SCOTT EDIL PHARMACIA LTD.,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

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ITA 834/CHANDI/2023Status: DisposedITAT Chandigarh03 March 2025AY 2018-19118 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal addressed multiple grounds raised by the assessees and the revenue. Regarding the deemed dividend under Section 2(22)(e), the Tribunal noted that the issue was common to many appeals and involved credits exceeding remuneration/payments. The judgment indicates that this issue, along with others such as the validity of transfer orders under Section 127 and the requirement for approval under Section 153D, were central to the appeals. The Tribunal also considered grounds related to payments made for property construction and unexplained investments. The operative part of the judgment is not fully detailed in the provided text, but it implies a consolidated decision on these common issues. The principle likely to be cited from this judgment would relate to the interpretation and application of Section 2(22)(e), Section 127, and Section 153D in the context of assessments conducted under Section 153A following a search.

What were the facts?

The appeals were filed against orders passed by the learned CIT(A) pertaining to assessments conducted under Section 153A of the Income Tax Act, 1961. These assessments followed a search action under Section 132 of the Act in the Scott Edil Group of cases on November 15, 2017. The appeals involve multiple assessees, including Maxport India Pvt. Ltd., Vaishali Aggarwal, Scott Edil Advance Research Laboratories & Education Limited, Scott Edil Pharmacia Ltd., Shri Balram Krishan, and Sanjeev Aggarwal. The assessment years range from 2010-11 to 2018-19. The respondent in all appeals is the Deputy Commissioner of Income-tax, Centre Circle-1, Chandigarh. The appeals were heard together due to identical facts and common issues.

What were the issues?

The Tribunal had to decide on several issues across the various appeals. A primary issue concerned the addition of deemed dividends under Section 2(22)(e) of the Income Tax Act, 1961, arising from credits exceeding remuneration or payments received from specific companies (SEPL and SEARLE). Another significant issue was the validity of transfer orders under Section 127 of the Act, dated March 30, 2018, with the assessees arguing they were without the sanction of law and thus bad in law. The assessees also contested orders passed in the absence of incriminating material and raised grounds regarding the approval obtained under Section 153D of the Act. For some assessees, issues included payments made by SEPL for property construction and unexplained investments in jewellery. The revenue, in its appeals, also raised the issue of deemed dividends under Section 2(22)(e). The assessees relied on various arguments, including the lack of legal sanction for transfer orders and the absence of incriminating material. The revenue's contentions were primarily focused on the applicability of Section 2(22)(e).

Which sections of the Income-tax Act were involved?

Section 153A,Section 132,Section 2(22)(e),Section 127,Section 153D,Section 69C,Section 115BBE

AI-generated summary — verify with the full judgment below

Heard together (2 matters)

ITA No. 480/CHD /2023
ITA No. 489/CHD /2023

Read from the judgment's own cause title. This page is filed under one of them.

Order \nPer Bench:\nAll th ese ca ptio ne d a ppe al s ha ve be e n dir ected a gainst the\nsepa rate order s o f th e Ld. CIT(A ) an d per taine d to the asse ssme nts\nca rried ou t under Sec tion 153A of t he Income Tax Ac t, 1961\n(he reina fte r re ferre d to as the “A ct”) p ursua nt to the searc h ac tion\nca rried out under Se ction 132 of the Act in Sc ott E dil G roup of cases\non 15.

