394 ITR 146 (Guj.) 2. Varshaben S. Patel v. ITO

338 ITR 51High Court2011#263 most cited

What is 394 ITR 146 (Guj.) 2. Varshaben S. Patel v. ITO authority for?

Reasons for reopening an assessment must be specific and not vague, scanty, or based on borrowed satisfaction. The Assessing Officer must quantify the escaped income.

295

judgments rely on this decision, according to BharatTax’s citation analysis of 367,181 Indian tax judgments — from 2012 to 2026.

Also referred to as

Varshaben S. Patel v. ITO · section 147 · section 148 · reassessment notice · vague reasons · borrowed satisfaction · escaped income

Sections most often in play

Section 147Section 148Section 143(3)Section 68Section 133(6)Section 142(1)Section 143(1)Section 151

Issues it is cited on

undisclosed foreign income and assetssection 149(1)(c)section 4(2)section 201(3)section 158basection 150unexplained jewellerysection 70beyond four yearssection 18section 149(1)(b)statement under section 132(4)

Judgments citing 394 ITR 146 (Guj.) 2. Varshaben S. Patel v. ITO

Smt. Radhika Roy, New Delhi vs. DCIT, New Delhi

ITA 2019/DEL/2017[2009-10]Status: DisposedITAT Delhi14 Jun 2019AY 2009-10

Bench: Shri Beena A Pillai & Shri Prashant Maharishi

For Appellant: Shri Sachit Jolly, AdvFor Respondent: Shri Girish Dave, Adv
Section 147Section 148

…but legal advice for initiating the reassessment proceedings, which is not permitted under the law. 19. He relied upon the decision of the honourable Delhi High Court in case of Meenakshi overseas Ltd (395 ITR 677) and Signature Hotels Pvt. Ltd. v. ITO [2011] 338 ITR 51 (Delhi) to show that there is no application of mind by the learned assessing officer, nothing more than DDIT report is recorded in the reasons. He further referred to the decision of CIT V Atul Jain 299 ITR 383 and submitted that there should be a live link between the reasons recorded. He further submitted that though the assessment is concluded…

Vijay Aggarwal, Delhi vs. ITO, Ward- 48(5), New Delhi

In the result, all the appeals of different assessees are partly allowed

ITA 1077/DEL/2019[2010-11]Status: DisposedITAT Delhi30 May 2019AY 2010-11

Bench: : Shri Bhavnesh Saini & Shri L.P. Sahuassessment Year: 2010-11

Section 147Section 148Section 56(2)(vii)Section 68

…In the Income-Tax Appellate Tribunal, Delhi Bench ‘A’, New Delhi Before : Shri Bhavnesh Saini, Judicial Member And Shri L.P. Sahu, Accountant Member Assessment Year: 2010-11 Shri Vijay Agarwal, C-169, vs. Income-tax Officer, Pushpanjali enclave, Pritampura, Ward 48(5), New Delhi Delhi (PAN- AFSPA8080P) (Appellant) (Respondent) Assessment Year: 2010-11 Shri Raj Gupta, C-169, Pushpanjali vs. Income-tax Officer, enclave, Pritampura, Delhi Ward 48(5), New Delhi (PAN- AGSOG2661F) (Appellant) (Respondent) Assessment Year: 2010-11 Smt. Sheela Devi, 1756, Nai Basti vs. Income-tax Officer, Naya Bazar, Delhi Ward 47…

Ratan Pal Kain, Ghaziabad vs. ITO, Ward- 2(2), Ghaziabad

In the result, appeal filed by the assessee is allowed

ITA 1273/DEL/2018[2009-10]Status: DisposedITAT Delhi22 May 2019AY 2009-10

Bench: Sh. N. K. Billaiya

For Appellant: Sh. Akhilesh Kumar, AdvocateFor Respondent: Sh. S. L. Anuragi, Sr. DR
Section 148

…learly shows, according to him, that there is no enquiry made by the Assessing Officer. He, therefore, submitted that the issue is squarely covered in favour of the assessee by the decision of the Hon'ble Delhi High Court in Signature Hotels Pvt. Ltd. Vs. ITO 338 ITR 51 (Del.); (ii) He further stated that satisfaction recorded by the approving authority has merely mentioned "Yes". He submitted that such satisfaction without any reasoning is incorrect. He referred to the 8 ITA No.-1273/Del/2018 decision of the Hon'ble M.P. High Court in CIT Vs. S. Goyanka Lime and Chemical Ltd. 56 taxman.com 390 (MP). He further…

