Smt. Rachna Arora, New Delhi vs. ITO, New Delhi
In the result the appeals of the assessees are allowed
ITA 4079/DEL/2014[2001-02]Status: DisposedITAT Delhi22 Dec 2015AY 2001-02
Bench: Shri Vijay Pal Raorachna Arora, Ito, B-424, Meera Bagh, Ward-25(3), Vs. New Delhi New Delhi Pan:Aikpa0370Q (Assessee) (Respondent) Shanti Arora, Ito, B-424, Meera Bagh, Ward-25(3), Vs. New Delhi New Delhi Pan:Aikpa0370Q (Assessee) (Respondent) Amit Arora, Ito, B-424, Meera Bagh, Ward-25(3), Vs. New Delhi New Delhi Pan:Aikpa0370Q (Assessee) (Respondent)
For Appellant: Sh. B.B. Bhagar, AdvFor Respondent: Dr. Anjula Jain, Sr. DR
Section 144Section 147Section 148Section 271(1)(c)
…rding deemed income as concealed income being the difference between assessed income and return income. She has also relied upon the decision of the Hon’ble Supreme Court in the case of Union of India & Others v. Dharmendra Textile Processors & Others, (2007) 295 ITR 244 as well in the case of Mak Data (P) Ltd. v. CIT, (2014) 1 SCC 674. Thus the ld DR has supported the order of the authorities below and submitted that when the assessee has failed to discharge its onus to prove the transaction of gift as genuine and the addition made by the AO has attained finality then as per explanation of section 271(1)(c) the…