All Cargo Global Logistics Ltd. v. DCIT

137 ITD 287Income Tax Appellate Tribunal2012#51 most cited

What is All Cargo Global Logistics Ltd. v. DCIT authority for?

In non-abated assessments, the Assessing Officer can make additions under section 153A based on books of accounts or documents found during a search but not produced during the original assessment, provided such material is incriminating.

907

judgments rely on this decision, according to BharatTax’s citation analysis of 367,164 Indian tax judgments — from 2015 to 2026.

Also referred to as

All Cargo Global Logistics Ltd. v. DCIT · section 153A · section 132 · incriminating material · search and seizure · non-abated assessments · books of accounts · documents not produced · original assessment · ITAT Mumbai

Also reported as

18 ITR (Trib) 10618 ITR 106147 TTJ 51316 Taxmann.com 101

Sections most often in play

Section 153ASection 143(3)Section 147Section 148Section 153DSection 132Section 1961Section 153C

Issues it is cited on

casus omissussection 158b(b)section 153(a)section 158bb(1)deemed dividendsection 2(22)section 153a(1)(b)section 2(22)(e)accumulated profitssection 158bbretracted statementsection 153(1)

Judgments citing All Cargo Global Logistics Ltd. v. DCIT

DCIT- CC- 6(4), Mumbai vs. Smt. Divya Sameer Gehlaut, Mumbai

In the result, the appeal of the Revenue stands dismissed

ITA 1428/MUM/2022[2013-14]Status: DisposedITAT Mumbai31 Oct 2022AY 2013-14

Bench: Shri Aby T. Varkey, Jm & Shri Om Prakash Kant, Am आयकर अपील सं/ I.T.A. No.1428/Mum/2022 (निर्धारण वर्ा / Assessment Year: 2013-14) Deputy Commissioner Of Income बिधम/ Smt. Divya Sameer Tax, Gehlaut Vs. Central Circle 6(4), 17Th Floor, Tower 1, Room No. 1925, 19Th Floor, Indianbulls Finance Air India Building, Centre, Senapati Bapat Nariman Point, Marg, Elphinstone Mumbai-400021 Road, Mumbai-400013 स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Ajbpg2722R (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri .Om Kandalkar Revenue By: Shri. T Sankar (Dr) सुनवाई की तारीख / Date Of Hearing: 29/09/2022 घोषणा की तारीख /Date Of Pronouncement: 31/10/2022 आदेश / O R D E R Per Aby T. Varkey, Jm:

For Appellant: Shri .Om KandalkarFor Respondent: Shri. T Sankar (DR)
Section 132Section 143Section 143(3)Section 153CSection 54

…t allowing deduction u/s 54 of the Act is beyond the jurisdiction. In this regard, the appellant has relied upon the decision in the case of CIT vs. Murli Agro Products (Bombay High Court) in ITA No. 36 of 2009, All cargo Global Logistics Ltd. vs. DCIT (2012) 137 ITD 287 (SB) (Mum) and ACIT vs. Pratibha Industries Ltd. (2013)141 ITD 151 (Mum). In the present case of the appellant, for A.Y. 2013-14, assessment order has been passed under section 153C of the Act. The AO has not allowed deduction u/s 54 of the Act. The action of the AO is based on the details provided in the return of incomes and the entries in the…

Sangeetkumar Sawarmal Hisaria, Mumbai vs. Dy CIT -CC-2(4), Mumbai

ITA 785/MUM/2021[2011-12]Status: DisposedITAT Mumbai17 Oct 2022AY 2011-12
Section 132Section 143(3)Section 147Section 148Section 153A