Lakshya Ice & Cold Storage P Ltd, Aligarh vs. ITO Ward 1(5), Aligarh

In the result, by the assessee is allowed

ITA 124/AGR/2018[2010-11]Status: DisposedITAT Agra16 May 2019AY 2010-11

Bench: Shri Sudhanshu Srivastava & Dr. Mitha Lal Meenam/S Lakshya Ice & Cold Storage Pvt. Ltd. Vs.. Income Tax Officer, Goyal Bhawan, Opp. Maheshwari Inter Ward 1(5), Aligarh College, Sasni Gate, Bye Pass Road, Aligarh (Pan: Aabcl5656R) (Respondent) (Appellant)

For Appellant: Sh. Pradeep K. Sahgal, Adv. & Sh. Utsav Sahgal, C.AFor Respondent: Shri Waseem Arshad, Sr.DR
Section 147Section 148Section 234BSection 271(1)(c)Section 68

…ssment. In support, the Ld.AR relied on the following authoritative decisions: 1. Principal Commissioner of Income-tax-6 Vs. Meenakshi Overseas (P) Ltd. (2017) 82 taxmann.com 300 (Delhi High Court) 2. Signature Hotels (P.) Ltd. Vs. Income-tax Officer (2011) 338 ITR 51 (High Court of Delhi) 15 3. Principal Commissioner of Income-tax-4 Vs. G & G Pharma India Ltd. (2017) 81 taxmann.com 109 (High Court of Delhi) 4. Principal Commissioner of Income-tax Vs. RMG Polyvinyl (I) Ltd. (2017) 83 taxmann.com 348 (High Court of Delhi) 5. CIT Jallendhar Vs. Smit. Paramjit Kaur (2008) 168 Taxman 39 (High Court of Punjab &…

Varinder Pal Singh, Rampur vs. ITO, W-4, Khanna

In the result, the appeal of the assessee is allowed

ITA 481/CHANDI/2018[2009-10]Status: DisposedITAT Chandigarh24 Apr 2019AY 2009-10

Bench: Shri N.K. Sainiआयकर अपील सं./ Ita No.481/Chd/2018 "नधा"रण वष" / Assessment Year : 2009-10

For Appellant: S/Shri Sudhir Sehgal, advFor Respondent: Shri Manjit Singh, Sr.DR
Section 147Section 148

…the preceding year was accepted by the A.O., so there was no reason to doubt the opening cash in hand and making the addition for the year under consideration. Reliance was placed on the following case law: Signature Hotels P. Ltd. Vs. ITO & Another (2011) 338 ITR 51(Delhi) 12. In his rival submission, the Ld. Sr.DR strongly supported the orders of the authorities below and further submitted that specific information was in the possession of the A.O. on the basis of which the reasons were recorded before issuing the notice u/s 148 of the Act. It was further submitted that the assessee did not file any retu…

DCIT, Rohtak vs. M/S. Kla Food (India) Ltd., New Delhi

In the result Appeal of the Department is dismissed and the cross-objection of the Assessee is allowed

ITA 2846/DEL/2015[2007-08]Status: DisposedITAT Delhi08 Apr 2019AY 2007-08

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Respondent: Smt. Naina Soin Kapil, Sr. D.R
Section 143(3)Section 147Section 148Section 153C

…ave already been framed under section 143(3). Even the nature of the credit is not mentioned in the reasons. No particulars of accommodation entries have been mentioned. He has relied upon decision of Delhi High Court in the case of Signature Hotels (P) Ltd., 338 ITR 51 (Del.) He has submitted that reassessment is initiated on mere suspicion only. He has referred to page-1 of the paper book filed by the Departmental Representative in which the ACIT of the Investigation Wing has directed to issue notice under section 147/148 of the Income Tax Act, 1961 after recording reasons. He has submitted that all the Investo…

DCIT, Rohtak vs. M/S. Param Exim Ltd., New Delhi

In the result Appeal of the Department is dismissed and the cross-objection of the Assessee is allowed

ITA 2845/DEL/2015[2007-08]Status: DisposedITAT Delhi08 Apr 2019AY 2007-08

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Respondent: Smt. Naina Soin Kapil, Sr. D.R
Section 143(3)Section 147Section 148Section 153C