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2017. Sin ce the facts involve d in a ll the s e caption ed a p peals\nar e identic al and the re a re c ommon iss ues, he nce the sa me w ere heard\ntog ether a nd the sa me a re being dispo sed of by thi s common or der.\n2. The grou nds/i ssue s ra ise d i n a ll the appea ls ar e summa riz ed as\nunder :\nITA No. 489/Chandi/2023 (Sanjeev Aggarwal, AY 2017-18) (Assessee’s\nAppeal)\n1. Ground No. 1 – General in nature.\n2. Ground no. 2 – Deemed dividend on account of credits exceeding remuneration /\npayments received from SEPL.\n3. Ground no. 3 - Deemed dividend on account of credits exceeding remuneration /\npayments received from SEARLE.\n4. Ground no. 4 – approval u/s 153D\n5. Ground no. 5 – transfer order u/s 127 dated. 30.03.2018 was without sanction of\nlaw, hence bad in law.\n6. Ground no. 6 – General in nature.\nITA No. 505/Chandi/2023 Sanjeev Aggarwal, AY 2017-18 (Appeal by Department)\n1. Ground No. 1 – Deemed dividend u/s 2(22)(e) on account of credit credits\nexceeding remuneration / payments.\n2. Ground no. 2 – General in nature.\nITA No. 480/Chandi/2023 Sanjeev Aggarwal, AY 2018-19 ( Assessee’s Appeal)\n1. Ground No. 1 – General in nature.\n2. Ground no. 2 – Transfer order u/s 127 dtd. 30.03.2018 was without sanction of\nlaw, hence bad in law.\n3. Ground no. 3 – Deemed dividend on account of credits exceeding remuneration /\npayments received from SEPL.\n4. Ground no. 4 – Payment made by SEPL for construction of H.NO 323, Sector-9,\nChandigarh\n5. Ground no. 5 – Payment made by SEPL for construction of H.NO 3100, Sector 21,\nChandigarh.\n6. Ground no. 6 – Addition u/s 69C r.w.s.115BBE on account of difference in\nvaluation of H.NO 3100, Sector-21, Chandigarh.\n7. Ground no. 7: Approval u/s 153D.\n8. Ground No. 8- General in nature.\n5\n9. Ground No. 9- General in nature.\nITA No. 506/Chandi/2023 (Sanjeev Aggarwal, AY 2018-19 ) (Appeal by Department)\n1. Ground No. 1 – Deemed dividend on account of credits exceeding remuneration /\npayments received from SEPL.\n2. Ground No. 2: General in nature.\nITA No. 482/Chandi/2023 (Vaishali Aggarwal, AY 2017-18 ) (Appeal by Assessee)\n1. Ground No. 1 – General in nature.\n2. Ground No. 2 – Deemed dividend u/s 2(22)(e) on account of credit credits\nexceeding remuneration / payments.\n3. Ground No. 3 - Approval u/s 153D.\n4. Ground No. 4 - Transfer order u/s 127 dtd. 30.03.2018 was without sanction of\nlaw, hence bad in law.\n5. Ground No. 5 – General in nature.\nITA No. 483/Chandi/2023 (Vaishali Aggarwal, AY 2018-19) (Appeal by Assessee)\n1. Ground No. 1 – General in nature.\n2. Ground No. 2 – Transfer order u/s 127 dtd. 30.03.2018 was without sanction of law,\nhence bad in law.\n3. Ground No. 3 - Deemed dividend u/s 2(22)(e) on account of credit credits exceeding\nremuneration / payments.\n4. Ground No. 4 - Payment made by SEPL for construction of H.NO 323, Sector-9,\nChandigarh.\n5. Ground No. 5 – Payment made by SEPL for construction of H.NO 3100, Sector-21,\nChandigarh.\n6. Ground no. 6 – Addition u/s 69C r.w.s.115BBE on account of difference in valuation\nof H.NO 3100, Sector-21, Chandigarh.\n7. Ground No. 7 – Unexplained investment in jewellery.\n8. Ground No. 8 - Approval u/s 153D.\n9. Ground No. 9 – Reasonable opportunity of being heard not provided.\n6\nITA No. 591/Chandi/2023 (Maxport India Pvt Ltd, AY 2018-19 ) (Appeal by\nAssessee)\n1. Ground No. 1 – General in nature.\n2. Ground No. 2 - Transfer order u/s 127 dtd. 30.03.2018 was without sanction of law,\nhence bad in law.\n3. Ground No. 3 – Order deserves to be quashed in absence of incriminating material.\n4. Ground No. 4 – Deemed dividend on account of credits exceeding\nremuneration/payments received from SEPL\n5. Ground No. 5 - Approval u/s 153D.\n6. Ground No. 6 – General in nature.\nITA No. 579/Chandi/2023 (Maxport India Pvt Ltd, AY 2017-18 )(Appeal by Assessee)\n1. Ground No. 1 – General in nature.\n2. Ground No. 2 - Transfer order u/s 127 dated 30.03.2018 was without sanction of law,\nhence bad in law.