ACIT, NEW DELHI vs. SH. VIKRAM DHIRANI, NEW DELHI

ITA 6032/DEL/2016Status: DisposedITAT Delhi17 April 2023AY 2012-1327 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the evidence for the undisclosed foreign bank account was not admissible and that additions based on notional interest were unsustainable. Consequently, the additions made by the AO were deleted.

What were the facts?

Following a search operation, the Assessing Officer (AO) made additions to the assessee's income, primarily concerning an undisclosed foreign bank account and subsequent notional interest. The CIT(A) partially sustained additions related to the foreign bank account but deleted notional interest and other additions made in subsequent assessment years.

What were the issues?

The key issues were the admissibility of evidence for undisclosed foreign bank accounts and the taxability of notional interest. The Tribunal also considered the validity of additions made without incriminating material found during search and the deletion of penalties.

Which sections of the Income-tax Act were involved?

Section 153A,Section 143(3),Section 132(4),Section 271(1)(b),Section 271(1)(c)

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Cases cited in this judgment(30)Show list

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Heard together (8 matters)

ITA No.4475/Del/2016
ITA No.1092/Del/2017
ITA No.1849/Del/2017
ITA No.6031/Del/2016
ITA No.6028/Del/2016
ITA No.6029/Del/2016
ITA No.6030/Del/2016
ITA No.6032/Del/2016

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

IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH ‘G’ : NEW DELHI) D-1039, New Friends Colony, Central Circle-7, New Delhi-110065 (Old Central Circle-12) PAN : AHTPD6528L New Delhi ITA No.4647 to 4652 /Del/2016 A.Y. 2007-08, 2008-09, 2009-10, 2010-11, 2011-12, 2012-13 Central Circle-7, D-1039, New Friends (Old Central Circle-12) Colony, New Delhi New Delhi-110065 PAN : AHTPD6528L

ITA No.4475/Del/2016, A.Y. 2007-08 ITA No.1092/Del/2017, A.Y. 2007-08 D-1039, New Friends Colony, Central Circle-7, New Delhi-110065 (Old Central Circle-12) PAN : AHTPD6528L New Delhi ITA No.1849/Del/2017, A.Y. 2007-08 ITA No.6031/Del/2016, A.Y. 2008-09 ITA No.6028/Del/2016, A.Y. 2009-10 ITA No.6029/Del/2016, A.Y. 2010-11 ITA No.6030/Del/2016, A.Y. 2011-12 ITA No.6032/Del/2016, A.Y. 2012-13 Central Circle-7, D-1039, New Friends (Old Central Circle-12) Colony, New Delhi New Delhi-110065 PAN : AHTPD6528L Appellant Respondent

4100 & Ors Vikram Dhirani 2

Assessee by Shri P.C.Yadav, Adv. Reven

The order continues below.

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