5. PCIT v. Paramount Communication (P.) Ltd. Delhi High Court

392 ITR 444High Court2017#969 most cited

What is 5. PCIT v. Paramount Communication (P.) Ltd. Delhi High Court authority for?

For valid initiation of reassessment proceedings, the Assessing Officer must possess tangible material and apply independent mind to form a 'reason to believe' that income has escaped assessment. Reassessment cannot be based on mere borrowed satisfaction or unverified information without proper scrutiny.

111

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2017 to 2025.

Also referred to as

PCIT v. Paramount Communication · Paramount Communication · section 147 · section 148 · tangible material · reason to believe · application of mind · borrowed satisfaction · bogus LTCG · escaped assessment · entry operator · beyond four years

Also reported as

79 Taxmann.com 409

Sections most often in play

Section 147Section 148Section 68Section 143(3)Section 1961Section 69CSection 133(6)Section 143(1)

Issues it is cited on

section 147(b)section 147(a)non application of mindsection 151(1)approval under section 151beyond four yearsborrowed satisfactionentry operatorpaper companylive linktangible materialbogus ltcg

Judgments citing 5. PCIT v. Paramount Communication (P.) Ltd. Delhi High Court

ACIT Central Circle, Salem vs. Thriveni Earthmovers Pvt. Ltd., Salem

In the result, the appeal filed by the Revenue in ITA

ITA 2282/CHNY/2018[2013-14]Status: DisposedITAT Chennai25 Sept 2019AY 2013-14

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri. M. Srinivasa Rao, IRS, CIT
Section 143(3)Section 148

…Courts. The Hon’ble Gujarat High Court in the case of Jayant Security & Finance Ltd vs. ACIT, (2018) 254 Taxman 81, Hon’ble Rajasthan High Court in the case of Ankit Agrochem (P) Ltd vs. JCIT, 253 Taxman 141, PCIT vs. Paramount Communication P. Ltd, (2017) 392 ITR 444 (Delhi) and Aradhana Estate Pvt. Ltd vs. DCIT (2018) 404 ITR 105 (Guj) had upheld the validity of the reassessment based on the information received from Investigation Wing of the Department, if the Assessing Officer had formed a belief that income escaped assessment based on the information received from the investigation wing, if there is ne…

ACIT Central Circle, Salem vs. Thriveni Earthmovers Pvt. Ltd., Salem

In the result, the appeal filed by the Revenue in ITA

ITA 2281/CHNY/2018[2012-13]Status: DisposedITAT Chennai25 Sept 2019AY 2012-13

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri. M. Srinivasa Rao, IRS, CIT
Section 143(3)Section 148

…Courts. The Hon’ble Gujarat High Court in the case of Jayant Security & Finance Ltd vs. ACIT, (2018) 254 Taxman 81, Hon’ble Rajasthan High Court in the case of Ankit Agrochem (P) Ltd vs. JCIT, 253 Taxman 141, PCIT vs. Paramount Communication P. Ltd, (2017) 392 ITR 444 (Delhi) and Aradhana Estate Pvt. Ltd vs. DCIT (2018) 404 ITR 105 (Guj) had upheld the validity of the reassessment based on the information received from Investigation Wing of the Department, if the Assessing Officer had formed a belief that income escaped assessment based on the information received from the investigation wing, if there is ne…

ACIT Central Circle, Salem vs. Thriveni Earthmovers Pvt. Ltd., Salem

In the result, the appeal filed by the Revenue in ITA

ITA 2280/CHNY/2018[2011-12]Status: DisposedITAT Chennai25 Sept 2019AY 2011-12

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri. M. Srinivasa Rao, IRS, CIT
Section 143(3)Section 148