…ave already been framed under section 143(3). Even the nature of the credit is not mentioned in the reasons. No particulars of accommodation entries have been mentioned. He has relied upon decision of Delhi High Court in the case of Signature Hotels (P) Ltd., 338 ITR 51 (Del.) He has submitted that reassessment is initiated on mere suspicion only. He has referred to page-1 of the paper book filed by the Departmental Representative in which the ACIT of the Investigation Wing has directed to issue notice under section 147/148 of the Income Tax Act, 1961 after recording reasons. He has submitted that all the Investo…

Sbs Realtors Pvt. Ltd., New Delhi vs. ITO, Ward-22(4), New Delhi

In the result, the appeal of the assessee is allowed

ITA 7791/DEL/2018[2009-10]Status: DisposedITAT Delhi01 Apr 2019AY 2009-10

Bench: Shri G.D. Agrawal, Before Shri G.D. Agrawal, Vice & And Before Shri Before Shri G.D. Agrawal, G.D. Agrawal, Vice & And Ms. Suchitra Kamble Ms. Suchitra Kamblems. Suchitra Kamble Ms. Suchitra Kamble

For Appellant: Shri Kapil Goel and Shri Rajesh Jain, CAsFor Respondent: Shri S.S. Rana, CIT-DR and Shri Rajesh Kumar, Additional CIT
Section 143(1)Section 143(2)Section 147Section 148Section 151

…ioner is mechanical and without application of any independent mind. In support of his contention, he relied upon the following decisions :- (i) Sarthak Securities Co.P.Ltd. Vs. ITO – [2010] 329 ITR 110 (Delhi). (ii) Signature Hotels P.Ltd. Vs. ITO – [2011] 338 ITR 51 (Delhi). (iii) PCIT Vs. G And G Pharma India Ltd. – [2016] 384 ITR 147 (Delhi). (iv) PCIT Vs. RMG Polyvinyl (I) Ltd. – [2017] 396 ITR 5 (Delhi). (v) PCIT Vs. Meenakshi Overseas Pvt.Ltd. – [2017] 395 ITR 677 (Delhi). 4. Learned DR, on the other hand, stated that it is a case where the original return was accepted under Section 143(1) and there…

Hightech Construction P.Ltdr, New Delhi vs. ITO, Ward-1(3), Faridabad

In the result, both the Appeals of the assessee are partly

ITA 1606/DEL/2019[2012-13]Status: DisposedITAT Delhi22 Mar 2019AY 2012-13

Bench: Shri H.S. Sidhu & Shri L.P. Sahu

For Appellant: SH. KAPIL GOEL, ADVFor Respondent: SH. AMIT KATOCH, SR. DR
Section 133(6)Section 143(2)Section 147Section 148Section 292B

…2017 , we find force in arguments of Ld AR as recorded above. Before testing the arguments of both sides on validity of reopening action, it may be profitable to refer to guiding words of Hon’ble Delhi High Court in case of Signature Hotels as cited by Ld AR (338 ITR 51) on subject of reopening made on basis of allegation of accommodation entry: “5. Before dealing with the facts of the case, we may notice some judgments of the Supreme Court when proceedings under Section 147/148 of the Act can be initiated on statements made by third person on the account of "accommodation entry". In ITO versus Lakhmani Mewal Da…

Hightech Construction P.Ltdr, New Delhi vs. ITO, Ward-1(3), Faridabad

In the result, both the Appeals of the assessee are partly

ITA 1605/DEL/2019[2011-12]Status: DisposedITAT Delhi22 Mar 2019AY 2011-12

Bench: Shri H.S. Sidhu & Shri L.P. Sahu

For Appellant: SH. KAPIL GOEL, ADVFor Respondent: SH. AMIT KATOCH, SR. DR
Section 133(6)Section 143(2)Section 147Section 148Section 292B

…2017 , we find force in arguments of Ld AR as recorded above. Before testing the arguments of both sides on validity of reopening action, it may be profitable to refer to guiding words of Hon’ble Delhi High Court in case of Signature Hotels as cited by Ld AR (338 ITR 51) on subject of reopening made on basis of allegation of accommodation entry: “5. Before dealing with the facts of the case, we may notice some judgments of the Supreme Court when proceedings under Section 147/148 of the Act can be initiated on statements made by third person on the account of "accommodation entry". In ITO versus Lakhmani Mewal Da…

