109 TTJ 700 (Del) SMC Share Brokers Ltd. v. DCIT

293 ITR 43High Court2007#309 most cited

What is 109 TTJ 700 (Del) SMC Share Brokers Ltd. v. DCIT authority for?

Where an assessment order is merely a copy-paste of observations from an investigation wing's appraisal report without independent verification, it is not a valid basis for making additions to income.

264

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2015 to 2026.

Also referred to as

SMC Share Brokers Ltd. · CIT vs SMC Share Stock Brokers · CIT vs S M Aggarwal · 293 ITR 43 · 288 ITR 345 · copy paste assessment · appraisal report · investigation wing · AO · independent investigation

Sections most often in play

Section 143(3)Section 69ASection 132Section 153ASection 69CSection 153CSection 147Section 292C

Issues it is cited on

buyback of sharessection 115adsection 2(1a)section 2(1)section 66section 60section 153a proceedingssection 63onus of proofsection 2(14)(iii)section 158bbsection 269t

Judgments citing 109 TTJ 700 (Del) SMC Share Brokers Ltd. v. DCIT

Asstt. Commissioner of Income Tax, Central Circle, Kota vs. Banas Minerals Private Limited, Jhalawar

In the result the appeal of the revenue in ITA no

ITA 240/JPR/2024[2018-19]Status: DisposedITAT Jaipur03 Dec 2024AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Rajendra Jain (Adv.) (V.C)For Respondent: Smt. Alka Gautam, CIT-DR (V.H)
Section 153ASection 250Section 69B

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR Mk0 ,l- lhrky{eh] U;kf;d lnL; ,oa Jh jkBksM deys'k t;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la vk;dj vihy la-@ITA. Nos. 239 & 240/JP/2024 vk;dj vihy la vk;dj vihy la fu/kZkj.k o"kZ@Assessment Years : 2013-14 & 2018-19 fu/kZkj.k o"kZ@ fu/kZkj.k o"kZ@ fu/kZkj.k o"kZ@ cuke cuke cuke cuke ACIT, Banas Minerals Private Ltd Central Circle, F 51 Phase III, RICCO Vs. Kota Industrial Area, Jhalawar LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AADCB 01…

ACIT, Central Circle, Kota vs. Banas Minerals Private Limited, Jhalawar

In the result the appeal of the revenue in ITA no

ITA 239/JPR/2024[2013-14]Status: DisposedITAT Jaipur03 Dec 2024AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Rajendra Jain (Adv.) (V.C)For Respondent: Smt. Alka Gautam, CIT-DR (V.H)
Section 153ASection 250Section 69B

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR Mk0 ,l- lhrky{eh] U;kf;d lnL; ,oa Jh jkBksM deys'k t;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la vk;dj vihy la-@ITA. Nos. 239 & 240/JP/2024 vk;dj vihy la vk;dj vihy la fu/kZkj.k o"kZ@Assessment Years : 2013-14 & 2018-19 fu/kZkj.k o"kZ@ fu/kZkj.k o"kZ@ fu/kZkj.k o"kZ@ cuke cuke cuke cuke ACIT, Banas Minerals Private Ltd Central Circle, F 51 Phase III, RICCO Vs. Kota Industrial Area, Jhalawar LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AADCB 01…

ACIT, New Delhi vs. M/S. Devine Infracon Pvt. Ltd., New Delhi

ITA 3068/DEL/2014[2010-11]Status: DisposedITAT Delhi28 Oct 2024AY 2010-11

Bench: M Balaganesh, Accontant Member & Ms Madhumita Royassessment Year: 2010-11 The Assistant Vs. M/S Divine Infracon Commissioner Of Income Private Limited, Plot Tax, Central Circle-09, No. 4, Sector-13, Jhandewalan, New Delhi, Dwarka City Centre, Room No.357, Ara Centre, Dwarka, New Delhi- E-2, Jhandewalan 110075 Extension, New Delhi Pan :Aaccd4476A (Appellant) (Respondent) Assessee By Shri Salil Aggarwal, Sr, Advocate Department By Shri T James Singson, Cit, Dr

Section 132Section 139(1)Section 143(2)Section 153ASection 68

…f which the Tribunal could come to the finding that the amount of Rs. 1,07,350 was remitted by the assessee from Madras and that it represented the concealed income of the assessee." [Emphasis Supplied] ii) 288 ITR 345 (Del) CIT V SMC Share Stock Brokers iii) 293 ITR 43 (Del) CIT VS M Aggarwal iv) 295 ITR 105(Del) CIT vs Dharam Pal Prem Chand Ltd iv) 207 CTR 115 CIT Vs Pradeep Kumar Gupta 5.8 - It is further submitted that appellant had produced all the evidences to substantiate the identity of the investors, genuineness of the transaction and creditworthiness of the investors, and the investors who are assessed…

