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 367,181 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

Kamlashri Developers, Mumbai vs. DCIT (3)(4) CC, Mumbai

In the result, the appeals of the assessee for AYs 2008-09, 2009-10, 2010-

ITA 4348/MUM/2019[2012-13]Status: DisposedITAT Mumbai30 Aug 2022AY 2012-13

Bench: Shri Aby T Varkey & Shri Gagan Goyal

For Appellant: Ms. Ketki RajeshirkeFor Respondent: Shri Rashmikant Modi
Section 132(4)Section 143(2)Section 143(3)Section 153A

…ed by the Hon’ble Bombay High Court in the cases of Continental Warehousing Corporation (NhavaSheva) Ltd (supra), CIT vs Murli Agro Products Ltd (49 taxmann.com 172) and the Special Bench of this Tribunal in the case of All Cargo Global Logistics Ltd vs DCIT (137 ITD 287). The Revenue had alternatively contended that, the statements recorded u/s 132(4) carries sufficient evidentiary value and therefore any admission by the assessee to any wrong doing itself constitutes incriminating material to justify additions in unabated assessments. The Revenue further contended that, the decisions relied upon by the assessee…

Kamlashri Developers, Mumbai vs. DCIT (3)(4) CC, Mumbai

In the result, the appeals of the assessee for AYs 2008-09, 2009-10, 2010-

ITA 4347/MUM/2019[2011-12]Status: DisposedITAT Mumbai30 Aug 2022AY 2011-12

Bench: Shri Aby T Varkey & Shri Gagan Goyal

For Appellant: Ms. Ketki RajeshirkeFor Respondent: Shri Rashmikant Modi
Section 132(4)Section 143(2)Section 143(3)Section 153A

…ed by the Hon’ble Bombay High Court in the cases of Continental Warehousing Corporation (NhavaSheva) Ltd (supra), CIT vs Murli Agro Products Ltd (49 taxmann.com 172) and the Special Bench of this Tribunal in the case of All Cargo Global Logistics Ltd vs DCIT (137 ITD 287). The Revenue had alternatively contended that, the statements recorded u/s 132(4) carries sufficient evidentiary value and therefore any admission by the assessee to any wrong doing itself constitutes incriminating material to justify additions in unabated assessments. The Revenue further contended that, the decisions relied upon by the assessee…

Kamlashri Developers, Mumbai vs. DCIT (3)(4) CC, Mumbai

In the result, the appeals of the assessee for AYs 2008-09, 2009-10, 2010-

ITA 4346/MUM/2019[2010-1]Status: DisposedITAT Mumbai30 Aug 2022

Bench: Shri Aby T Varkey & Shri Gagan Goyal

For Appellant: Ms. Ketki RajeshirkeFor Respondent: Shri Rashmikant Modi
Section 132(4)Section 143(2)Section 143(3)Section 153A

…ed by the Hon’ble Bombay High Court in the cases of Continental Warehousing Corporation (NhavaSheva) Ltd (supra), CIT vs Murli Agro Products Ltd (49 taxmann.com 172) and the Special Bench of this Tribunal in the case of All Cargo Global Logistics Ltd vs DCIT (137 ITD 287). The Revenue had alternatively contended that, the statements recorded u/s 132(4) carries sufficient evidentiary value and therefore any admission by the assessee to any wrong doing itself constitutes incriminating material to justify additions in unabated assessments. The Revenue further contended that, the decisions relied upon by the assessee…

Kamlashri Developers, Mumbai vs. DCIT(3)(4), Central Circle, Mumbai

In the result, the appeals of the assessee for AYs 2008-09, 2009-10, 2010-

ITA 4345/MUM/2019[2009-10]Status: DisposedITAT Mumbai30 Aug 2022AY 2009-10

Bench: Shri Aby T Varkey & Shri Gagan Goyal

For Appellant: Ms. Ketki RajeshirkeFor Respondent: Shri Rashmikant Modi
Section 132(4)Section 143(2)Section 143(3)Section 153A

…ed by the Hon’ble Bombay High Court in the cases of Continental Warehousing Corporation (NhavaSheva) Ltd (supra), CIT vs Murli Agro Products Ltd (49 taxmann.com 172) and the Special Bench of this Tribunal in the case of All Cargo Global Logistics Ltd vs DCIT (137 ITD 287). The Revenue had alternatively contended that, the statements recorded u/s 132(4) carries sufficient evidentiary value and therefore any admission by the assessee to any wrong doing itself constitutes incriminating material to justify additions in unabated assessments. The Revenue further contended that, the decisions relied upon by the assessee…

Kamlashri Developers, Mumbai vs. DCIT(3)(4), Central Circle, Mumbai

In the result, the appeals of the assessee for AYs 2008-09, 2009-10, 2010-

ITA 4344/MUM/2019[2008-09]Status: DisposedITAT Mumbai30 Aug 2022AY 2008-09

Bench: Shri Aby T Varkey & Shri Gagan Goyal

For Appellant: Ms. Ketki RajeshirkeFor Respondent: Shri Rashmikant Modi
Section 132(4)Section 143(2)Section 143(3)Section 153A

…ed by the Hon’ble Bombay High Court in the cases of Continental Warehousing Corporation (NhavaSheva) Ltd (supra), CIT vs Murli Agro Products Ltd (49 taxmann.com 172) and the Special Bench of this Tribunal in the case of All Cargo Global Logistics Ltd vs DCIT (137 ITD 287). The Revenue had alternatively contended that, the statements recorded u/s 132(4) carries sufficient evidentiary value and therefore any admission by the assessee to any wrong doing itself constitutes incriminating material to justify additions in unabated assessments. The Revenue further contended that, the decisions relied upon by the assessee…

Kamla Ankur Developer, Mumbai vs. DCIT (3)(4), CC, Mumbai

In the result, the appeals of the assessee for AYs 2008-09,

ITA 4224/MUM/2019[2013-14]Status: DisposedITAT Mumbai30 Aug 2022AY 2013-14

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकरअपीलसं/ I.T.A. Nos.4219 To 4224/Mum/2019 (निर्धारणवर्ा / Assessment Years: 2008-09 To 2013-14) Kamlaankur Developers बनाम/ Dcit, Central Circle-3(4) Ground Floor, Shanti Vimal, P. 19Th Floor, Air India Vs. M. Road, Vile Parle East, Building, Nariman Point, Mumbai-400021. Mumbai-400057. स्थधयीलेखधसं./जीआइआरसं./Pan/Gir No. :Aaifk4903G (अपीलधथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri Rashmikant Modi Ms. Ketki Rajeshirke Revenue By: Shri Vinay Sinha(Dr) सुिवधईकीतधरीख / Date Of Hearing: 15/07/2022 घोर्णधकीतधरीख /Date Of Pronouncement: 30/08/2022 आदेश / O R D E R Perbench These Appeals Preferred By The Assessee Are Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals)-51, Mumbai [Hereinafter In Short “Ld. Cit(A)”] Dated 09.04.2019 For A.Y. 2008-09 To Ay. 2013-14. Since Issues Involved Are Common, All The Appeals For All The Assessment Year/Years (Hereinafter Referred To As “Ay”) Were Heard Together. Both The Parties Also Argued Them Together Raising Similar Arguments On These Issues. Accordingly, For The Sake Of Convenience & Brevity, We Dispose All The Appeals By This Consolidated Order.

For Appellant: Shri Rashmikant ModiFor Respondent: Shri Vinay Sinha(DR)
Section 132(4)Section 143(2)Section 143(3)Section 153A

…of Continental Warehousing Corporation (Nhava Sheva) Ltd (supra), CIT vs Murli Agro Products Ltd (49 taxmann.com 172) and the Special Bench of this Tribunal in A.Ys. 2008-09 to 2013-14 KamlaAnkur Developers the case of All Cargo Global Logistics Ltd vs DCIT (137 ITD 287). The Revenue had alternatively contended that, the statements recorded u/s 132(4) carries sufficient evidentiary value and therefore any admission by the assessee to any wrong doing itself constitutes incriminating material to justify additions in unabated assessments. The Revenue further contended that, the decisions relied upon by the assessee…

Kamla Ankur Developer, Mumbai vs. DCIT (3) (4) -CC, Mumbai

In the result, the appeals of the assessee for AYs 2008-09,

ITA 4223/MUM/2019[2012-13]Status: DisposedITAT Mumbai30 Aug 2022AY 2012-13

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकरअपीलसं/ I.T.A. Nos.4219 To 4224/Mum/2019 (निर्धारणवर्ा / Assessment Years: 2008-09 To 2013-14) Kamlaankur Developers बनाम/ Dcit, Central Circle-3(4) Ground Floor, Shanti Vimal, P. 19Th Floor, Air India Vs. M. Road, Vile Parle East, Building, Nariman Point, Mumbai-400021. Mumbai-400057. स्थधयीलेखधसं./जीआइआरसं./Pan/Gir No. :Aaifk4903G (अपीलधथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri Rashmikant Modi Ms. Ketki Rajeshirke Revenue By: Shri Vinay Sinha(Dr) सुिवधईकीतधरीख / Date Of Hearing: 15/07/2022 घोर्णधकीतधरीख /Date Of Pronouncement: 30/08/2022 आदेश / O R D E R Perbench These Appeals Preferred By The Assessee Are Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals)-51, Mumbai [Hereinafter In Short “Ld. Cit(A)”] Dated 09.04.2019 For A.Y. 2008-09 To Ay. 2013-14. Since Issues Involved Are Common, All The Appeals For All The Assessment Year/Years (Hereinafter Referred To As “Ay”) Were Heard Together. Both The Parties Also Argued Them Together Raising Similar Arguments On These Issues. Accordingly, For The Sake Of Convenience & Brevity, We Dispose All The Appeals By This Consolidated Order.

For Appellant: Shri Rashmikant ModiFor Respondent: Shri Vinay Sinha(DR)
Section 132(4)Section 143(2)Section 143(3)Section 153A

…of Continental Warehousing Corporation (Nhava Sheva) Ltd (supra), CIT vs Murli Agro Products Ltd (49 taxmann.com 172) and the Special Bench of this Tribunal in A.Ys. 2008-09 to 2013-14 KamlaAnkur Developers the case of All Cargo Global Logistics Ltd vs DCIT (137 ITD 287). The Revenue had alternatively contended that, the statements recorded u/s 132(4) carries sufficient evidentiary value and therefore any admission by the assessee to any wrong doing itself constitutes incriminating material to justify additions in unabated assessments. The Revenue further contended that, the decisions relied upon by the assessee…

Kamla Ankur Developer, Mumbai vs. DCIT (3) (4), Mumbai

In the result, the appeals of the assessee for AYs 2008-09,

ITA 4222/MUM/2019[2011-12]Status: DisposedITAT Mumbai30 Aug 2022AY 2011-12

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकरअपीलसं/ I.T.A. Nos.4219 To 4224/Mum/2019 (निर्धारणवर्ा / Assessment Years: 2008-09 To 2013-14) Kamlaankur Developers बनाम/ Dcit, Central Circle-3(4) Ground Floor, Shanti Vimal, P. 19Th Floor, Air India Vs. M. Road, Vile Parle East, Building, Nariman Point, Mumbai-400021. Mumbai-400057. स्थधयीलेखधसं./जीआइआरसं./Pan/Gir No. :Aaifk4903G (अपीलधथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri Rashmikant Modi Ms. Ketki Rajeshirke Revenue By: Shri Vinay Sinha(Dr) सुिवधईकीतधरीख / Date Of Hearing: 15/07/2022 घोर्णधकीतधरीख /Date Of Pronouncement: 30/08/2022 आदेश / O R D E R Perbench These Appeals Preferred By The Assessee Are Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals)-51, Mumbai [Hereinafter In Short “Ld. Cit(A)”] Dated 09.04.2019 For A.Y. 2008-09 To Ay. 2013-14. Since Issues Involved Are Common, All The Appeals For All The Assessment Year/Years (Hereinafter Referred To As “Ay”) Were Heard Together. Both The Parties Also Argued Them Together Raising Similar Arguments On These Issues. Accordingly, For The Sake Of Convenience & Brevity, We Dispose All The Appeals By This Consolidated Order.

For Appellant: Shri Rashmikant ModiFor Respondent: Shri Vinay Sinha(DR)
Section 132(4)Section 143(2)Section 143(3)Section 153A

…of Continental Warehousing Corporation (Nhava Sheva) Ltd (supra), CIT vs Murli Agro Products Ltd (49 taxmann.com 172) and the Special Bench of this Tribunal in A.Ys. 2008-09 to 2013-14 KamlaAnkur Developers the case of All Cargo Global Logistics Ltd vs DCIT (137 ITD 287). The Revenue had alternatively contended that, the statements recorded u/s 132(4) carries sufficient evidentiary value and therefore any admission by the assessee to any wrong doing itself constitutes incriminating material to justify additions in unabated assessments. The Revenue further contended that, the decisions relied upon by the assessee…

Kamla Ankur Developer, Mumbai vs. DCIT (3) (4), Mumbai

In the result, the appeals of the assessee for AYs 2008-09,

ITA 4221/MUM/2019[2010-11]Status: DisposedITAT Mumbai30 Aug 2022AY 2010-11

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकरअपीलसं/ I.T.A. Nos.4219 To 4224/Mum/2019 (निर्धारणवर्ा / Assessment Years: 2008-09 To 2013-14) Kamlaankur Developers बनाम/ Dcit, Central Circle-3(4) Ground Floor, Shanti Vimal, P. 19Th Floor, Air India Vs. M. Road, Vile Parle East, Building, Nariman Point, Mumbai-400021. Mumbai-400057. स्थधयीलेखधसं./जीआइआरसं./Pan/Gir No. :Aaifk4903G (अपीलधथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri Rashmikant Modi Ms. Ketki Rajeshirke Revenue By: Shri Vinay Sinha(Dr) सुिवधईकीतधरीख / Date Of Hearing: 15/07/2022 घोर्णधकीतधरीख /Date Of Pronouncement: 30/08/2022 आदेश / O R D E R Perbench These Appeals Preferred By The Assessee Are Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals)-51, Mumbai [Hereinafter In Short “Ld. Cit(A)”] Dated 09.04.2019 For A.Y. 2008-09 To Ay. 2013-14. Since Issues Involved Are Common, All The Appeals For All The Assessment Year/Years (Hereinafter Referred To As “Ay”) Were Heard Together. Both The Parties Also Argued Them Together Raising Similar Arguments On These Issues. Accordingly, For The Sake Of Convenience & Brevity, We Dispose All The Appeals By This Consolidated Order.

For Appellant: Shri Rashmikant ModiFor Respondent: Shri Vinay Sinha(DR)
Section 132(4)Section 143(2)Section 143(3)Section 153A

…of Continental Warehousing Corporation (Nhava Sheva) Ltd (supra), CIT vs Murli Agro Products Ltd (49 taxmann.com 172) and the Special Bench of this Tribunal in A.Ys. 2008-09 to 2013-14 KamlaAnkur Developers the case of All Cargo Global Logistics Ltd vs DCIT (137 ITD 287). The Revenue had alternatively contended that, the statements recorded u/s 132(4) carries sufficient evidentiary value and therefore any admission by the assessee to any wrong doing itself constitutes incriminating material to justify additions in unabated assessments. The Revenue further contended that, the decisions relied upon by the assessee…

Kamla Ankur Developer, Mumbai vs. DCIT (3)(4) CC, Mumbai

In the result, the appeals of the assessee for AYs 2008-09,

ITA 4220/MUM/2019[2009-10]Status: DisposedITAT Mumbai30 Aug 2022AY 2009-10

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकरअपीलसं/ I.T.A. Nos.4219 To 4224/Mum/2019 (निर्धारणवर्ा / Assessment Years: 2008-09 To 2013-14) Kamlaankur Developers बनाम/ Dcit, Central Circle-3(4) Ground Floor, Shanti Vimal, P. 19Th Floor, Air India Vs. M. Road, Vile Parle East, Building, Nariman Point, Mumbai-400021. Mumbai-400057. स्थधयीलेखधसं./जीआइआरसं./Pan/Gir No. :Aaifk4903G (अपीलधथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri Rashmikant Modi Ms. Ketki Rajeshirke Revenue By: Shri Vinay Sinha(Dr) सुिवधईकीतधरीख / Date Of Hearing: 15/07/2022 घोर्णधकीतधरीख /Date Of Pronouncement: 30/08/2022 आदेश / O R D E R Perbench These Appeals Preferred By The Assessee Are Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals)-51, Mumbai [Hereinafter In Short “Ld. Cit(A)”] Dated 09.04.2019 For A.Y. 2008-09 To Ay. 2013-14. Since Issues Involved Are Common, All The Appeals For All The Assessment Year/Years (Hereinafter Referred To As “Ay”) Were Heard Together. Both The Parties Also Argued Them Together Raising Similar Arguments On These Issues. Accordingly, For The Sake Of Convenience & Brevity, We Dispose All The Appeals By This Consolidated Order.

For Appellant: Shri Rashmikant ModiFor Respondent: Shri Vinay Sinha(DR)
Section 132(4)Section 143(2)Section 143(3)Section 153A

…of Continental Warehousing Corporation (Nhava Sheva) Ltd (supra), CIT vs Murli Agro Products Ltd (49 taxmann.com 172) and the Special Bench of this Tribunal in A.Ys. 2008-09 to 2013-14 KamlaAnkur Developers the case of All Cargo Global Logistics Ltd vs DCIT (137 ITD 287). The Revenue had alternatively contended that, the statements recorded u/s 132(4) carries sufficient evidentiary value and therefore any admission by the assessee to any wrong doing itself constitutes incriminating material to justify additions in unabated assessments. The Revenue further contended that, the decisions relied upon by the assessee…

Kamla Ankur Developer, Mumbai vs. DCIT (3)(4), CC, Mumbai

In the result, the appeals of the assessee for AYs 2008-09,

ITA 4219/MUM/2019[2008-09]Status: DisposedITAT Mumbai30 Aug 2022AY 2008-09

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकरअपीलसं/ I.T.A. Nos.4219 To 4224/Mum/2019 (निर्धारणवर्ा / Assessment Years: 2008-09 To 2013-14) Kamlaankur Developers बनाम/ Dcit, Central Circle-3(4) Ground Floor, Shanti Vimal, P. 19Th Floor, Air India Vs. M. Road, Vile Parle East, Building, Nariman Point, Mumbai-400021. Mumbai-400057. स्थधयीलेखधसं./जीआइआरसं./Pan/Gir No. :Aaifk4903G (अपीलधथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri Rashmikant Modi Ms. Ketki Rajeshirke Revenue By: Shri Vinay Sinha(Dr) सुिवधईकीतधरीख / Date Of Hearing: 15/07/2022 घोर्णधकीतधरीख /Date Of Pronouncement: 30/08/2022 आदेश / O R D E R Perbench These Appeals Preferred By The Assessee Are Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals)-51, Mumbai [Hereinafter In Short “Ld. Cit(A)”] Dated 09.04.2019 For A.Y. 2008-09 To Ay. 2013-14. Since Issues Involved Are Common, All The Appeals For All The Assessment Year/Years (Hereinafter Referred To As “Ay”) Were Heard Together. Both The Parties Also Argued Them Together Raising Similar Arguments On These Issues. Accordingly, For The Sake Of Convenience & Brevity, We Dispose All The Appeals By This Consolidated Order.

For Appellant: Shri Rashmikant ModiFor Respondent: Shri Vinay Sinha(DR)
Section 132(4)Section 143(2)Section 143(3)Section 153A

…of Continental Warehousing Corporation (Nhava Sheva) Ltd (supra), CIT vs Murli Agro Products Ltd (49 taxmann.com 172) and the Special Bench of this Tribunal in A.Ys. 2008-09 to 2013-14 KamlaAnkur Developers the case of All Cargo Global Logistics Ltd vs DCIT (137 ITD 287). The Revenue had alternatively contended that, the statements recorded u/s 132(4) carries sufficient evidentiary value and therefore any admission by the assessee to any wrong doing itself constitutes incriminating material to justify additions in unabated assessments. The Revenue further contended that, the decisions relied upon by the assessee…

Kamla Shubham Estate, Mumbai vs. DCIT- CC -(3)(4), Mumbai

In the result, the appeals of the assessee for AYs 2008-09,

ITA 4217/MUM/2019[2010-11]Status: DisposedITAT Mumbai30 Aug 2022AY 2010-11

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकरअपीलसं/I.T.A. Nos.4215 To 4218 & 1577 & 1579/Mum/2019 (निर्धारणवर्ा / Assessment Years:2008-09 To 2012-13 & 2014-15) Kamla Shubham Estate बिधम/ Dcit Central Circle (3)(4) Ground Floor, Shanti Vimal, 19Th Floor, Air India Vs. P.M. Road, Vile Parle East, Building, Nariman Point, Mumbai-400057. Mumbai-400021. स्थायीलेखासं./जीआइआरसं./Pan/Gir No. :Aaifk6226E (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri Rashmikant Modi Ms. Ketki Rajeshirke Revenue By: Shri Vinay Sinha(Dr) सुनवाईकीतारीख / Date Of Hearing: 15/07/2022 घोषणाकीतारीख /Date Of Pronouncement: 30/08/2022 आदेश / O R D E R Per Bench These Appeals Preferred By The Assessee Are Against The Common Orders Of The Ld. Commissioner Of Income Tax (Appeals)-51, Mumbai [Hereinafter In Short “Ld. Cit(A)”] Dated 09.04.2019 For A.Y. 2008-09 To Ay. 2011-12 & Dated 11.02.2019 For Ays 2012-13 & 2014-15. Since Issues Involved Are Common, All The Appeals For All The Assessment Year/Years (Hereinafter Referred To As “Ay”) Were Heard Together. Both The Parties Also Argued Them Together Raising Similar Arguments On These Issues. Accordingly, For The Sake Of Convenience & Brevity, We Dispose All The Appeals By This Consolidated Order.

For Appellant: Shri Rashmikant ModiFor Respondent: Shri Vinay Sinha(DR)
Section 132(4)Section 143(2)Section 143(3)Section 153A

…d by the Hon’ble Bombay High Court in the cases of Continental Warehousing Corporation (Nhava Sheva) Ltd (supra), CIT vs Murli Agro Products Ltd (49 taxmann.com 172) and the Special Bench of this Tribunal in the case of All Cargo Global Logistics Ltd vs DCIT (137 ITD 287). The Revenue had alternatively contended that, the statements recorded u/s 132(4) carries sufficient evidentiary value and therefore any admission by the assessee to any wrong doing itself constitutes incriminating material to justify additions in unabated assessments. The Revenue further contended that, the decisions relied upon by the assessee…

