How many judgments cite AGR Investments Ltd. v. Addl. CIT (Del)?

47 judgments on BharatTax cite AGR Investments Ltd. v. Addl. CIT (Del) (333 ITR 146), spanning 2012 to 2025.

Which sections of the Income Tax Act does AGR Investments Ltd. v. Addl. CIT (Del) come up under?

It is most often cited in judgments turning on Section 147, Section 148, Section 143(3), Section 131, Section 133(6), Section 68.

AGR Investments Ltd. v. Addl. CIT (Del)

333 ITR 146High Court2011#2448 most cited

What is AGR Investments Ltd. v. Addl. CIT (Del) authority for?

For initiating reassessment proceedings under Section 147, the Assessing Officer must possess fresh tangible material or specific information, often from the investigation wing, which forms a direct nexus with the reason to believe that income has escaped assessment, demonstrating the application of mind. A prima facie reason, rather than a final verdict, is sufficient to assume jurisdiction for issuing a notice under Section 148.

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2012 to 2025.

Also referred to as

AGR Investments Ltd. · Section 147 · Section 148 · reassessment · reason to believe · tangible material · fresh information · investigation wing information · live link · application of mind · prima facie reason · escaped assessment

Sections most often in play

Section 147 Section 148 Section 143(3)Section 131 Section 133(6)Section 68 Section 144 Section 151

Issues it is cited on

section 2(40)section 147of live link paper company fresh tangible material section 148(2)beyond four years bogus ltcg mere change of opinion price rigging change of opinion section 151(2)

Judgments citing AGR Investments Ltd. v. Addl. CIT (Del)

United Fabricators & Technical Services P.Ltd, New Delhi vs. ACIT Circle-27(1), New Delhi

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

ITA 2193/DEL/2019[2010-11]Status: DisposedITAT Delhi28 Mar 2022AY 2010-11

Bench: Sh. R. K. Pandaita No. 2193/Del/2019 : Asstt. Year : 2010-11 United Fabricators & Technical Vs Acit, Services Pvt. Ltd., B-15, Suvidha Circle-27(1), Apartment, Sector-13, Rohini, New Delhi-110002 New Delhi-110085 (Appellant) (Respondent) Pan No. Aaacu8110F Assessee By : None Revenue By : Sh. Om Prakash, Sr. Dr Date Of Hearing: 28.03.2022 Date Of Pronouncement: 28.03.2022

For Appellant: NoneFor Respondent: Sh. Om Prakash, Sr. DR

Section 143(1)Section 147Section 148Section 37Section 40A

…received from Investigation Wing. Whether information received from Investigation Wing can be a basis for reopening the assessment proceedings or not, has been answered by Hon'ble jurisdictional High Court in the case AGR Investment Ltd. vs. Addl. CIT & Anr. 333 ITR 146, wherein it was held that the 'specific information received from the office of the Directorate of Investigation as regards the transactions entered into by the assessee with a number of concerns which had made accommodation entries and they were not genuine transactions, was neither a change of opinion nor did it convey a particular interpretati…

Jai Jagannath Mover P. Ltd., Kolkata vs. I.T.O., Ward-11(4), Kolkata

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 206/KOL/2020[2009-10]Status: DisposedITAT Kolkata18 Feb 2022AY 2009-10

Bench: Shri A. T. Varkey, Jm]

Section 147

…. v. Dy. CIT [2012] 27 taxmann.com 200/346 ITR 207 (Guj.), ITO v. Selected Dalurband Coal Co. (P.) Ltd. [1996] 217 ITR 597 (SC), Rattan Gupta v. Union of India [1998] 234 ITR 220 (Delhi), AGR Investment Ltd. v. Addl. CIT [2011] 9 taxmann.com 62/197 Taxman 177/333 ITR 146 (Delhi), Raymond Wollen Mills Ltd. v. ITO [1999] 236 ITR 34 (SC) and Asstt. CIT v. Rajesh Jhaveri Stock Brokers (P.) Ltd. [2007] 161 Taxman 316/291 ITR 500 (SC), cited by learned Counsel for the revenue, bear on the aspect of sufficiency or otherwise of the material used for formation of belief. These judgments make it clear that what can be subm…