Ganadhipati Construction Private Ltd, Patna vs. PCIT, Central, Patna

In the result, all the appeals of the assessee bearing

ITA 360/PAT/2024[2021-22]Status: DisposedITAT Patna16 Oct 2024AY 2021-22

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 133(6)Section 142(1)Section 143(3)Section 153CSection 263

…dmissible evidence i.e. by the evidence of those persons who can vouchsafe for the truth of the facts in issue. Further reliance is placed on the following judicial pronouncements: i. Mohammed Yusuf vs. D. &Ors., AIR 1968 (Bom.) 112. ii. CIT vs. S M Aggarwal, 293 ITR 43 (Del.) 26. Further it is brought to our notice that huge addition has been made in the hands of other assessee, namely, Shri Satyendra Kumar Sharma, who has owned various documents seized during the course of search and has stated to that even Assessment Years: 2017-2018to 2021-2022 Gandhipati Construction Private Limited some documents are in his…

Ganadhipati Construction Private Limited, Patna vs. PCIT, Central, Patna

In the result, all the appeals of the assessee bearing

ITA 359/PAT/2024[2020-21]Status: DisposedITAT Patna16 Oct 2024AY 2020-21

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 133(6)Section 142(1)Section 143(3)Section 153CSection 263

…dmissible evidence i.e. by the evidence of those persons who can vouchsafe for the truth of the facts in issue. Further reliance is placed on the following judicial pronouncements: i. Mohammed Yusuf vs. D. &Ors., AIR 1968 (Bom.) 112. ii. CIT vs. S M Aggarwal, 293 ITR 43 (Del.) 26. Further it is brought to our notice that huge addition has been made in the hands of other assessee, namely, Shri Satyendra Kumar Sharma, who has owned various documents seized during the course of search and has stated to that even Assessment Years: 2017-2018to 2021-2022 Gandhipati Construction Private Limited some documents are in his…

Ganadhipati Construction Private Limited, Patna vs. PCIT, Central, Patna

In the result, all the appeals of the assessee bearing

ITA 358/PAT/2024[2019-20]Status: DisposedITAT Patna16 Oct 2024AY 2019-20

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 133(6)Section 142(1)Section 143(3)Section 153CSection 263

…dmissible evidence i.e. by the evidence of those persons who can vouchsafe for the truth of the facts in issue. Further reliance is placed on the following judicial pronouncements: i. Mohammed Yusuf vs. D. &Ors., AIR 1968 (Bom.) 112. ii. CIT vs. S M Aggarwal, 293 ITR 43 (Del.) 26. Further it is brought to our notice that huge addition has been made in the hands of other assessee, namely, Shri Satyendra Kumar Sharma, who has owned various documents seized during the course of search and has stated to that even Assessment Years: 2017-2018to 2021-2022 Gandhipati Construction Private Limited some documents are in his…

Ganadhipati Construction Pvt Ltd, Patna vs. PCIT, Central, Patna

In the result, all the appeals of the assessee bearing

ITA 357/PAT/2024[2018-19]Status: DisposedITAT Patna16 Oct 2024AY 2018-19

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 133(6)Section 142(1)Section 143(3)Section 153CSection 263

…dmissible evidence i.e. by the evidence of those persons who can vouchsafe for the truth of the facts in issue. Further reliance is placed on the following judicial pronouncements: i. Mohammed Yusuf vs. D. &Ors., AIR 1968 (Bom.) 112. ii. CIT vs. S M Aggarwal, 293 ITR 43 (Del.) 26. Further it is brought to our notice that huge addition has been made in the hands of other assessee, namely, Shri Satyendra Kumar Sharma, who has owned various documents seized during the course of search and has stated to that even Assessment Years: 2017-2018to 2021-2022 Gandhipati Construction Private Limited some documents are in his…

Ganadhipati Construction Private Limited, Patna vs. PCIT, Central, Patna

In the result, all the appeals of the assessee bearing

ITA 356/PAT/2024[2017-18]Status: DisposedITAT Patna16 Oct 2024AY 2017-18

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 133(6)Section 142(1)Section 143(3)Section 153CSection 263

…dmissible evidence i.e. by the evidence of those persons who can vouchsafe for the truth of the facts in issue. Further reliance is placed on the following judicial pronouncements: i. Mohammed Yusuf vs. D. &Ors., AIR 1968 (Bom.) 112. ii. CIT vs. S M Aggarwal, 293 ITR 43 (Del.) 26. Further it is brought to our notice that huge addition has been made in the hands of other assessee, namely, Shri Satyendra Kumar Sharma, who has owned various documents seized during the course of search and has stated to that even Assessment Years: 2017-2018to 2021-2022 Gandhipati Construction Private Limited some documents are in his…