Ppn Properties Pvt. Ltd., Delhi vs. ITO, Ward- 19(2), New Delhi

In the result, the appeals of the assessee are allowed

ITA 3060/DEL/2018[2009-10]Status: DisposedITAT Delhi16 Jan 2019AY 2009-10

Bench: Shri N.S. Sainiassessment Year: 2009-10

Section 131Section 143(3)Section 147Section 148

…d by the assessee to the reopening of the assessment and hence the reopening of assessment initiated by the Assessing Officer was bad in law. 9. He relied on decision of Hon’ble Delhi High Court in the case of Signature Hotels Pvt. Ltd. Vs. ITO & Anr. (2011) 338 ITR 51 (Del) where it was held that that the reassessment proceedings were initiated on the basis of information received from the Director of Income-tax (Investigation) that the petitioner had introduced money amounting to Rs.5 lakhs during financial year 2002-03 as stated in the annexure. According to the information, the amount received from a company…

Prashant Agencies Pvt. Ltd., Delhi vs. ITO, Ward- 19(3), New Delhi

In the result, the appeals of the assessee are allowed

ITA 3059/DEL/2018[2009-10]Status: DisposedITAT Delhi16 Jan 2019AY 2009-10

Bench: Shri N.S. Sainiassessment Year: 2009-10

Section 131Section 143(3)Section 147Section 148

…d by the assessee to the reopening of the assessment and hence the reopening of assessment initiated by the Assessing Officer was bad in law. 9. He relied on decision of Hon’ble Delhi High Court in the case of Signature Hotels Pvt. Ltd. Vs. ITO & Anr. (2011) 338 ITR 51 (Del) where it was held that that the reassessment proceedings were initiated on the basis of information received from the Director of Income-tax (Investigation) that the petitioner had introduced money amounting to Rs.5 lakhs during financial year 2002-03 as stated in the annexure. According to the information, the amount received from a company…

M/S Holy Faith International Pvt. Ltd, Jalandhar vs. The Dy Commissioner of Income Tax, Jalandhar

In the result, the appeal of the assessee is allowed

ITA 181/ASR/2017[2008-09]Status: DisposedITAT Amritsar15 Jan 2019AY 2008-09

Bench: Sh. N. K. Saini, Hon’Ble & Sh. Ravish Soodita No.181/Asr./2017 : Asstt. Year : 2008-09 M/S Holy Faith International Vs Deputy Commissioner Of Income Tax, Pvt. Ltd., Mbd House, Central Circle-Ii, Railway Road, Jalandhar Jalandhar (Appellant) (Respondent) Pan No. Aaach6111J Assessee By : Sh. Sudhir Sehgal, Adv. Revenue By : Sh. Bhawani Shankar, Dr Date Of Hearing : 07.01.2019 Date Of Pronouncement : 15.01.2019 Order Per N. K. Saini: This Is An Appeal By The Assessee Against The Order Dated 20.03.2017 Of Ld. Cit(A)-I, Jalandhar. 2. Following Grounds Have Been Raised In This Appeal: “1. That The Worthy Commissioner Of Income Tax (A)-1, Jalandhar Has Erred In Dismissing The Appeal Filed By The Assessee. 2. That The Ld. Cit(A) Has Erred In Confirming The Contention Of The Assessing Officer In Reopening The Case U/S 148 Of The Income Tax Act And, Thus, Framing Of Assessment U/S 147 R.W.S.143(3)/153C At An Income Of Rs. 4,95,13,441/- Against The Returned Income Of Rs. 4,63,33,441/-. 3. That The Ld. Cit(A) Has Erred In Not Considering That There Was No Reason To Believe That The Income Of The

For Appellant: Sh. Sudhir Sehgal, AdvFor Respondent: Sh. Bhawani Shankar, DR
Section 131Section 132Section 147Section 148Section 153C

…ot justified. The reliance was placed on the following case laws: " Sheo Nath Singh Vs ACIT 82 ITR 0147 (SC) " CIT Vs SFIL Stock Broking Ltd. (2010) 325 ITR 285 (Del.) " Pr. CIT Vs G. G. Pharma India Ltd. 384 ITR 147 (Del.) " Signature Hotels Pvt. Ltd. Vs ITO 338 ITR 51 (Del.) " ITO Vs Narnaudia Financial Services Pvt. Ltd. in ITA No. 4094/Del/2009 " Sh. Chunnilal Prajapati Vs ITO-II in ITA Nos.290 to 295/Luc/2010 " G. N. Shaw (Wine) (P) Ltd. Vs ITO 260 ITR 513 (Cal.) " Sun Pharmaceutical Industries Ltd. Vs DCIT 381 ITR 387 (Del.) " Shaf Broadcast Pvt. Ltd. Vs ACIT in ITA NO. 1819/Mum/2012 " Ashok Kumar Vs ACIT i…