…THE INCOME TAX APPELLATE TRIBUNAL “E” Bench, Mumbai Shri B.R. Baskaran (AM) & Shri Anikesh Banerjee (JM) I.T.A. No. 785/Mum/2021 (A.Y. 2011-12) I.T.A. No. 870/Mum/2021 (A.Y. 2012-13) I.T.A. No. 509/Mum/2021 (A.Y. 2013-14) I.T.A. No. 508/Mum/2021 (A.Y. 2014-15) I.T.A. No. 502/Mum/2021 (A.Y. 2015-16) I.T.A. No. 869/Mum/2021 (A.Y. 2016-17) I.T.A. No. 786/Mum/2021 (A.Y. 2017-18) I.T.A. No. 1029/Mum/2021 (A.Y. 2018-19) Vs. DCIT, CC-2(4) Sangeetkumar Sawarmal Hisaria 802, 8th Floor 74/80, 3rd Floor PratishthaBhavan Souri Building, Babu Old CGO Building Genu Road, Kalbadevi Annexe, M.K. Road Mumbai-400 002. Mumbai-40…

Renudevi Hisaria, Mumbai vs. DCIT Cent. Cir-2(4), Mumbai

ITA 1291/MUM/2021[2012-13]Status: DisposedITAT Mumbai17 Oct 2022AY 2012-13

Bench: The Tribunal.

Section 132Section 139(1)Section 143(2)Section 143(3)Section 148Section 153A

…THE INCOME TAX APPELLATE TRIBUNAL “E” Bench, Mumbai Shri B.R. Baskaran (AM) & Shri Anikesh Banerjee (JM) I.T.A. No. 1291/Mum/2021 (A.Y. 2012-13) I.T.A. No. 1287/Mum/2021 (A.Y. 2015-16) I.T.A. No. 1306/Mum/2021 (A.Y. 2017-18) Vs. DCIT, CC-2(4) Renudevi Hisaria 74/80, 3rd Floor 802, 8th Floor Souri Building, Babu Pratishtha Bhavan Genu Road, Kalbadevi Old CGO Building Mumbai-400 002. Annexe, M.K. Road Mumbai-400 020. PAN : AABPH1487R Assessee by Shri Neelkanth Khandelwal Department by Shri H N Singh, CIT DR and Shri Airiju Jaikaran, Sr DR Date of Hearing 27.07.2022 Date of Pronouncement 17.10.2022 O R D E R P…

Dy CIT-CC-2(4), Mumbai vs. Late Shri Sawarmal Hisaria Through L/H Sandeep Hisaria, Mumbai

ITA 1042/MUM/2021[2017-18]Status: DisposedITAT Mumbai17 Oct 2022AY 2017-18
Section 132Section 143(2)Section 143(3)Section 153A

…THE INCOME TAX APPELLATE TRIBUNAL “E” Bench, Mumbai Shri B.R. Baskaran (AM) & Shri Anikesh Banerjee (JM) I.T.A. No. 1042/Mum/2021 (A.Y. 2017-18) I.T.A. No. 1043/Mum/2021 (A.Y. 2014-15) Vs. Sandeep Hisaria, DCIT, Central Circle-2(4) Old CGO Building L/H of Late Shri 8th Floor, M.K. Road Sawarmal Hisaria, Mumbai-400 020. 74/80, 3rd Floor, Souri Building, Babu Genu Road,Kalbadevi Mumbai-400 002. (Appellant) (Respondent) I.T.A. No. 751/Mum/2021 (A.Y. 2017-18) I.T.A. No. 756/Mum/2021 (A.Y. 2012-13) I.T.A. No. 757/Mum/2021 (A.Y. 2014-15) I.T.A. No. 758/Mum/2021 (A.Y. 2015-16) I.T.A. No. 759/Mum/2021 (A.Y. 2016-17…

DCIT, Coimbatore vs. O.Arumugasamy, Coimbatore

ITA 777/CHNY/2017[2012-13]Status: DisposedITAT Chennai28 Sept 2022AY 2012-13

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ed that this issue is adjudicated by Hon’ble Bombay High Court in the case of Continental Warehousing Corporation (Nhava Sheva) Ltd., supra, wherein considering the judgment of the Special Bench of the Mumbai Tribunal in the case of All Cargo Global Logistics 137 ITD 287(SB) (Mum), considered this issue that, whether there is scope of assessment u/s. 153A of the Act in respect to completed assessment which is limited only to undisclosed income and undisclosed assets found during the course of search or not? Hon'ble High Court held that on a plain reading of section 153 of the Act it becomes clear that on initiati…