Nalanda Engicon Pvt. Ltd, Patna vs. Pr. CIT Central, Patna

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

ITA 329/PAT/2024[2021-22]Status: DisposedITAT Patna12 Sept 2024AY 2021-22

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

Section 127Section 143(3)Section 153ASection 263

…dmissible evidence i.e. by the evidence of those persons who can vouchsafe for the truth of the facts in issue. Further reliance is placed on the following judicial pronouncements: i. Mohammed Yusuf vs. D. &Ors., AIR 1968 (Bom.) 112. ii. CIT vs. S M Aggarwal, 293 ITR 43 (Del.) 26. Further it is brought to our notice that huge addition has been made in the hands of other assessee, namely, Shri Satyendra Kumar Sharma, who has owned various documents seized during the course of search and has stated to that even some documents are in his own hand writing. The ld. Assessing Officer of the assessee is also the ld. Ass…

Nalanda Engicon Pvt. Ltd, Patna vs. Pr. CIT Central, Patna

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

ITA 328/PAT/2024[2020-21]Status: DisposedITAT Patna12 Sept 2024AY 2020-21

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

Section 127Section 143(3)Section 153ASection 263

…dmissible evidence i.e. by the evidence of those persons who can vouchsafe for the truth of the facts in issue. Further reliance is placed on the following judicial pronouncements: i. Mohammed Yusuf vs. D. &Ors., AIR 1968 (Bom.) 112. ii. CIT vs. S M Aggarwal, 293 ITR 43 (Del.) 26. Further it is brought to our notice that huge addition has been made in the hands of other assessee, namely, Shri Satyendra Kumar Sharma, who has owned various documents seized during the course of search and has stated to that even some documents are in his own hand writing. The ld. Assessing Officer of the assessee is also the ld. Ass…

Nalanda Engicon Pvt. Ltd, Patna vs. Pr. CIT Central, Patna

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

ITA 327/PAT/2024[2019-20]Status: DisposedITAT Patna12 Sept 2024AY 2019-20

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

Section 127Section 143(3)Section 153ASection 263

…dmissible evidence i.e. by the evidence of those persons who can vouchsafe for the truth of the facts in issue. Further reliance is placed on the following judicial pronouncements: i. Mohammed Yusuf vs. D. &Ors., AIR 1968 (Bom.) 112. ii. CIT vs. S M Aggarwal, 293 ITR 43 (Del.) 26. Further it is brought to our notice that huge addition has been made in the hands of other assessee, namely, Shri Satyendra Kumar Sharma, who has owned various documents seized during the course of search and has stated to that even some documents are in his own hand writing. The ld. Assessing Officer of the assessee is also the ld. Ass…

Nalanda Engicon Pvt. Ltd, Patna vs. Pr. CIT Central, Patna

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

ITA 326/PAT/2024[2018-19]Status: DisposedITAT Patna12 Sept 2024AY 2018-19

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

Section 127Section 143(3)Section 153ASection 263

…dmissible evidence i.e. by the evidence of those persons who can vouchsafe for the truth of the facts in issue. Further reliance is placed on the following judicial pronouncements: i. Mohammed Yusuf vs. D. &Ors., AIR 1968 (Bom.) 112. ii. CIT vs. S M Aggarwal, 293 ITR 43 (Del.) 26. Further it is brought to our notice that huge addition has been made in the hands of other assessee, namely, Shri Satyendra Kumar Sharma, who has owned various documents seized during the course of search and has stated to that even some documents are in his own hand writing. The ld. Assessing Officer of the assessee is also the ld. Ass…

Nalanda Engicon Pvt. Ltd, Patna vs. Pr. CIT Central, Patna

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

ITA 325/PAT/2024[2017-18]Status: DisposedITAT Patna12 Sept 2024AY 2017-18

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

Section 127Section 143(3)Section 153ASection 263

…dmissible evidence i.e. by the evidence of those persons who can vouchsafe for the truth of the facts in issue. Further reliance is placed on the following judicial pronouncements: i. Mohammed Yusuf vs. D. &Ors., AIR 1968 (Bom.) 112. ii. CIT vs. S M Aggarwal, 293 ITR 43 (Del.) 26. Further it is brought to our notice that huge addition has been made in the hands of other assessee, namely, Shri Satyendra Kumar Sharma, who has owned various documents seized during the course of search and has stated to that even some documents are in his own hand writing. The ld. Assessing Officer of the assessee is also the ld. Ass…