Intime Realty Pvt. Ltd., Mumbai vs. DCIT- CC 3(4), Mumbai

In the result, appeal of the assessee in ITA No

ITA 6357/MUM/2019[2010-11]Status: DisposedITAT Mumbai06 Dec 2021AY 2010-11

Section 133ASection 139Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 151(1)

…der:-  “Sterlite Industries(lndia) Ltd. V/s. ACIT (MAD) (302 ITR 275) where it was held that information from Enforcement Directorate showing possible inflation of purchases ' notice issued u/s.148 valid'.  In AGR Investment Ltd. v/s, Addl.CIT & Anr.(Del) (333 ITR 146)  Shalimar Buildcon (P) Ltd. Vs ITO ITAT Jaipur (136 TTJ 701) wherein it was held that information from investigation Wing ' notice u/s. 148 issued on the basis of such letter'.” 7 M/s. Intime Realty P. Ltd., 5.3. We find that the reopening in the instant case has been made beyond four years from the end of the relevant assessment year which…

Sastvijay Investment & Consultancy Services P.Ltd, New Delhi vs. ITO, Ward-22(4), New Delhi

In the result, both the appeals filed by the assessee are allowed

ITA 901/DEL/2019[2010-11]Status: DisposedITAT Delhi10 Nov 2021AY 2010-11

Bench: Shri R.K. Panda & Shri Vijay Pal Rao

For Appellant: Shri Amol Sinha &For Respondent: Shri Prakash Dubey, Sr. DR

Section 132Section 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 68

…or forming the belief that the income of Rs. 32,50,000/- has escaped the assessment in the case of appellant. Whether information received from or not, has been answered by Hon'ble jurisdictional High Court in the case AGR Investment Ltd. vs. Addl. CIT & Anr. 333 ITR 146, wherein on the similar facts, it was held that the 'specific information received from the office of the Directorate of Investigation as regards the transactions entered into by the assessee with a number of concerns which had made accommodation entries and they were not genuine transactions, was neither a change of opinion nor did it convey a p…

Jsk Industries Private Limited, Mumbai vs. DCIT CC-8(1), Mumbai

ITA 5891/MUM/2019[2010-11]Status: DisposedITAT Mumbai28 Oct 2021AY 2010-11

Bench: Shri Rajesh Kumar & Shri Amarjit Singh

Section 147Section 68

…ormation contained in the letter could form the basis for forming an opinion that there was reason to believe that income had escaped assessment without any further verification. 8.25 In AGR Investment Ltd. v. Addl. CIT [2011] 9 taxmann.com 62/197 Taxman 177/333 ITR 146 (Delhi), in a challenge to the initiation of proceedings under Section 147 of the Act, the Delhi High Court held that specific information received from the office of Director of Income Tax (Investigation) regarding transactions entered into by the assessee Company for accommodation entries is not a change of opinion and is material for the AO ha…

Sarita Dudheria, Bangalore vs. Deputy Commissioner of Income Tax, Bangalore

In the result appeal filed by assessee stands partly allowed

ITA 723/BANG/2016[2010-11]Status: DisposedITAT Bangalore06 Nov 2020AY 2010-11

Bench: Shri A. K. Garodia & Smt. Beena Pillaiassessment Years : 2010 – 11

For Appellant: Shri.KR.Pradeep CA along with Smt.Girija G.P.CAFor Respondent: Shri.Priyadarshi Mishra

Section 131Section 132Section 132(4)Section 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 234A

