Vijayshree Food Products P.Ltd, New Delhi vs. ACIT, Central Circle-30, New Delhi
In the result, both these appeals are partly allowed
ITA 587/DEL/2019[2014-15]Status: DisposedITAT Delhi06 Dec 2021AY 2014-15
Bench: Shri R.K. Panda & Ms Suchitra Kambleassessment Year: 2014-15 Vijayshree Food Products P. Ltd., Vs. Acit, C/O Ravi Gupta, Advocate, Central Circle-30, E-6A, Kailash Colony, New Delhi. New Delhi. Pan: Aaccv4721C (Appellant) (Respondent) Assessee By : Shri P.C. Yadav, Advocate Revenue By : Shri Prakash Dubey, Sr.Dr Date Of Hearing : 09.09.2021 Date Of Pronouncement : 06.12.2021 Order Per R.K. Panda, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 28Th December, 2018 Of The Cit(A)-30, New Delhi, Relating To Assessment Year 2014-15. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Company Engaged In The Business Of Manufacturing & Export Of Tobacco Products. It Filed Its Return Of Income On 30Th September, 2014 Declaring The Loss Of Rs.18,78,467/-. The Return Was Processed U/S 143(1) Of The Act On 26Th November, 2014 At The Returned Income. Subsequently, The Ao Reopened The Assessment As Per The Provisions Of Section 147 Of The Act By Recording The Following Reasons:-
For Appellant: Shri P.C. Yadav, AdvocateFor Respondent: Shri Prakash Dubey, Sr.DR
Section 131Section 131(1)(d)Section 132Section 132(4)Section 143(1)Section 147Section 148Section 68
…nce it is case of borrowed satisfaction. Otherwise the AO would not have made incorrect observations and relied on the past events to assume the sanctity of future transactions. For the above proposition, he relied on the following decisions:- (a) G&G Pharma- 384 ITR 147(Del); & (b) CIT v. Smt. Pramjit Kaur (2009) 311 ITR 38 (P&H). 10. The ld. Counsel for the assessee in yet another plank of argument submitted that the date of reasons recorded, the date of sanction and the date of issuance of notice coupled with factual inaccuracies committed by the AO would prove that ld. CIT has granted the approval in a mech…