O.Arumugasamy, Chennai vs. DCIT, Coimbatore

ITA 763/CHNY/2017[2012-13]Status: DisposedITAT Chennai28 Sept 2022AY 2012-13

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ed that this issue is adjudicated by Hon’ble Bombay High Court in the case of Continental Warehousing Corporation (Nhava Sheva) Ltd., supra, wherein considering the judgment of the Special Bench of the Mumbai Tribunal in the case of All Cargo Global Logistics 137 ITD 287(SB) (Mum), considered this issue that, whether there is scope of assessment u/s. 153A of the Act in respect to completed assessment which is limited only to undisclosed income and undisclosed assets found during the course of search or not? Hon'ble High Court held that on a plain reading of section 153 of the Act it becomes clear that on initiati…

DCIT, Coimbatore vs. Shri A. Senthilkumar, Coimbatore

ITA 2707/CHNY/2016[2011-12]Status: DisposedITAT Chennai28 Sept 2022AY 2011-12

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ed that this issue is adjudicated by Hon’ble Bombay High Court in the case of Continental Warehousing Corporation (Nhava Sheva) Ltd., supra, wherein considering the judgment of the Special Bench of the Mumbai Tribunal in the case of All Cargo Global Logistics 137 ITD 287(SB) (Mum), considered this issue that, whether there is scope of assessment u/s. 153A of the Act in respect to completed assessment which is limited only to undisclosed income and undisclosed assets found during the course of search or not? Hon'ble High Court held that on a plain reading of section 153 of the Act it becomes clear that on initiati…

A. Senthil Kumar, Coimbatore vs. DCIT, Coimbatore

ITA 2570/CHNY/2016[2011-12]Status: DisposedITAT Chennai28 Sept 2022AY 2011-12

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ed that this issue is adjudicated by Hon’ble Bombay High Court in the case of Continental Warehousing Corporation (Nhava Sheva) Ltd., supra, wherein considering the judgment of the Special Bench of the Mumbai Tribunal in the case of All Cargo Global Logistics 137 ITD 287(SB) (Mum), considered this issue that, whether there is scope of assessment u/s. 153A of the Act in respect to completed assessment which is limited only to undisclosed income and undisclosed assets found during the course of search or not? Hon'ble High Court held that on a plain reading of section 153 of the Act it becomes clear that on initiati…

DCIT, Coimbatore vs. O.Arumugasamy, Coimbatore

ITA 1833/CHNY/2015[2011-12]Status: DisposedITAT Chennai28 Sept 2022AY 2011-12

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ed that this issue is adjudicated by Hon’ble Bombay High Court in the case of Continental Warehousing Corporation (Nhava Sheva) Ltd., supra, wherein considering the judgment of the Special Bench of the Mumbai Tribunal in the case of All Cargo Global Logistics 137 ITD 287(SB) (Mum), considered this issue that, whether there is scope of assessment u/s. 153A of the Act in respect to completed assessment which is limited only to undisclosed income and undisclosed assets found during the course of search or not? Hon'ble High Court held that on a plain reading of section 153 of the Act it becomes clear that on initiati…

DCIT, Coimbatore vs. O.Arumugasamy, Coimbatore

ITA 1398/CHNY/2015[2008-09]Status: DisposedITAT Chennai28 Sept 2022AY 2008-09

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ed that this issue is adjudicated by Hon’ble Bombay High Court in the case of Continental Warehousing Corporation (Nhava Sheva) Ltd., supra, wherein considering the judgment of the Special Bench of the Mumbai Tribunal in the case of All Cargo Global Logistics 137 ITD 287(SB) (Mum), considered this issue that, whether there is scope of assessment u/s. 153A of the Act in respect to completed assessment which is limited only to undisclosed income and undisclosed assets found during the course of search or not? Hon'ble High Court held that on a plain reading of section 153 of the Act it becomes clear that on initiati…