…ry while you and cannot be discarded in a summary manner. Ld.Sr.DR placed reliance on following decisions: • Decision by Hon’ble Supreme Court in Bannalal Jat Constructions (P.) Ltd vs. ACIT reported in (2019) 106 taxmann.com. • AGR investment Ltd reported in 333 ITR 146 (DEL) • Safetage International India (P) Ltd reported in 332 ITR 622 (del) • Mobius India Ltd (Mad) in WP No. 3354 and 3355 of 2015 by order dated 04/08/2015 Page 12 of 16 ITA No.732/Bang/2016 Asst.Yr:2010-11 • Senate vs DCIT reported in (2016) 68 Taxmann.com 223 (Bang) • Rameshchandra and Co vs CIT reported in (1987) 35 taxman 153 (BOM) • Kunh…

ITO 15 (2)(2), Mumbai vs. M/S Limbo Engineering P Ltd., Mumbai

In the result the all the three appeals of the revenue are dismissed

ITA 7277/MUM/2019[2013-14]Status: DisposedITAT Mumbai29 Oct 2020AY 2013-14

Bench: Shri Rajesh Kumar & Shri Ram Lal Negiassessment Year : 2011-12

For Appellant: Shri Neel Khandelwal &For Respondent: Dr Rajeev Harit&Shri J. Micheal, D.R

Section 143(1)Section 143(3)Section 147Section 148Section 148(2)

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “A”, MUMBAI BEFORE SHRI RAJESH KUMAR, ACCOUNTANT MEMBER AND SHRI RAM LAL NEGI, JUDICIAL MEMBER Assessment Year : 2011-12 Income Tax Officer- M/s. Limbo Engineering 15(2)(1), P. Ltd., Room No.357, B-60/B, Stations Plaza, 3rd Flr, Vs. Station Road, Aayakar Bhavan, Bhandup (W), M.K. Road, Mumbai – 400 078 Marine Lines, PAN: AABCL 9224B Mumbai - 400020 (Appellant) (Respondent) ITA Nos.7276 & 7277/M/2019 Assessment Years: 2012-13 & 2013-14 Income Tax Officer- M/s. Limbo Engineering 15(2)(2), P. Ltd., R.No.15B, Gr. Flr, B-60/B, Stations Plaza, Vs. Aayakar Bhavan,…

DCIT Central Circle-7(4), Mumbai vs. M/S Wellknown Polysters Ltd., Mumbai

In the result the all the three appeals of the revenue are dismissed

ITA 1388/MUM/2019[2014-15]Status: DisposedITAT Mumbai29 Oct 2020AY 2014-15

Bench: Shri Rajesh Kumar & Shri Ram Lal Negiassessment Year : 2011-12

For Appellant: Shri Neel Khandelwal &For Respondent: Dr Rajeev Harit&Shri J. Micheal, D.R

Section 143(1)Section 143(3)Section 147Section 148Section 148(2)

ITO 15 (2)(2), Mumbai vs. M/S Limbo Engineering P Ltd., Mumbai

In the result the all the three appeals of the revenue are dismissed

ITA 7276/MUM/2019[2012-13]Status: DisposedITAT Mumbai29 Oct 2020AY 2012-13

Bench: Shri Rajesh Kumar & Shri Ram Lal Negiassessment Year : 2011-12

For Appellant: Shri Neel Khandelwal &For Respondent: Dr Rajeev Harit&Shri J. Micheal, D.R

Section 143(1)Section 143(3)Section 147Section 148Section 148(2)

Seawood Hospitality & Realty Pvt. Ltd., Mumbai vs. DCIT (CC) 3 (4), Mumbai

The appeals of the assessee are allowed on the legal aspect of quashing of reopening of assessment