Radiance Stock Traders Pvt. Ltd., Delhi vs. ITO, Ward- 20(4), New Delhi

In the result, the Appeal filed by the Assessee stands allowed

ITA 4542/DEL/2018[2010-11]Status: DisposedITAT Delhi29 Nov 2018AY 2010-11

Bench: Shri H.S. Sidhuassessment Year : 2010-11

For Appellant: Sh. Gautam Jain, Adv. & Sh. LalitFor Respondent: Sh. S.L. Anuragi, Sr. DR
Section 147Section 234BSection 68

…ated 31.8.2016 R.K. Garg Developers (P) Ltd. v. ITO 21. 299 ITR 383 (Del) CIT vs Atul Jain dated 23.5.2007 22. ITR 285 (Del) CIT vs SFIL Stock Broking Ltd. dated 27.4.2010 23. 329 ITR 110 (Del) Sarthak Securities Co. (P) Ltd. vs ITO dated 18 October 2010 24. 338 ITR 51 (Del) Signature Hotels (P) Ltd. vs. ITO dated 21.7.2011 25. ITA No. 1395/2008 (Del) Smt. Meera Kapoor vs. CIT dated 31.8.2012 26. 357 ITR 24 (Del) CIT vs. Suren International (P) Ltd. dated 7.5.2013 27. 357 ITR 330 (Del) CIT vs. Insecticides (India) Ltd. dated 20.5.2013 28. 303 ITR 155 (Del.) CIT vs. Indian Sugar and Gen. Ind. Ex dated 30.07.2007…

M/S. Proficient Commodities Pvt. Ltd., Kolkata vs. DCIT, Circle - 5(1), Kolkata

In the result, both these appeals of the assessee are allowed

ITA 2308/KOL/2017[2011-12]Status: DisposedITAT Kolkata02 Nov 2018AY 2011-12

Bench: Sri J. Sudhakar Reddy & Sri S.S. Viswanethra Ravi]

Section 250

…applying the proposition laid down by the Jurisdictional High Court in G&G Pharma India (supra) we hold that the reopening of assessment is bad in law" 7.3. The Hon'ble Delhi High Court in the case of Signature Hotels (P) Ltd. vs ITO and another, reported in 338 ITR 51 (Delhi) has under similar circumstances held as follows: "For the A.Y. 2003-04, the return of income of the assessee company was accepted u/s 143(1) of the Income-tax Act, 1961 and was not selected for scrutiny. Subsequently, the Assessing Officer issued notice u/s 148 which was objected by the assessee. The Assessing Officer rejected the objectio…

M/S. Proficient Commodities Pvt. Ltd., Kolkata vs. DCIT, Circle - 5(1), Kolkata

In the result, both these appeals of the assessee are allowed

ITA 2307/KOL/2017[2010-11]Status: DisposedITAT Kolkata02 Nov 2018AY 2010-11

Bench: Sri J. Sudhakar Reddy & Sri S.S. Viswanethra Ravi]

Section 250

…applying the proposition laid down by the Jurisdictional High Court in G&G Pharma India (supra) we hold that the reopening of assessment is bad in law" 7.3. The Hon'ble Delhi High Court in the case of Signature Hotels (P) Ltd. vs ITO and another, reported in 338 ITR 51 (Delhi) has under similar circumstances held as follows: "For the A.Y. 2003-04, the return of income of the assessee company was accepted u/s 143(1) of the Income-tax Act, 1961 and was not selected for scrutiny. Subsequently, the Assessing Officer issued notice u/s 148 which was objected by the assessee. The Assessing Officer rejected the objectio…

Sushil Bansal, New Delhi vs. ACIT, Circle- 57(1), New Delhi

In the result, the appeal is dismissed

ITA 4441/DEL/2017[2013-14]Status: DisposedITAT Delhi23 Oct 2018AY 2013-14

Bench: : Shri Amit Shukla & Shri L.P. Sahuassessment Year: 2013-14

Section 132Section 147Section 148Section 151Section 69C

…lowing judgments: • Shri Sai Infrastructure vs. DCIT, W.P. © 2158/2016and W.P.(C) 2383/2016,dt.23.07.2018, Delhi High Court • Pr. CIT vs. Meenakshi Overseas Pvt. Ltd. , ITA 692/2016, dt.26.05.2017, Delhi High Court • Signature Hotels (P) Ltd. vs. ITO (2011) 338 ITR 51 (Del) • Pr. CIT vs. SNG Developers Limited, ITA 92/2017, dt. 12.07.2017, Delhi High Court, SLP dismissed dt. 09.02.2018 11 In the case of Shamshad khan vs. ACIT, W.P.(C) No.11504 of 2016, dt. 11.04.2017, Delhi High Court, on the similar fact situation, observed as under: “6. Having considered the aforesaid contentions, the Court is of the view t…