DCIT, Coimbatore vs. O.Arumugasamy, Coimbatore

ITA 1011/CHNY/2015[2010-11]Status: DisposedITAT Chennai28 Sept 2022AY 2010-11

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ed that this issue is adjudicated by Hon’ble Bombay High Court in the case of Continental Warehousing Corporation (Nhava Sheva) Ltd., supra, wherein considering the judgment of the Special Bench of the Mumbai Tribunal in the case of All Cargo Global Logistics 137 ITD 287(SB) (Mum), considered this issue that, whether there is scope of assessment u/s. 153A of the Act in respect to completed assessment which is limited only to undisclosed income and undisclosed assets found during the course of search or not? Hon'ble High Court held that on a plain reading of section 153 of the Act it becomes clear that on initiati…

DCIT, Coimbatore vs. A.Senthil Kumar, Coimbatore

ITA 1010/CHNY/2015[2010-11]Status: DisposedITAT Chennai28 Sept 2022AY 2010-11

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ed that this issue is adjudicated by Hon’ble Bombay High Court in the case of Continental Warehousing Corporation (Nhava Sheva) Ltd., supra, wherein considering the judgment of the Special Bench of the Mumbai Tribunal in the case of All Cargo Global Logistics 137 ITD 287(SB) (Mum), considered this issue that, whether there is scope of assessment u/s. 153A of the Act in respect to completed assessment which is limited only to undisclosed income and undisclosed assets found during the course of search or not? Hon'ble High Court held that on a plain reading of section 153 of the Act it becomes clear that on initiati…

DCIT, Coimbatore vs. Senthil Enterprises, Coimbatore

ITA 709/CHNY/2014[2010-11]Status: DisposedITAT Chennai28 Sept 2022AY 2010-11

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ed that this issue is adjudicated by Hon’ble Bombay High Court in the case of Continental Warehousing Corporation (Nhava Sheva) Ltd., supra, wherein considering the judgment of the Special Bench of the Mumbai Tribunal in the case of All Cargo Global Logistics 137 ITD 287(SB) (Mum), considered this issue that, whether there is scope of assessment u/s. 153A of the Act in respect to completed assessment which is limited only to undisclosed income and undisclosed assets found during the course of search or not? Hon'ble High Court held that on a plain reading of section 153 of the Act it becomes clear that on initiati…

DCIT, Coimbatore vs. Shri T.M.Muthukumar, Coimbatore

ITA 150/CHNY/2013[2005-06]Status: DisposedITAT Chennai28 Sept 2022AY 2005-06

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ed that this issue is adjudicated by Hon’ble Bombay High Court in the case of Continental Warehousing Corporation (Nhava Sheva) Ltd., supra, wherein considering the judgment of the Special Bench of the Mumbai Tribunal in the case of All Cargo Global Logistics 137 ITD 287(SB) (Mum), considered this issue that, whether there is scope of assessment u/s. 153A of the Act in respect to completed assessment which is limited only to undisclosed income and undisclosed assets found during the course of search or not? Hon'ble High Court held that on a plain reading of section 153 of the Act it becomes clear that on initiati…

DCIT, Coimbatore vs. Shri O.Arumugasamy, Coimbatore

ITA 144/CHNY/2013[2009-10]Status: DisposedITAT Chennai28 Sept 2022AY 2009-10

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ed that this issue is adjudicated by Hon’ble Bombay High Court in the case of Continental Warehousing Corporation (Nhava Sheva) Ltd., supra, wherein considering the judgment of the Special Bench of the Mumbai Tribunal in the case of All Cargo Global Logistics 137 ITD 287(SB) (Mum), considered this issue that, whether there is scope of assessment u/s. 153A of the Act in respect to completed assessment which is limited only to undisclosed income and undisclosed assets found during the course of search or not? Hon'ble High Court held that on a plain reading of section 153 of the Act it becomes clear that on initiati…