…Courts. The Hon’ble Gujarat High Court in the case of Jayant Security & Finance Ltd vs. ACIT, (2018) 254 Taxman 81, Hon’ble Rajasthan High Court in the case of Ankit Agrochem (P) Ltd vs. JCIT, 253 Taxman 141, PCIT vs. Paramount Communication P. Ltd, (2017) 392 ITR 444 (Delhi) and Aradhana Estate Pvt. Ltd vs. DCIT (2018) 404 ITR 105 (Guj) had upheld the validity of the reassessment based on the information received from Investigation Wing of the Department, if the Assessing Officer had formed a belief that income escaped assessment based on the information received from the investigation wing, if there is ne…

Magan Behari Lal, Delhi vs. DCIT Circle-16(2), New Delhi

In the result, appeal filed by the assessee is allowed on the point of law

ITA 4558/DEL/2019[2009-10]Status: DisposedITAT Delhi16 Sept 2019AY 2009-10

Bench: Shri N.K. Billaiya, [Assessment Year: 2009-10]

Section 133ASection 143(1)Section 148

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘SMC’ BENCH, NEW DELHI BEFORE SHRI N.K. BILLAIYA, ACCOUNTANT MEMBER, [Assessment Year: 2009-10] Magan Behari Lal, DCIT, S-89, Greater Kailash II, Circle-16(2), C.R. Building, I.P. Estate, New Delhi-110048 New Delhi-110002 PAN-AAQPL1792A Appellant Respondent Assessee by Shri Salil Kapoor, Ms. Ananya Kapoor & Shri Sumit Lal Chandani, Revenue by Shri S.L. Anuragi Date of Hearing 11/09/2019 Date of Pronouncement 16/09/2019 ORDER This appeal by the assessee is preferred against the order of the CIT(A)-6, Delhi, dated 28/03/2019, pertaining to Assessment Year 2009-10. 2.…

Ramdev Mundhra, New Delhi vs. ITO Ward - 55(5), New Delhi

In the result, all the five appeals filed by the respective assessees are allowed

ITA 1722/DEL/2019[2011-12]Status: DisposedITAT Delhi21 Aug 2019AY 2011-12

Bench: Shri R.K. Panda

For Appellant: Shri Kapil Goel, AdvocateFor Respondent: Shri S.L. Anuragi, Sr.DR
Section 10(38)Section 127Section 147Section 148Section 151Section 68Section 69

….” 9. Referring to the decision of the coordinate Bench of the Tribunal in the case of M/s SBS Realtors (P) Ltd. vs. ITO, vide ITA No.7791/Del/2018, order dated 1st April, Hon'ble Delhi High Court in the case of Paramount Communication (P) Ltd., reported in 392 ITR 444, has held that reopening of assessment on the basis of the report of the Investigation Wing is invalid where there is no crucial link between the information made available to the Assessing Officer and the formation of believe of escapement of income. He accordingly submitted that since the reopening of the assessment was made on the basis of so…

Shriya Devi Mundhra, New Delhi vs. ITO Ward 55(5), New Delhi

In the result, all the five appeals filed by the respective assessees are allowed

ITA 1523/DEL/2019[2011-12]Status: DisposedITAT Delhi21 Aug 2019AY 2011-12

Bench: Shri R.K. Panda

For Appellant: Shri Kapil Goel, AdvocateFor Respondent: Shri S.L. Anuragi, Sr.DR
Section 10(38)Section 127Section 147Section 148Section 151Section 68Section 69

….” 9. Referring to the decision of the coordinate Bench of the Tribunal in the case of M/s SBS Realtors (P) Ltd. vs. ITO, vide ITA No.7791/Del/2018, order dated 1st April, Hon'ble Delhi High Court in the case of Paramount Communication (P) Ltd., reported in 392 ITR 444, has held that reopening of assessment on the basis of the report of the Investigation Wing is invalid where there is no crucial link between the information made available to the Assessing Officer and the formation of believe of escapement of income. He accordingly submitted that since the reopening of the assessment was made on the basis of so…