Rajiv Jain, New Delhi vs. ITO, Ward- 63(2), New Delhi

In the result, both appeals filed by the appellant’s are allowed

ITA 7061/DEL/2017[2007-08]Status: DisposedITAT Delhi27 Sept 2018AY 2007-08

Bench: Shri N. K. Billaiya

For Appellant: Sh. Naveen Kumar Goyal, CAFor Respondent: Sh. Surender Pal, Sr. DR
Section 147Section 148Section 153A

…e to go through the entire gamut of proceedings. It is totally unwarranted. Resultantly, the initiation of proceedings under Section 147 and issuance of notice under Section 148 of the Act are hereby quashed.” 12 In the case of Signature Hotels P Ltd Vs. ITO 338 ITR 51, it has been held as under: The first sentence of the reasons states that information had been received from Director of Income-Tax (Investigation) that the petitioner had introduced money amounting to Rs.5 lacs during financial year 2002-03 as per the details given in W.P. (C) NO. 8067/2010 Page 12 Annexure. The said Annexure, reproduced above,…

M/S. Anjli Metal Overseas Prop. Neeraj Rathore, Delhi vs. ITO, Ward- 63(3), New Delhi

In the result, both appeals filed by the appellant’s are allowed

ITA 7059/DEL/2017[2007-08]Status: DisposedITAT Delhi27 Sept 2018AY 2007-08

Bench: Shri N. K. Billaiya

For Appellant: Sh. Naveen Kumar Goyal, CAFor Respondent: Sh. Surender Pal, Sr. DR
Section 147Section 148Section 153A

…e to go through the entire gamut of proceedings. It is totally unwarranted. Resultantly, the initiation of proceedings under Section 147 and issuance of notice under Section 148 of the Act are hereby quashed.” 12 In the case of Signature Hotels P Ltd Vs. ITO 338 ITR 51, it has been held as under: The first sentence of the reasons states that information had been received from Director of Income-Tax (Investigation) that the petitioner had introduced money amounting to Rs.5 lacs during financial year 2002-03 as per the details given in W.P. (C) NO. 8067/2010 Page 12 Annexure. The said Annexure, reproduced above,…

Ajay Sharma, Delhi vs. ITO, Ward- 35(3), New Delhi

The appeal of the assessee is allowed

ITA 2723/DEL/2018[2010-11]Status: DisposedITAT Delhi26 Sept 2018AY 2010-11

Bench: Shri N. K. Saini & Ms Suchitra Kamblejyoti Engineering Works Vs Ito C/O. Kapil Goel, Advocate, F-26/124, Ward-35(3) Sector-7, Rohini New Delhi Delhi Aadfj9259M (Appellant) (Respondent) Sadhna Sharma Vs Ito C/O. Kapil Goel, Advocate, F-26/124, Ward-35(3) Sectdor-7, New Delhi Rohini, Delhi Aawps0941G (Appellant) (Respondent) Sadhna Sharma Vs Ito C/O. Kapil Goel, Advocate, F-26/124, Ward-35(3) Sectdor-7, New Delhi Rohini, Delhi Aawps0941G (Appellant) (Respondent) Ajay Sharma Vs Ito C/O. Kapil Goel, Advocate, F-26/124, Ward-35(3) Sector-7, New Delhi Rohini, Delhi Abbps7289K (Appellant) (Respondent)

Section 148

…f proceedings. It is 21 ITA No. 2719/Del/2018 & Ors. totally unwarranted. Resultantly, the initiation of proceedings under Section 147 and issuance of notice under Section 148 of the Act are hereby quashed.” 12 In the case of Signature Hotels P Ltd Vs. ITO 338 ITR 51, it has been held as under: The first sentence of the reasons states that information had been received from Director of Income-Tax (Investigation) that the petitioner had introduced money amounting to Rs.5 lacs during financial year 2002-03 as per the details given in W.P. (C) NO. 8067/2010 Page 12 Annexure. The said Annexure, reproduced above,…