DCIT, Coimbatore vs. Shri O.Arumugasamy, Coimbatore

ITA 143/CHNY/2013[2008-09]Status: DisposedITAT Chennai28 Sept 2022AY 2008-09

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ed that this issue is adjudicated by Hon’ble Bombay High Court in the case of Continental Warehousing Corporation (Nhava Sheva) Ltd., supra, wherein considering the judgment of the Special Bench of the Mumbai Tribunal in the case of All Cargo Global Logistics 137 ITD 287(SB) (Mum), considered this issue that, whether there is scope of assessment u/s. 153A of the Act in respect to completed assessment which is limited only to undisclosed income and undisclosed assets found during the course of search or not? Hon'ble High Court held that on a plain reading of section 153 of the Act it becomes clear that on initiati…

DCIT, Coimbatore vs. Shri M.Palanisamy, Coimbatore

ITA 142/CHNY/2013[2009-10]Status: DisposedITAT Chennai28 Sept 2022AY 2009-10

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ed that this issue is adjudicated by Hon’ble Bombay High Court in the case of Continental Warehousing Corporation (Nhava Sheva) Ltd., supra, wherein considering the judgment of the Special Bench of the Mumbai Tribunal in the case of All Cargo Global Logistics 137 ITD 287(SB) (Mum), considered this issue that, whether there is scope of assessment u/s. 153A of the Act in respect to completed assessment which is limited only to undisclosed income and undisclosed assets found during the course of search or not? Hon'ble High Court held that on a plain reading of section 153 of the Act it becomes clear that on initiati…

DCIT, Coimbatore vs. Shri M.Palanisamy, Coimbatore

ITA 141/CHNY/2013[2008-09]Status: DisposedITAT Chennai28 Sept 2022AY 2008-09

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ed that this issue is adjudicated by Hon’ble Bombay High Court in the case of Continental Warehousing Corporation (Nhava Sheva) Ltd., supra, wherein considering the judgment of the Special Bench of the Mumbai Tribunal in the case of All Cargo Global Logistics 137 ITD 287(SB) (Mum), considered this issue that, whether there is scope of assessment u/s. 153A of the Act in respect to completed assessment which is limited only to undisclosed income and undisclosed assets found during the course of search or not? Hon'ble High Court held that on a plain reading of section 153 of the Act it becomes clear that on initiati…

DCIT, Coimbatore vs. Shri A.Senthilkumar, Coimbatore

ITA 140/CHNY/2013[2009-10]Status: DisposedITAT Chennai28 Sept 2022AY 2009-10

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ed that this issue is adjudicated by Hon’ble Bombay High Court in the case of Continental Warehousing Corporation (Nhava Sheva) Ltd., supra, wherein considering the judgment of the Special Bench of the Mumbai Tribunal in the case of All Cargo Global Logistics 137 ITD 287(SB) (Mum), considered this issue that, whether there is scope of assessment u/s. 153A of the Act in respect to completed assessment which is limited only to undisclosed income and undisclosed assets found during the course of search or not? Hon'ble High Court held that on a plain reading of section 153 of the Act it becomes clear that on initiati…

DCIT, Coimbatore vs. Shri A.Senthilkumar, Coimbatore

ITA 139/CHNY/2013[2008-09]Status: DisposedITAT Chennai28 Sept 2022AY 2008-09

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ed that this issue is adjudicated by Hon’ble Bombay High Court in the case of Continental Warehousing Corporation (Nhava Sheva) Ltd., supra, wherein considering the judgment of the Special Bench of the Mumbai Tribunal in the case of All Cargo Global Logistics 137 ITD 287(SB) (Mum), considered this issue that, whether there is scope of assessment u/s. 153A of the Act in respect to completed assessment which is limited only to undisclosed income and undisclosed assets found during the course of search or not? Hon'ble High Court held that on a plain reading of section 153 of the Act it becomes clear that on initiati…