Gopal Chand Mundhra and Sons, New Delhi vs. ITO, Ward-55(5), New Delhi

In the result, all the five appeals filed by the respective assessees are allowed

ITA 1375/DEL/2019[2011-121]Status: DisposedITAT Delhi21 Aug 2019AY 2011-121

Bench: Shri R.K. Panda

For Appellant: Shri Kapil Goel, AdvocateFor Respondent: Shri S.L. Anuragi, Sr.DR
Section 10(38)Section 127Section 147Section 148Section 151Section 68Section 69

….” 9. Referring to the decision of the coordinate Bench of the Tribunal in the case of M/s SBS Realtors (P) Ltd. vs. ITO, vide ITA No.7791/Del/2018, order dated 1st April, Hon'ble Delhi High Court in the case of Paramount Communication (P) Ltd., reported in 392 ITR 444, has held that reopening of assessment on the basis of the report of the Investigation Wing is invalid where there is no crucial link between the information made available to the Assessing Officer and the formation of believe of escapement of income. He accordingly submitted that since the reopening of the assessment was made on the basis of so…

Neelkanth Plywood Pvt. Ltd., New Delhi vs. ITO, Ward- 18(1), New Delhi

In the result, the appeal filed by the assessee is allowed

ITA 6702/DEL/2018[2008-09]Status: DisposedITAT Delhi21 Aug 2019AY 2008-09

Bench: Sh. R. K. Pandaassessment Year: 2008-09 M/S. Neelkanth Plywood Pvt. Income Tax Officer Ltd. C/O Anil Jain Dd & Co. Vs Ward – 18 (1) Chartered Accountants, 611, New Delhi Surya Kiran Building, 19 K. G. Marg, New Delhi-110001 Pan No.Aaacn0805B (Appellant) (Respondent)

Section 133Section 143(1)Section 147Section 148Section 271Section 68

…/[2014] 362 ITR 417 (Delhi) 7. Pranawa Leafin (P) Ltd. Vs. DCIT Bombay High court [2013] 33 taxmann.com 454 (Bomba) /[2013] 215 Taxman 109 (Bombay) (MAG.) 8. PCIT Vs. Paramount Communications (P.) Ltd. Delhi High Court [2017] 79 taxmann.com 409 (Delhi)/[2017] 392 ITR 444 (Delhi). 9. Paramount Communication (P.) Ltd. Vs PCIT Supreme Court 2017-TIQL-253- SC-IT 10. - Amit Polyprints (P.) Ltd. Vs PCIT Gujarat High Court T20181 94 taxmann.com 393 (Gujarat) 11. Aaspas Multimedia Ltd. Vs PCIT Gujarat High Court T20171 83 taxmann.com 82 (Gujarat) 12. Murlibhai Fatandas Sawlani Vs. ITO Gujarat High Court 2016-TIOL-370-…

Damyanti Mundhra, New Delhi vs. ITO Ward-55(5), New Delhi

In the result, all the five appeals filed by the respective assessees are allowed

ITA 1721/DEL/2019[2011-12]Status: DisposedITAT Delhi21 Aug 2019AY 2011-12

Bench: Shri R.K. Panda

For Appellant: Shri Kapil Goel, AdvocateFor Respondent: Shri S.L. Anuragi, Sr.DR
Section 10(38)Section 127Section 147Section 148Section 151Section 68Section 69

….” 9. Referring to the decision of the coordinate Bench of the Tribunal in the case of M/s SBS Realtors (P) Ltd. vs. ITO, vide ITA No.7791/Del/2018, order dated 1st April, Hon'ble Delhi High Court in the case of Paramount Communication (P) Ltd., reported in 392 ITR 444, has held that reopening of assessment on the basis of the report of the Investigation Wing is invalid where there is no crucial link between the information made available to the Assessing Officer and the formation of believe of escapement of income. He accordingly submitted that since the reopening of the assessment was made on the basis of so…

Gopal Chand Mundhra, New Delhi vs. ITO Ward-55(5), New Delhi

In the result, all the five appeals filed by the respective assessees are allowed

ITA 1524/DEL/2019[2011-12]Status: DisposedITAT Delhi21 Aug 2019AY 2011-12

Bench: Shri R.K. Panda

For Appellant: Shri Kapil Goel, AdvocateFor Respondent: Shri S.L. Anuragi, Sr.DR
Section 10(38)Section 127Section 147Section 148Section 151Section 68Section 69

….” 9. Referring to the decision of the coordinate Bench of the Tribunal in the case of M/s SBS Realtors (P) Ltd. vs. ITO, vide ITA No.7791/Del/2018, order dated 1st April, Hon'ble Delhi High Court in the case of Paramount Communication (P) Ltd., reported in 392 ITR 444, has held that reopening of assessment on the basis of the report of the Investigation Wing is invalid where there is no crucial link between the information made available to the Assessing Officer and the formation of believe of escapement of income. He accordingly submitted that since the reopening of the assessment was made on the basis of so…

Rhino Footware Pvt Ltd, New Delhi vs. ITO Ward 2(3), New Delhi

In the result, the appeal of the assessee is allowed

ITA 2009/DEL/2019[2010-11]Status: DisposedITAT Delhi14 Aug 2019AY 2010-11

Bench: Sh. H.S. Sidhuassessment Year: 2011-12

Section 147Section 148

…e do not find any basis for reaching to the conclusion that there was escapement of income by the Assessing Officer. Learned DR has relied upon the decision of Hon'ble Jurisdictional High Court in the case of PCIT Vs. Paramount Communication Pvt.Ltd. – [2017] 392 ITR 444 (Delhi), wherein on the basis of report of the Investigation Wing, Hon'ble Jurisdictional High Court has upheld the issue of notice under Section 148. Their Lordships held as under :- “Held, that having regard to the contents of the notice issued under section 148 of the Income-tax Act, 1961, the findings of the Appellate Tribunal were not susta…

Instyle Infrastructure P.Ltd, New Delhi vs. ITO, Ward-12(3), New Delhi

In the result, the appeal of the assessee is allowed

ITA 1268/DEL/2019[2009-10]Status: DisposedITAT Delhi14 Aug 2019AY 2009-10

Bench: Sh. H.S. Sidhuassessment Year: 2011-12

Section 147Section 148

…e do not find any basis for reaching to the conclusion that there was escapement of income by the Assessing Officer. Learned DR has relied upon the decision of Hon'ble Jurisdictional High Court in the case of PCIT Vs. Paramount Communication Pvt.Ltd. – [2017] 392 ITR 444 (Delhi), wherein on the basis of report of the Investigation Wing, Hon'ble Jurisdictional High Court has upheld the issue of notice under Section 148. Their Lordships held as under :- “Held, that having regard to the contents of the notice issued under section 148 of the Income-tax Act, 1961, the findings of the Appellate Tribunal were not susta…

Luxe Trading and Holding (India) Pvt. Ltd., New Delhi vs. ITO, Ward- 15(4), New Delhi

In the result, the appeal of the assessee is allowed

ITA 6677/DEL/2018[2011-12]Status: DisposedITAT Delhi14 Aug 2019AY 2011-12

Bench: Sh. H.S. Sidhuassessment Year: 2011-12

Section 147Section 148

…e do not find any basis for reaching to the conclusion that there was escapement of income by the Assessing Officer. Learned DR has relied upon the decision of Hon'ble Jurisdictional High Court in the case of PCIT Vs. Paramount Communication Pvt.Ltd. – [2017] 392 ITR 444 (Delhi), wherein on the basis of report of the Investigation Wing, Hon'ble Jurisdictional High Court has upheld the issue of notice under Section 148. Their Lordships held as under :- “Held, that having regard to the contents of the notice issued under section 148 of the Income-tax Act, 1961, the findings of the Appellate Tribunal were not susta…

Sunil Kanayalal Gambani, Mumbai vs. ACIT Cir 2, Kalyan

In the result, the appeal is allowed for statistical purposes

ITA 1179/MUM/2017[2007-08]Status: DisposedITAT Mumbai31 Jul 2019AY 2007-08

Bench: Shri Saktijit Dey () & Shri N.K. Pradhan () Assessment Year: 2007-08

For Appellant: Mr. M. Subramanian, ARFor Respondent: Mr. Chaudhary Arun Kumar Singh, DR
Section 132(4)Section 143(1)Section 143(3)Section 148Section 234A

…ity to cross examine them. 6. Per contra, the Ld. DR files a written submission and relies on the decision in PCIT v. Paramount Communication (P.) Ltd. (2017-TIOL-253-SC- IT), PCIT v. Paramount Communication (P.) Ltd. [2017] 79 taxmann.com 409 (Delhi)/[2017] 392 ITR 444 (Delhi), Indu Lata Rangwala v. DCIT [2017] 80 taxmann.com 102 (Delhi)/[2016] 384 ITR 337 (Delhi)/[2016] 286 CTR 474 (Delhi), Thakorbhai Maganbhai Patel v. ITO [2017] 78 taxmann.com 201 (SC)/[2017] 245 Taxman 333 (SC), Thakorbhai Maganbhai Patel v. ITO [2017] 79 taxmann.com 409 (Delhi)/[2017] 392 ITR 444 (Delhi), Aravali Infrapower Ltd. v. DCIT (2…

DCIT, New Delhi vs. M/S. Senorita Enterprises Pvt. Ltd., New Delhi

ITA 5388/DEL/2015[2007-08]Status: DisposedITAT Delhi26 Jul 2019AY 2007-08

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

For Appellant: Sh. Yogesh Jagia, AdvFor Respondent: Sh. Amit Katoch, Sr. DR
Section 131(1)Section 139(1)Section 143(1)Section 143(2)Section 147Section 148Section 151(2)Section 68

…bogus purchase by assessee received by DRI from CCE which was passed on to revenue authorities was 'tangible material outside record' to initiate valid reassessment proceedings. PCIT Vs Paramount Communication (P.) Ltd.[2017] 79 taxmann.com 409 (Delhi)/r20171 392 ITR 444 (Delhi) where Hon’ble Delhi High Court held that Information regarding bogus purchase by assessee received by DRI from CCE which was passed on to revenue authorities was 'tangible material outside record' to initiate valid reassessment proceedings. 2 Aradhna Estate (P.) Ltd.Vs PCIT [2018] 91 taxmann.com H9 (Gujarat) where Hon’ble Gujarat High Co…

The ITO, Ward-2(3)(8), Surat vs. Shri Yogendraraj U. Singhvi, Surat

In the result, the appeal of the assessee is partly allowed

ITA 79/AHD/2017[2007-08]Status: DisposedITAT Surat25 Jul 2019AY 2007-08

Bench: Shri Bhavnesh Saini & Shri O. P. Meenaआ.अ.सं./I.T.A No.2926/Ahd/2016: िनधा"रण वष"/Assessment Year: 2007-08 Shri Yogendraraj U Singhvi, V. Income Tax Officer, Office No. 103, Ist Floor, H. No. 6/1946-B, Ward- 2(3)(8), Dalagia Street, Mahidharpura Surat Aayakar Bhavan Surat [Pan: Anjps 9745 G] अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं./I.T.A No.79/Ahd/2017: िनधा"रण वष"/Assessment Year: 2007-08 Income Tax Officer, V. Shri Yogendraraj U Singhvi, Ward- 2(3)(8), Office No. 103, Ist Floor, H. No. 6/1946- Aayakar Bhavan Surat B, Dalagia Street, Mahidharpura Surat [Pan: Anjps 9745 G] अपीलाथ" Appellant ""यथ"/Respondent Shri Prakash Jhunjhunwala, C.A. िनधा"रती क" ओर से Assessee By Shri S.R. Meena, Sr. D.R. राज"व क" ओर से Revenue By 24.07.2019 सुनवाई क" तारीख Date Of Hearing 25.07.2019 उ"ोषणा क" तारीख Date Of Pronouncement

Section 143Section 147

…preme Court judgement in the case of Pr. CIT v. Pramamount Communication (P.) Ltd. [2017-TIOL-253- SC-IT] affirming the judgement of Hon`ble Delhi High Court in the case of Pr. CIT v. Paramount Communication (P.) Ltd. [2017] 79 taxmann.com 409 (Delhi) [2017 ] 392 ITR 444 (Delhi) held that Information regarding bogus purchase by assessee received by DRI for CCE which was passed on to the revenue authorities was “tangible material on record “to initiate valid reassessment proceedings. Similarly, learned CIT(D.R.) submitted that the Hon’ble Gujarat High Court in the case of Amit Polyprints (P) Ltd. v. DCIT [2018] 94…

Shri Yogendraraj U.Singhvi, Surat vs. The Income Tax Officer, Ward-2(3)(8), Surat

In the result, the appeal of the assessee is partly allowed

ITA 2926/AHD/2016[2007-08]Status: DisposedITAT Surat25 Jul 2019AY 2007-08

Bench: Shri Bhavnesh Saini & Shri O. P. Meenaआ.अ.सं./I.T.A No.2926/Ahd/2016: िनधा"रण वष"/Assessment Year: 2007-08 Shri Yogendraraj U Singhvi, V. Income Tax Officer, Office No. 103, Ist Floor, H. No. 6/1946-B, Ward- 2(3)(8), Dalagia Street, Mahidharpura Surat Aayakar Bhavan Surat [Pan: Anjps 9745 G] अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं./I.T.A No.79/Ahd/2017: िनधा"रण वष"/Assessment Year: 2007-08 Income Tax Officer, V. Shri Yogendraraj U Singhvi, Ward- 2(3)(8), Office No. 103, Ist Floor, H. No. 6/1946- Aayakar Bhavan Surat B, Dalagia Street, Mahidharpura Surat [Pan: Anjps 9745 G] अपीलाथ" Appellant ""यथ"/Respondent Shri Prakash Jhunjhunwala, C.A. िनधा"रती क" ओर से Assessee By Shri S.R. Meena, Sr. D.R. राज"व क" ओर से Revenue By 24.07.2019 सुनवाई क" तारीख Date Of Hearing 25.07.2019 उ"ोषणा क" तारीख Date Of Pronouncement

Section 143Section 147

…preme Court judgement in the case of Pr. CIT v. Pramamount Communication (P.) Ltd. [2017-TIOL-253- SC-IT] affirming the judgement of Hon`ble Delhi High Court in the case of Pr. CIT v. Paramount Communication (P.) Ltd. [2017] 79 taxmann.com 409 (Delhi) [2017 ] 392 ITR 444 (Delhi) held that Information regarding bogus purchase by assessee received by DRI for CCE which was passed on to the revenue authorities was “tangible material on record “to initiate valid reassessment proceedings. Similarly, learned CIT(D.R.) submitted that the Hon’ble Gujarat High Court in the case of Amit Polyprints (P) Ltd. v. DCIT [2018] 94…

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

In the result, the appeal of the assessee is allowed

ITA 825/DEL/2019[2009-10]Status: DisposedITAT Delhi25 Jul 2019AY 2009-10

Bench: Sh. H.S. Sidhuassessment Year: 2009-10

Section 133(6)Section 147Section 153A

…al on which Assessing Officer records his or her satisfaction has to be 4 communicated to assessee, without mandating disclosure of any specific document. 8. PCIT, Vs Paramount Communication (P.) Ltd. Delhi High Court [20171 79 taxmann.com 409 (Delhi)/r20171 392 ITR 444 (Delhi) Information regarding bogus purchase by assessee received by DRI from CCE which was passed on to revenue authorities was 'tangible material outside record’ to initiate valid reassessment proceedings. 9. Paramount Communication (P.) Ltd. Vs PCIT Supreme Court 2017-TIQL-253- SC-IT SLP of assessee dismissed. Information regarding bogus purch…

