 CTR (Delhi) 393

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