Nalanda Engicon Pvt. Ltd, Patna vs. Pr. CIT Central, Patna

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

ITA 323/PAT/2024[2015-16]Status: DisposedITAT Patna12 Sept 2024AY 2015-16

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

Section 127Section 143(3)Section 153ASection 263

…dmissible evidence i.e. by the evidence of those persons who can vouchsafe for the truth of the facts in issue. Further reliance is placed on the following judicial pronouncements: i. Mohammed Yusuf vs. D. &Ors., AIR 1968 (Bom.) 112. ii. CIT vs. S M Aggarwal, 293 ITR 43 (Del.) 26. Further it is brought to our notice that huge addition has been made in the hands of other assessee, namely, Shri Satyendra Kumar Sharma, who has owned various documents seized during the course of search and has stated to that even some documents are in his own hand writing. The ld. Assessing Officer of the assessee is also the ld. Ass…

Nalanda Engicon Pvt. Ltd, Patna vs. Pr. CIT (Central), Patna

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

ITA 322/PAT/2024[2014-15]Status: DisposedITAT Patna12 Sept 2024AY 2014-15

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

Section 127Section 143(3)Section 153ASection 263

…dmissible evidence i.e. by the evidence of those persons who can vouchsafe for the truth of the facts in issue. Further reliance is placed on the following judicial pronouncements: i. Mohammed Yusuf vs. D. &Ors., AIR 1968 (Bom.) 112. ii. CIT vs. S M Aggarwal, 293 ITR 43 (Del.) 26. Further it is brought to our notice that huge addition has been made in the hands of other assessee, namely, Shri Satyendra Kumar Sharma, who has owned various documents seized during the course of search and has stated to that even some documents are in his own hand writing. The ld. Assessing Officer of the assessee is also the ld. Ass…

Anil Chaudhary, New Delhi vs. ACIT Central Circle-17, New Delhi

In the result, appeals filed by the assessee are allowed

ITA 2938/DEL/2023[2017-18]Status: DisposedITAT Delhi30 Aug 2024AY 2017-18

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR
Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

…he basis of which it could justify its action, as the statement of the aforesaid two witnesses was the only basis of issuing the Show-Cause Notice.” iii) 125 ITR 713 (SC) Kishnichand Chellaram vs. CIT iv) 288 ITR 345 (Del.) CIT vs. SMC Share Broker Limited v) 293 ITR 43 (Del) CIT vs. S.M. Aggarwal vi) 295 ITR 105 (Del) CIT vs. Dharam Pal Prem Chand Ltd. vii) 303 ITR 95 (Del) CIT vs. Pradeep Kumar Gupta viii) 322 ITR 396 (Del) CIT vs. Ashwani Gupta ix) 379 ITR 367 (Del) CIT v Sunil Aggarwal x) 382 ITR 639 (Del) Roger Enterprise Ltd vs. CIT xi) 2024 SCC Online Del 4012 PCIT vs. Pavitra Realcon (P) Ltd. (pages 438-4…

Anil Chaudhary, New Delhi vs. ACIT Central Circle-17, New Delhi

In the result, appeals filed by the assessee are allowed

ITA 2937/DEL/2023[2016-17]Status: DisposedITAT Delhi30 Aug 2024AY 2016-17

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR
Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

…he basis of which it could justify its action, as the statement of the aforesaid two witnesses was the only basis of issuing the Show-Cause Notice.” iii) 125 ITR 713 (SC) Kishnichand Chellaram vs. CIT iv) 288 ITR 345 (Del.) CIT vs. SMC Share Broker Limited v) 293 ITR 43 (Del) CIT vs. S.M. Aggarwal vi) 295 ITR 105 (Del) CIT vs. Dharam Pal Prem Chand Ltd. vii) 303 ITR 95 (Del) CIT vs. Pradeep Kumar Gupta viii) 322 ITR 396 (Del) CIT vs. Ashwani Gupta ix) 379 ITR 367 (Del) CIT v Sunil Aggarwal x) 382 ITR 639 (Del) Roger Enterprise Ltd vs. CIT xi) 2024 SCC Online Del 4012 PCIT vs. Pavitra Realcon (P) Ltd. (pages 438-4…

Anil Chaudhary, New Delhi vs. ACIT Central Circle-17, New Delhi

In the result, appeals filed by the assessee are allowed

ITA 2936/DEL/2023[2015-16]Status: DisposedITAT Delhi30 Aug 2024AY 2015-16

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR
Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