ITA 92/MUM/2019[2010-11]Status: DisposedITAT Mumbai28 Oct 2020AY 2010-11

Bench: Shri Justice P P Bhatt & Shri M.Balaganesh, Am M/S. Seawoods Hospitality & Vs. Dcit(Cc)-3(4), Mumbai Realty Pvt. Ltd., Central Circle – 3(4) Room No.1915, 19Th Floor B/306-309, Business Dynasty Park Air India Building Jb Nagar, Opp. Sangam Cinema, Nariman Point Andheri (E) Mumbai – 400 021 Mumbai – 400 059 Pan/Gir No.Aamcs1472M (Appellant) .. (Respondent) & M/S. Sukaniya Properties Pvt. Ltd., Vs. Dcit (Cc)-3(4), B/306-309, Business Dynasty Mumbai Park, J B Nagar, Opp. Sangam Central Circle-3(4) Room No.1915, 19Th Floor Cinema, Andheri (E), Mumbai – 400 059 Air India Building Nariman Point Mumbai-400021 Pan/Gir No. Aadcs9585J (Appellant) .. (Respondent) M/S. Seawood Hospitaly & Realty P. Ltd. & M/S. Sukaniya Properties P. Ltd.

Section 132Section 133ASection 143(1)Section 143(2)Section 143(3)Section 148Section 151(1)Section 68

…ITR 275 wherein it was held that information from Enforcement Directorate showing inflation of purchases could be a good ground for issuing notice u/s.148 of the Act. e. Decision of the Hon’ble Delhi High Court in the case of AGR Investment Ltd., reported in 333 ITR 146 and the decision of Jaipur Bench in the case of Shalimar Buildcon 136 TTJ 701 wherein it was held that the notice u/s.148 of the Act could be issued based on information from Investigation Wing about tainted transactions carried out by the assessee. M/s. Seawood Hospitaly and Realty P. Ltd., & M/s. Sukaniya Properties P. Ltd., 5.11. We find that…

Ashapura Minechem Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Central Circle 3(3), Mumbai

In the result, the appeal is allowed

ITA 6974/MUM/2017[2011-12]Status: DisposedITAT Mumbai27 May 2020AY 2011-12

Bench: Us Is A Listed Public Limited Company Engaged In The Business Of Mining Bauxite & Selling The Same In Domestic As Well As International Market. The Assessee Had Filed An Income Tax Return Disclosing Total Loss Of Rs 509.11 Crores Whereas The Assessment Under

Section 143(3)Section 155J

Arun Kumar Dalmia HUF, Mumbai vs. Income Tax Officer-12(3)(4), Mumbai

In the result, the appeal is partly allowed

ITA 6546/MUM/2018[2006-07]Status: DisposedITAT Mumbai16 Dec 2019AY 2006-07

Bench: Shri Saktijit Dey () & Shri N.K. Pradhan () Assessment Year: 2006-07 Arun Kumar Dalmia Huf Income Tax Officer-12(3)(4), 1010, Maker Chambers V, Vs. Aayakar Bhavan, M.K. Road, Nariman Point, Mumbai- Churchgate, Mumbai-400020. 400021. Pan No. Aaeha0173J Appellant Respondent

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Smt. Jothilakshmi Nayak, Sr. DR

Section 133(6)Section 143(1)Section 143(3)Section 148Section 68

…r Joint/Additional Commissioner has applied his mind is not warranted at the appellate stage, (ii) reopening done u/s 148 is valid in view of the decision in Sterlite Industries (Delhi) Ltd. v. ACIT 302 ITR 275 (Mad) and AGR Investments Ltd. v. Additional CIT 333 ITR 146 (Delhi), (iii) there was no response by M/s Basant Marketing Pvt. Ltd. to the notice u/s 133(6) issued by the AO. On the basis of the above facts, the Ld. CIT(A) confirmed the addition of Rs.8,06,000/- made by the AO u/s 68 of the Act. 5. Before us, the Ld. counsel for the assessee files a Paper Book containing documents and certifies that those…