\n3. Ground No. 3 – Order deserves to be quashed in absence of incriminating material.\n4. Ground No. 4 – Commission on sales and purchase transactions carries out allegedly\noutside books.\n5. Ground No. 5 - Approval u/s 153D.\n6. Ground No. 6 – General in nature.\nITA No. 584/Chandi/2023 (Maxport India Pvt Ltd, AY 2016-17 ) (Appeal by\nAssessee)\n1. Ground No. 1 – General in nature.\n2. Ground No. 2 - Transfer order u/s 127 dtd. 30.03.2018 was without sanction of law,\nhence bad in law.\n3. Ground No. 3 – Order deserves to be quashed in absence of incriminating material.\n4. Ground No. 4 – Commission on sales and purchase transactions carries out allegedly\noutside books.\n5. Ground No. 5 - Approval u/s 153D.\n7\n8\n8\n8\n8\n7\n7\n7\n7\n7\n7\n8\n8\n9\n5\n5\n5\n6\n8\n7\n4\n3\n3\n3\n3\n3\n3\n3\n3\n3\n5\n5\n5\n5\n5\n3\n7\n4\n3\n3\n3\n3\n3\n3\n3\n3\n3\n3\n3\n5\n5\n5\n5\n5\n8\n6. Ground No. 6 – General in nature.\nITA No. 583/Chandi/2023 (Maxport India Pvt Ltd, AY 2015-16) (Appeal by Assessee)\n1. Ground No. 1 – General in nature.\n2. Ground No. 2 - Transfer order u/s 127 dtd. 30.03.2018 was without sanction of law,\nhence bad in law.\n3. Ground No. 3 – Order deserves to be quashed in absence of incriminating material.\n4. Ground No. 4 – Commission on sales and purchase transactions carries out allegedly\noutside books.\n5. Ground No. 5 - Approval u/s 153D.\n6. Ground No. 6 – General in nature.\nITA No. 582/Chandi/2023 (Maxport India Pvt Ltd, AY 2014-15 )(Appeal by Assessee)\n1. Ground No. 1 – General in nature.\n2. Ground No. 2 - Transfer order u/s 127 dtd. 30.03.2018 was without sanction of law,\nhence bad in law.\n3. Ground No. 3 – Order deserves to be quashed in absence of incriminating material.\n4. Ground No. 4 – Commission on sales and purchase transactions carries out allegedly\noutside books.\n5. Ground No. 5 - Approval u/s 153D.\n6. Ground No. 6 – General in nature.\nITA No. 732/Chandi/2023 (Balram Krishan Aggarwal, AY 2018-19) (Appeal by\nAssessee)\n1. Ground No. 1 – General in nature.\n2. Ground No. 2 - Transfer order u/s 127 dtd. 30.03.2018 was without sanction of\nlaw, hence bad in law.\n3. Ground No. 3 – Order deserves to be quashed in absence of incriminating material.\n9\n10\n10\n10\n10\n10\n11\n4. Ground No. 4 – Commission on sales and purchase transactions carries out allegedly\noutside books.\n5. Ground No. 5 - Payment of Rs.18,15,549/-by SEPL for construction of house and\nholding the same as deemed dividend.\n6. Ground No. 6 – Payment of Rs.7,77,384/- by SEPL for construction of house and\nholding the same as deemed dividend.\n7. Ground No. 7 – Difference in valuation as per DVO report and books of accounts.\n8. Ground No. 8- Shortage of stock found during search.\n9. Ground no. 9 – approval u/s 153D\n10.Ground no.

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– reasonable opportunity of being heard not given.\n11.Ground no. 11 – general in nature.\nITA No. 732/Chandi/2023 (Balram Krishan Aggarwal, AY 2017-18) (Appeal by\nAssessee)\n1. Ground No. 1 – General in nature.\n2. Ground No. 2 - Transfer order u/s 127 dated 30.03.2018 was without sanction of\nlaw, hence bad in law.\n3. Ground No. 3 – Order deserves to be quashed in absence of incriminating material.\n4. Ground No. 4 – Payment by SEPL for construction of house and holding the same\nas deemed dividend.\n5. Ground No. 5 Purchases treated as bogus purchase.\n6. Ground No. 6 – Approval u/s 153D.\n7. Ground No. 7 – Reasonable opportunity of being heard not given.\n8. Ground No. 8- General in nature.\nITA No. 730/Chandi/2023 (Balram Krishan Aggarwal, AY 2016-17) (Appeal by\nAssessee)\n1. Ground No. 1 – General in nature.\n2. Ground No. 2 - Transfer order u/s 127 dtd. 30.03.2018 was without sanction of\nlaw, hence bad in 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More judgments on Section 153A

All 18,957 judgments and leading authorities on Section 153A →

Recent GST High Court judgments

Search GST case law →