…he basis of which it could justify its action, as the statement of the aforesaid two witnesses was the only basis of issuing the Show-Cause Notice.” iii) 125 ITR 713 (SC) Kishnichand Chellaram vs. CIT iv) 288 ITR 345 (Del.) CIT vs. SMC Share Broker Limited v) 293 ITR 43 (Del) CIT vs. S.M. Aggarwal vi) 295 ITR 105 (Del) CIT vs. Dharam Pal Prem Chand Ltd. vii) 303 ITR 95 (Del) CIT vs. Pradeep Kumar Gupta viii) 322 ITR 396 (Del) CIT vs. Ashwani Gupta ix) 379 ITR 367 (Del) CIT v Sunil Aggarwal x) 382 ITR 639 (Del) Roger Enterprise Ltd vs. CIT xi) 2024 SCC Online Del 4012 PCIT vs. Pavitra Realcon (P) Ltd. (pages 438-4…

Anil Chaudhary, New Delhi vs. ACIT Central Circle-17, New Delhi

In the result, appeals filed by the assessee are allowed

ITA 2935/DEL/2023[2014-15]Status: DisposedITAT Delhi30 Aug 2024AY 2014-15

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR
Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

…he basis of which it could justify its action, as the statement of the aforesaid two witnesses was the only basis of issuing the Show-Cause Notice.” iii) 125 ITR 713 (SC) Kishnichand Chellaram vs. CIT iv) 288 ITR 345 (Del.) CIT vs. SMC Share Broker Limited v) 293 ITR 43 (Del) CIT vs. S.M. Aggarwal vi) 295 ITR 105 (Del) CIT vs. Dharam Pal Prem Chand Ltd. vii) 303 ITR 95 (Del) CIT vs. Pradeep Kumar Gupta viii) 322 ITR 396 (Del) CIT vs. Ashwani Gupta ix) 379 ITR 367 (Del) CIT v Sunil Aggarwal x) 382 ITR 639 (Del) Roger Enterprise Ltd vs. CIT xi) 2024 SCC Online Del 4012 PCIT vs. Pavitra Realcon (P) Ltd. (pages 438-4…

Gyan Infrabuild Pvt. Ltd, Varanasi vs. ACIT Central Circle-03, Patna

In the result, all the appeals of the assessee for Assessment Year

ITA 178/PAT/2023[2018-19]Status: DisposedITAT Patna13 May 2024AY 2018-19

Bench: Shri Sonjoy Sarma, Hon’Blei.T.A. No. 175 To 178/Pat/2023 Assessment Year: 2015-16 To 2018-19 Gyan Infrabuild Private Limited Principal Commissioner Of Awlespur, Kandwa Vs Income-Tax (Central), Patna Varanasi - 221006 [Pan: Aaecg0509Mc] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri S.C. Aggrawal, Sr. Adv. & Shri Manish Rastogi, Adv. Revenue By : Md. A.H. Chowdhary, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 05/03/2024 घोषणा क" तारीख /Date Of Pronouncement: 13/05/2024 आदेश/O R D E R Per, Dr. Manish Borad: The Present Appeals Are Directed At The Instance Of The Assessee Against The Separate & Identical Orders Of The Learned Principal Commissioner Of Income Tax (Central), Patna (Hereinafter The “Ld. Pr. Cit”) Even Dt. 26/03/2022, Passed U/S 263 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2015-16 To 2018-19. 2. The Registry Has Pointed Out That There Is A Delay Of 14 Days In Filing Of These Appeals. There Is A Petition For Condonation Of Delay Stating Therein, The Reasons For The Delay. Relevant Content Of The Petition Dt. 08/06/2023 Is Extracted For Ready Reference:- “…….. 1. That We Had Received An Order U/S 263 Passed By Id Principal Commissioner Of Income-Tax, Central Circle, Patna On 26.03.2022. 2

For Appellant: Shri S.C. Aggrawal, Sr. Adv. & Shri Manish Rastogi, AdvFor Respondent: Md. A.H. Chowdhary, CIT, D/R
Section 132Section 133ASection 153ASection 263

…dmissible evidence i.e. by the evidence of those persons who can vouchsafe for the truth of the facts in issue. Further reliance is placed on the following judicial pronouncements: i. Mohammed Yusuf vs. D. &Ors., AIR 1968 (Bom.) 112. ii. CIT vs. S M Aggarwal, 293 ITR 43 (Del.) 26. Further it is brought to our notice that huge addition has been made in the hands of other assessee, namely, Shri Satyendra Kumar Sharma, who has owned various documents seized during the course of search and has stated to that even some documents are in his own hand writing. The ld. Assessing Officer of the assessee is also the ld. Ass…