DCIT, NEW DELHI vs. ROLLAND ENTERPRISES LTD., NEW DELHI

ITA 3353/DEL/2015Status: DisposedITAT Delhi29 December 2023AY 2012-13Bench: Sh. Saktijit Dey, Vice President Dr. B. R. R. Kumar (Accountant Member)22 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that assessments made under Section 153C for AY 2007-08, based on a satisfaction note recorded on 18.11.2013, were outside the scope of Section 153C and thus void ab initio. Consequently, the assessment for AY 2012-13 was also treated as void.

What were the facts?

The Revenue appealed against the CIT(A)'s order deleting additions made under Section 153C. The assessee filed cross-objections challenging the jurisdiction and validity of proceedings initiated under Section 153C and other procedural aspects.

What were the issues?

The key issues were the validity of proceedings initiated under Section 153C based on the date of the satisfaction note and the consequent impact on the assessment years involved.

Which sections of the Income-tax Act were involved?

Section 153C,Section 143(3),Section 6(3)(ii),Section 9(1),Section 124(4),Section 144C,Section 143(2)

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Cases cited in this judgment(4)Show list

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Income Tax Appellate Tribunal, DELHI BENCH ‘D’, NEW DELHI

Before: Sh. Saktijit DeyDr. B. R. R. Kumar

For Respondent: DR &
Hearing: 26.10.2023Pronounced: 29.12.2023

Heard together (4 matters)

ITA No.3348/Del/2015
ITA No.3353/Del/2015
CO No.352/Del/2015
CO No.357/Del/2015

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

Per Bench: The present appeals by the Revenue and the Cross Objections by the assessee have been filed against the orders of ld. CIT(A)-XXVII, New Delhi.

2.

The common grounds raised in ITA Nos. 3348 & 3353/Del/2015. In ITA No. 3348/Del/2015, following grounds have been raised by the Revenue:

The order continues below.

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