DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3, NEW DELHI, DELHI vs. BHUSHAN DUA, DELHI

ITA 2951/DEL/2023Status: DisposedITAT Delhi25 September 2025AY 2016-17Bench: MS. MADHUMITA ROY (Judicial Member), SHRI NAVEEN CHANDRA (Accountant Member)309 pages
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What did the Tribunal hold?

The Tribunal held that protective assessments of amounts already confirmed as substantive additions in the hands of SCIPL would amount to double taxation. Therefore, such protective additions were to be deleted.

What were the facts?

A search action was conducted on Super Cassettes Industries Pvt Ltd (SCIPL) group, leading to assessments under Section 153A and 143(3). The appeals involved additions on account of income retained abroad, unaccounted cash transactions, and bogus expenses related to film production.

What were the issues?

Whether protective additions made in the hands of the assessee, when substantive additions on the same issue are confirmed in the hands of another entity (SCIPL), amount to double taxation.

Which sections of the Income-tax Act were involved?

Section 132,Section 153A,Section 143(3)

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Cases cited in this judgment(25)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

Super Cassettes Industries Pvt. Ltd. IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “G”: NEW DELHI BEFORE Ms. MADHUMITA ROY, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER A.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

Super Cassettes Industries Pvt. Ltd., Vs DCIT Central Circle-03, E-2/16 White House, Ansari Road, Delhi. Daryaganj, New Delhi-110002. PAN: AABCS 4712 P APPELLANT RESPONDENT A.Y. 2013-14 A.Y. 2014-15 A.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

DCIT Central Circle-03, Vs Super Cassettes Industries Pvt. Ltd., Delhi. E-2/16 White House, Ansari Road, Daryaganj, New Delhi-110002. PAN: AABCS 4712 P APPELLANT RESPONDENT

AND Super Cassettes Industries Pvt. Ltd. A.Y. 2019-20

DCIT Central Circle- Vs Luv Ranjan, R-11/40, Rajnagar, Ghaziabad- 03,Delhi. 201002PAN: AHGPR 9364 K APPELLANT RESPONDENT

AND A.Y. 2013-14 A.Y. 2014-15 A.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

DCIT Central Circle-03, Vs Bhushan Dua Delhi W-83 Greater Kailash Part II New Delhi 110048 PAN:

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