DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. PATANJALI AYURVED LTD., DELHI
What did the Tribunal hold?
The Tribunal noted that the appeals stem from a common search action and subsequent section 153C proceedings. The Assessing Officer's assessment order indicated that non-genuine bills were provided to the assessee by another party.
What were the facts?
The appeals arise from search action in M/s. Hawala Traders Group, leading to section 153C proceedings against M/s. Patanjali Ayurved Ltd. The Assessing Officer noted that Sh. Sumit Jindal provided non-genuine bills to various entities, including the assessee.
What were the issues?
The core issue revolves around the validity of assessments made under section 153C based on non-genuine bills provided by a third party. The appeals concern multiple assessment years.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI BENCH: ‘B NEW DELHI
Before: SHRI SATBEER SINGH GODARA & SHRI MANISH AGARWAL
ORDER
PER SATBEER SINGH GODARA, JM
The instant batch of seven appeals involves the single assessee, namely, M/s. Patanjali Ayurved Ltd. This assessee and the department have filed their respective three cross appeals each Nos.534 to 536/Del/2025 and 605 & 607/Del/2025, against the Commissioner of Income Tax (Appeals)- 24 [in short, the “CIT(A)”], New Delhi’s separate orders, dated 26.11.2024 (for AYs: 2013-14 and 2014-15) and 27.11.2024 (for AY: 2015-16), passed in case nos. CIT(A), Delhi-24/10102/2012- 13, 10194/2013-14 and 11029/2014-15, in proceedings under section 143(3) r.w.s. 153C of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’), respectively. The assessee’s last appeal ITA No.537/Del/2025 is directed against CIT(A)-24, New Delhi’s order dated 27.12.2024 passed in case no. CIT(A), Delhi- 24/10463/2016-17 involving proceedings under section 153C of the Act. Heard both the parties. Case files perused.
We notice during the course of hearing that the instant batch of seven cases i.e. assessee’s four and the Revenue’s three cross- appeals, arises from a common search action dated 31st October to 2 | P a g e 3rd November, 2018 in M/s. Hawala Traders Group leading to initiation of section 153C proceedings herein which finally culminated in the impugned assessments dated 27th March, 2023 in question. And that the learned Assessing Officer himself clarified in the assessment order(s) at page 2 para 4 that “in the case of Sh. Sumit Jindal it was found that he has provided non-genuine bills to………….., including “M/s. Patanjali Ayurved Ltd.” i.e. the assessee. Meaning thereby that no addition herein has been made which could be held to be based on any specific incriminating or seized material during “search”; held as mandatory in PCIT Vs. Abhisar Buildwell Pvt. Ltd. (2023) 454 ITR 212 (SC).
We make it clear that once the learned Assessing Officer had issued his section 153C notice on 06.08.2021, all these assessment years i.e. AY 2013-14 to 2015-16 & 2017-18 are “unabated” ones; and, therefore, we hardly find any merit in the Revenue’s vehement contentions supporting the four impugned assessments, which are hereby quashed in very terms. All other pleadings on merits between the parties herein stand rendered academic.
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