Surinder Kumar & Sons HUF, New Delhi vs. ITO, New Delhi

In the result, the appeal of the assessee is dismissed

ITA 890/DEL/2012[2000-01]Status: DisposedITAT Delhi09 Dec 2019AY 2000-01

Bench: Shri Amit Shukla & Shri B.R.R Kumar

For Appellant: Shri V. Raj Kumar, AdvFor Respondent: Shri S.S. Rana, CIT-D.R

Section 147Section 148Section 149Section 151Section 68Section 68oSection 69Section 69A

…n from the Investigation Wing relating to the assessee and based on application of mind Assessing Officer has reopened the assessment. In support, he relied upon the judgment of Hon’ble Delhi High Court in the case of AGR Investment Ltd. vs. Addl. CIT, (2011) 333 ITR 146 (Del). On the issue of cross-examination also he held that nowhere assessee had produced any material to prove that assessee has requested the Assessing Officer for cross-examination or asked for the reasons recorded. On merits, after detailed discussion and relying upon the various judgments he has confirmed the addition. However, he held that t…

Time Media & Entertainment LLP (Earlier Time Media & Entertainment Private Limited), Mumbai vs. Income Tax Officer 16(1)(5), Mumbai

In the result, the appeal of the assessee in ITA no

ITA 6534/MUM/2017[2010-11]Status: DisposedITAT Mumbai18 Jun 2019AY 2010-11

Bench: Shri Sandeep Gosain & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.6534/Mum/2017 (नििाारण वर्ा / Assessment Year: 2010-11) बिाम/ Time Media & Income Tax Officer- Entertainment Llp (Earlier 16(1)(5) Time Media & R.No. 439, 4 Th Floor, V. Entertainment Private Aayakar Bhavan, Ltd.) M.K Marg, 104, Rachna, V.P Road, Mumbai-400020 Vile Parle (W), Mumbai-400056 स्थायी ऱेखा सं./ Pan: Aaact1581C (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) .. Assessee By: Shri. Reepal G. Tralshawala Revenue By: Shri. D.G. Pansari (Dr) सुनवाई की तारीख /Date Of Hearing : 28.03.2019 घोषणा की तारीख /Date Of Pronouncement : 18.06.2019 आदेश / O R D E R Per Ramit Kochar: This Appeal, Filed By Assessee, Being Ita No. 6534/Mum/2017, Is Directed Against Appellate Order Dated 31.07.2017, Passed By Learned Commissioner Of Income Tax (Appeals)-4, Mumbai (Hereinafter Called “The Cit(A)”) In Appeal No. Cit(A)-4/It-89/Ito-16(1)(5)/2016-17, For Assessment Year 2010-11, The Appellate Proceedings Had Arisen Before Learned Cit(A) From The Assessment Order Dated 30.03.2016 Passed By Learned Assessing Officer (Hereinafter Called “The Ao”) U/S 143(3) R.W.S. 147 Of The Income-Tax Act, 1961 (Hereinafter Called “The Act”) For Ay 2010-11. I.T.A. No.6534/Mum/2017

For Appellant: Shri. Reepal G. TralshawalaFor Respondent: Shri. D.G. Pansari (DR)

Section 143(1)Section 143(2)Section 143(3)

…othing to indicate that the information collected did not pertain to or was not concerned with the persons referred to. The respondent made his own inferences on the basis thereof. 24. In AGR Investment Ltd. v. Addl. CIT [2011] 9 taxmann.com 62/197 Taxman 177/333 ITR 146 (Delhi), relied upon by Mr. Putney, in a challenge to the initiation of proceedings under Section 147 of the Act, the Delhi High Court held that specific information received from the office of Director of Income Tax (Investigation) regarding transactions entered into by the assessee Company for accommodation entries is not a change of opinion an…

Sanjay Sureshchandra Shah, Pune vs. Income-Tax Officer, Ward - 14(3), Pune

In the result, the appeal is partly allowed for statistical

ITA 6/PUN/2019[2010-11]Status: DisposedITAT Pune20 Mar 2019AY 2010-11

Bench: Shri R.S. Syalआयकर अपील सं. / Ita No.06/Pun/2019 िनधा"रण वष" / Assessment Year : 2010-11

