(1.) THE Revenue is aggrieved by the order of the Income Tax Appellate Tribunal (ITAT) dated 24.11.2011 in ITA No. 4194/Del/2011. The impugned order had rejected the Revenue's appeal.
(2.) THE following questions of law was framed for consideration at the time the matter was heard:
(3.) THE AO noticed that the assessee was a private company and that in such cases there was a close and proximate relationship between the promoters and shareholders. It was further held that the assessee should not have had any difficulty to produce the investors had the whole transaction been genuine. After analyzing each bank account entry of all the share applicants, the AO concluded as follows: