8). (v) P.R.Patel v. Dy.CIT

78 ITD 51Income Tax Appellate Tribunal2001#18268 most cited
5

judgments rely on this decision, according to BharatTax’s citation analysis of 348,607 Indian tax judgments — from 2022 to 2024.

Judgments citing 8). (v) P.R.Patel v. Dy.CIT

Income Tax Officer, Ward-1, Ahmednagar vs. Narendra Sampatlal Bafna, Ahmednagar

In the result, the appeal filed by the Revenue and the CO filed by the assessee are dismissed

ITA 688/PUN/2024[2017-18]Status: DisposedITAT Pune19 Aug 2024AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2017-18

For Appellant: Shri Prasad BhandariFor Respondent: Shri Keyur Patel, CIT
Section 1Section 132Section 132(4)Section 143(3)

…tified in making the addition. Even in this case, the issue of no addition can be made on the basis of documents found with third party was not raised. The CIT(A) has further referred to the decision of ITAT, Mumbai in the case of P. R. Patel Vs. DCIT [(2001) 78 ITD 51 (Mum)] for the proposition that seized papers cannot be called dumb paper because they indicate date, amount and calculation. There is no dispute with the above proposition. The papers are found pertaining to Dhariwal Group as admitted by Shri Mehta and therefore, these documents may be relevant for deciding the issue in the case of Dhariwal Group.…

Mangi Lal Kandoi, Jaipur vs. Assistant Commissioner of Income Tax, Central Circle – 2, Jaipur

In the result, appeal of the assessee is partly allowed

ITA 322/JPR/2022[2013-14]Status: DisposedITAT Jaipur13 Oct 2022AY 2013-14
For Appellant: Shri S. L. Poddar, AdvFor Respondent: Smt. Runi Pal, Addl. CIT
Section 127Section 142(1)Section 143(2)Section 245D(4)Section 271A

…ee. (iv) JCIT vs West Bengal Trading Agency, IT(SS) NO.49(Cal) of 2001 There has to be direct or circumstantial material to establish that the intention expressed in the seized document/books has actually been implemented (vide para 8) (v) P.R.Patel v. Dy.CIT 78 ITD 51 (TBOM) No addition can be made on the basis of a seized documents which do not bear the name of assessee. 10. Absent of satisfaction in the assessment order: - 34 Mangi Lal Kandoi, Jaipur vs. ACIT, Jaipur It is submitted that it is established position of law that the Learned Assessing Officer was required to record his satisfaction for initiati…

Mangi Lal Kandoi, Jaipur vs. Assistant Commissioner of Income Tax, Central Circle – 2, Jaipur

In the result, the appeals of the assessee in ITA No

ITA 321/JPR/2022[2012-13]Status: DisposedITAT Jaipur13 Oct 2022AY 2012-13
For Appellant: Shri S.L. Poddar ( Adv.)For Respondent: Ms. Runi Pal (Addl.CIT)a
Section 127Section 153ASection 271(1)(c)

…e. (iv) JCIT vs West Bengal Trading Agency, IT(SS) NO.49(Cal) of 2001 There has to be direct or circumstantial material to establish that the intention expressed in the seized document/books has actually been implemented (vide para 8). (v) P.R.Patel v. Dy.CIT 78 ITD 51 (TBOM) No addition can be made on the basis of a seized documents which do not bear the name of assessee. 5. Finding the of learned CIT(A) – Mangi Lal Kandoi vs. ACIT It is submitted that the learned CIT(A) has confirmed the penalty imposed by the Learned AO on the basis of that in the quantum proceedings the Hon’ble ITAT sustained the addition on…

Mangi Lal Kandoi, Jaipur vs. Assistant Commissioner of Income Tax, Central Circle – 2, Jaipur

In the result, the appeals of the assessee in ITA No

ITA 320/JPR/2022[2011-12]Status: DisposedITAT Jaipur13 Oct 2022AY 2011-12
For Appellant: Shri S.L. Poddar ( Adv.)For Respondent: Ms. Runi Pal (Addl.CIT)a
Section 127Section 153ASection 271(1)(c)

…e. (iv) JCIT vs West Bengal Trading Agency, IT(SS) NO.49(Cal) of 2001 There has to be direct or circumstantial material to establish that the intention expressed in the seized document/books has actually been implemented (vide para 8). (v) P.R.Patel v. Dy.CIT 78 ITD 51 (TBOM) No addition can be made on the basis of a seized documents which do not bear the name of assessee. 5. Finding the of learned CIT(A) – Mangi Lal Kandoi vs. ACIT It is submitted that the learned CIT(A) has confirmed the penalty imposed by the Learned AO on the basis of that in the quantum proceedings the Hon’ble ITAT sustained the addition on…

Mangi Lal Kandoi, Jaipur vs. Assistant Commissioner of Income Tax, Central Circle – 2, Jaipur

In the result, the appeals of the assessee in ITA No

ITA 319/JPR/2022[2010-11]Status: DisposedITAT Jaipur13 Oct 2022AY 2010-11
For Appellant: Shri S.L. Poddar ( Adv.)For Respondent: Ms. Runi Pal (Addl.CIT)a
Section 127Section 153ASection 271(1)(c)

…e. (iv) JCIT vs West Bengal Trading Agency, IT(SS) NO.49(Cal) of 2001 There has to be direct or circumstantial material to establish that the intention expressed in the seized document/books has actually been implemented (vide para 8). (v) P.R.Patel v. Dy.CIT 78 ITD 51 (TBOM) No addition can be made on the basis of a seized documents which do not bear the name of assessee. 5. Finding the of learned CIT(A) – Mangi Lal Kandoi vs. ACIT It is submitted that the learned CIT(A) has confirmed the penalty imposed by the Learned AO on the basis of that in the quantum proceedings the Hon’ble ITAT sustained the addition on…

8). (v) P.R.Patel v. Dy.CIT (78 ITD 51) — Cited in 5 Judgments | BharatTax