Section 133ASection 147Section 148

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “SMC”, PUNE BEFORE SHRI R.S. SYAL, VICE PRESIDENT आयकर अपील सं. / ITA No.06/PUN/2019 िनधा"रण वष" / Assessment Year : 2010-11 Shri Sanjay Sureshchandra Shah, ITO, Ward-14(3), Vs. 10, Radhika Vaibhav, Pune S.No.77, Jagtap Nagar, Wanwadi, Pune PAN : AIAPS4805R (Appellant) (Respondent) Appellant by Shri Rajiv Thakkar Respondent by Shri Rajesh Gawli Date of hearing 20-03-2019 Date of pronouncement 20-03-2019 आदेश / ORDER PER R.S.SYAL, VP : This appeal by the assessee is directed against the order passed by the CIT(A)-7, Pune on 05-11-2018 in relation to the assessme…

Income Tax Officer-10(1)(2), Mumbai vs. Idm Agro Bio Tech Limited, Mumbai

Appeal is dismissed

ITA 5805/MUM/2017[2008-09]Status: DisposedITAT Mumbai04 Dec 2017AY 2008-09

Bench: Shri Shamim Yahyaआयकर अपील सं./I.T.A. No. 5805/Mum/2017 ("नधा"रण वष" / Assessment Year: 2008-09) Ito-10(1)(2), Idm Agro Bio Tech Ltd. Room No. 25, Aayakar Bhavan, A/45, Nandjyot Industrial Estate, बनाम/ Ground Floor, M. K. Road, Safed Pool, Sakinaka, Andheri Vs. Mumbai-400 020 Kurla Road, Andheri (E), Mumbai-400 072 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. Aabc 17012 C (Revenue) : (Assessee) ""या"ेप सं./C.O. No. 260/Mum/2017 (Arising Out Of Ita No. 5805/Mum/2017) ("नधा"रण वष" / Assessment Year: 2008-09) Idm Agro Bio Tech Ltd. Ito-10(1)(2), A/45, Nandjyot Industrial Estate, Room No. 25, Aayakar Bhavan, बनाम/ Safed Pool, Sakinaka, Andheri Kurla Ground Floor, M. K. Road, Vs. Road, Andheri (E), Mumbai-400 020 Mumbai-400 072 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. Aabc 17012 C (Assessee) : (Revenue) : Shri N. Hemalatha Revenue By Assessee By : Dr. P. Daniel सुनवाई क" तार"ख / : 15.11.2017 Date Of Hearing घोषणा क" तार"ख / : 04.12.2017 Date Of Pronouncement

For Appellant: Dr. P. Daniel

Section 131Section 143(1)Section 143(2)Section 147Section 148Section 68

…howing possible inflation of purchases- notice issued u/s 148 valid. (Sterlite Industries (India) Ltd vs ACIT (Mad) 302 ITR 275 • Information from Investigation Wing- notice 148 issued on the basis of such letter is valid. AGR Investment Ltd vsAddl. CIT (Del) 333 ITR 146 Shafcnar Buucon P LW Vs ITO (ITAT. Jaipur) 136 TTJ 701 It is important to point out that there was no assessment or reassessment prior to issuance of notice u/s. 148. It is a settled legal proposition that in a case where, no assessment or reassessment prior to re-opening of the assessment, even if all the material facts are disclosed in the retu…

DCIT 1(2)(2), Mumbai vs. Parth Chem Imepx P.Ltd, Mumbai

Accordingly 9.The appeal of the Revenue in ITA no. 2952/Mum/2017 for AY 2009-10 is allowed for the statistical purposes

ITA 2953/MUM/2017[2011-12]Status: DisposedITAT Mumbai29 Sept 2017AY 2011-12

Bench: Shri Joginder Singh & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No. 2952/Mum/2017 (नििाारण वर्ा / Assessment Year : 2009-10)