The ITO, Ward-2(3)(7), Surat vs. Shri Dipak Banwarilal Agarwal, Surat

In the result, the appeal of the assessee is partly allowed

ITA 3277/AHD/2016[2007-08]Status: DisposedITAT Surat18 Jul 2019AY 2007-08

Bench: Shri H. S. Sidhu & Shri O. P. Meenaआ.अ.सं./I.T.A No.2932 & 3277/Ahd/2016: िनधा"रणवष"/Assessment Year: 2007-08 1. Shri Dipak Banwarilal Agarwal, V. 1. Income Tax Officer, Ward- 103 Devsagar, Dalgiya Street, 2(3)(7), Mahidarpura Surat Surat 2. Shri Dipak Banwarilal Agarwal, Pan:Afppa6178M 103 Devsagar, Dalgiya Street, Mahidarpura Surat 2. Income Tax Officer, Ward- 2(3)(7), Pan:Afppa6178M Surat अपीलाथ" Appellant ""यथ"/Respondent

Section 143Section 147

…upreme Court judgement in the case of Pr. CIT v. Pramamount Communication (P.) Ltd. [2017-TIOL-253-SC-IT] affirming the judgement of Hon`ble Delhi High Court in the case of Pr. CIT v. Paramount Communication (P.) Ltd. [2017] 79 taxmann.com 409 (Delhi) [2017 ] 392 ITR 444 (Delhi) held that Information regarding bogus purchase by assessee received by DRI for CCE which was passed on to the revenue authorities was “tangible material on record “to initiate valid reassessment proceedings. Similarly, learned CIT(D.R.) submitted that the Hon’ble Gujarat High Court in the case of Amit Polyprints (P) Ltd. v. DCIT [2018] 94…

Dipak Banwarilal Agarwal, Surat vs. The Income Tax Officer, Ward-2(3)(7), Surat

In the result, the appeal of the assessee is partly allowed

ITA 2932/AHD/2016[2007-08]Status: DisposedITAT Surat18 Jul 2019AY 2007-08

Bench: Shri H. S. Sidhu & Shri O. P. Meenaआ.अ.सं./I.T.A No.2932 & 3277/Ahd/2016: िनधा"रणवष"/Assessment Year: 2007-08 1. Shri Dipak Banwarilal Agarwal, V. 1. Income Tax Officer, Ward- 103 Devsagar, Dalgiya Street, 2(3)(7), Mahidarpura Surat Surat 2. Shri Dipak Banwarilal Agarwal, Pan:Afppa6178M 103 Devsagar, Dalgiya Street, Mahidarpura Surat 2. Income Tax Officer, Ward- 2(3)(7), Pan:Afppa6178M Surat अपीलाथ" Appellant ""यथ"/Respondent

Section 143Section 147

…upreme Court judgement in the case of Pr. CIT v. Pramamount Communication (P.) Ltd. [2017-TIOL-253-SC-IT] affirming the judgement of Hon`ble Delhi High Court in the case of Pr. CIT v. Paramount Communication (P.) Ltd. [2017] 79 taxmann.com 409 (Delhi) [2017 ] 392 ITR 444 (Delhi) held that Information regarding bogus purchase by assessee received by DRI for CCE which was passed on to the revenue authorities was “tangible material on record “to initiate valid reassessment proceedings. Similarly, learned CIT(D.R.) submitted that the Hon’ble Gujarat High Court in the case of Amit Polyprints (P) Ltd. v. DCIT [2018] 94…