For Appellant: Shri Satya Prakash SinghFor Respondent: Shri M.C. Omi Ningshen ,DR

Section 131Section 143(3)

…ent proceedings is correct and justified. Further till date the assessee has not able to produce the parties to prove the genuineness of the transaction. The Hon'ble Delhi High Court in the case of AGR Investment Ltd. vs. Additional commissioner of income tax 333 ITR 146 has held as under: " Reassessment-Notice under s. 148 -Maintainability of writ- There was specific information from the office of the Director of IT (Inv.) as regards transactions entered into by the assessee company with several concerns which had given accommodation entries and that they were not genuine transactions-Same constituted fresh inf…

DCIT 1(2)(2), Mumbai vs. Parth Chem Imepx P.Ltd, Mumbai

Accordingly 9.The appeal of the Revenue in ITA no. 2952/Mum/2017 for AY 2009-10 is allowed for the statistical purposes

ITA 2952/MUM/2017[2009-10]Status: DisposedITAT Mumbai29 Sept 2017AY 2009-10

Bench: Shri Joginder Singh & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No. 2952/Mum/2017 (नििाारण वर्ा / Assessment Year : 2009-10)

For Appellant: Shri Satya Prakash SinghFor Respondent: Shri M.C. Omi Ningshen ,DR

Section 131Section 143(3)

M/S Grand Slam Pvt. Ltd., New Delhi vs. ITO, New Delhi

In the result, the appeal of the assessee is allowed partly for statistical purpose

ITA 1791/DEL/2013[2003-04]Status: DisposedITAT Delhi09 Jun 2017AY 2003-04

Bench: Sh. I.C. Sudhir & Sh. O.P. Kantassessment Year: 2003-04

Section 131Section 13aSection 143(1)Section 143(2)Section 147Section 148Section 68

…be recorded by the Assessing Officer. Recording of reasons is for initiation of the reassessment proceedings, which is the starting point. Referring to the said aspect in AGR Investment Limited versus Additional Commissioner of Income Tax and Another, (2011) 333 ITR 146 (Del.), it has been observed that the phrase "reasons to believe" would mean the cause or justification for the 25 Assessing Officer to know or suppose that income had escaped assessment. It does not mean that the Assessing Officer should have finally ascertained the fact by legal evidence or conclusion. At that stage, the final outcome of the pr…

Kailashpati Overseas Pvt. Ltd., Delhi vs. ITO, New Delhi

In the result, the appeal is allowed for statistical purposes

ITA 1033/DEL/2013[2003-04]Status: DisposedITAT Delhi31 May 2017AY 2003-04

Bench: Shri R.S. Syal, Vice-Assessment Year : 2003-04 Kailashpati Overseas Pvt. Ltd., Vs. Ito, C/O Kapil Goel, Advocate, Ward 5(1), A-1/25, Sector-15, Rohini, New Delhi. Delhi. Pan : Aaack1244M

For Appellant: Shri Kapil Goel &For Respondent: Ms Bedobani, DR

Section 131Section 133(6)Section 142(1)Section 148Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH : SMC : NEW DELHI BEFORE SHRI R.S. SYAL, VICE- PRESIDENT Assessment Year : 2003-04 Kailashpati Overseas Pvt. Ltd., Vs. ITO, C/o Kapil Goel, Advocate, Ward 5(1), A-1/25, Sector-15, Rohini, New Delhi. Delhi. PAN : AAACK1244M (Appellant) (Respondent) Appellant by : Shri Kapil Goel & Shri Mukul Gupta, Advocates Respondent by: Ms Bedobani, DR Date of Hearing : 30.05.2017 Date of Pronouncement: 31.05.2017 ORDER This appeal by the assessee is directed against the order passed by the CIT(A) on 17.01.2013 in relation to the assessment year 2003-04. 2. It is a recalled m…