Kamla Shubham Estate, Mumbai vs. DCIT- CC -(3)(4), Mumbai

In the result, the appeals of the assessee for AYs 2008-09,

ITA 4215/MUM/2019[2008-09]Status: DisposedITAT Mumbai30 Aug 2022AY 2008-09

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकरअपीलसं/I.T.A. Nos.4215 To 4218 & 1577 & 1579/Mum/2019 (निर्धारणवर्ा / Assessment Years:2008-09 To 2012-13 & 2014-15) Kamla Shubham Estate बिधम/ Dcit Central Circle (3)(4) Ground Floor, Shanti Vimal, 19Th Floor, Air India Vs. P.M. Road, Vile Parle East, Building, Nariman Point, Mumbai-400057. Mumbai-400021. स्थायीलेखासं./जीआइआरसं./Pan/Gir No. :Aaifk6226E (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri Rashmikant Modi Ms. Ketki Rajeshirke Revenue By: Shri Vinay Sinha(Dr) सुनवाईकीतारीख / Date Of Hearing: 15/07/2022 घोषणाकीतारीख /Date Of Pronouncement: 30/08/2022 आदेश / O R D E R Per Bench These Appeals Preferred By The Assessee Are Against The Common Orders Of The Ld. Commissioner Of Income Tax (Appeals)-51, Mumbai [Hereinafter In Short “Ld. Cit(A)”] Dated 09.04.2019 For A.Y. 2008-09 To Ay. 2011-12 & Dated 11.02.2019 For Ays 2012-13 & 2014-15. Since Issues Involved Are Common, All The Appeals For All The Assessment Year/Years (Hereinafter Referred To As “Ay”) Were Heard Together. Both The Parties Also Argued Them Together Raising Similar Arguments On These Issues. Accordingly, For The Sake Of Convenience & Brevity, We Dispose All The Appeals By This Consolidated Order.

For Appellant: Shri Rashmikant ModiFor Respondent: Shri Vinay Sinha(DR)
Section 132(4)Section 143(2)Section 143(3)Section 153A

…d by the Hon’ble Bombay High Court in the cases of Continental Warehousing Corporation (Nhava Sheva) Ltd (supra), CIT vs Murli Agro Products Ltd (49 taxmann.com 172) and the Special Bench of this Tribunal in the case of All Cargo Global Logistics Ltd vs DCIT (137 ITD 287). The Revenue had alternatively contended that, the statements recorded u/s 132(4) carries sufficient evidentiary value and therefore any admission by the assessee to any wrong doing itself constitutes incriminating material to justify additions in unabated assessments. The Revenue further contended that, the decisions relied upon by the assessee…

Kamla Landmarc Infra, Mumbai vs. DCIT(3)(4) Central Circle, Mumbai

In the result, the appeals of the assessee for AYs 2008-09,

ITA 1632/MUM/2019[2014-15]Status: DisposedITAT Mumbai30 Aug 2022AY 2014-15

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकर अपील सं/ I.T.A. Nos. 1626 To 1632/Mum/2019 (निर्धारण वर्ा / Assessment Years:2008-09 To 2014-15) Kamla Landmarc Infra बिधम/ Dcit, Central Circle-3(4) 19Th Floor, Air India Ground Floor, Shanti Vimal, P. Vs. M. Road, Vile Parle East, Building, Nariman Point, Mumbai-400057. Mumbai-400021. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aahfk9340C (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri Rashmikant Modi Ms. Ketki Rajeshirke Revenue By: Shri Vinay Sinha (Dr) सुनवाई की तारीख / Date Of Hearing: 15/07/2022 घोषणा की तारीख /Date Of Pronouncement: 30/08/2022 आदेश / O R D E R Per Bench These Appeals Preferred By The Assessee Are Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals)-51, Mumbai [Hereinafter In Short “Ld. Cit(A)”] Dated 10.01.2019 For A.Y. 2008- 09 To Ay. 2014-15. Since Issues Involved Are Common, All The Appeals For All The Assessment Year/Years (Hereinafter Referred To As “Ay”) Were Heard Together. Both The Parties Also Argued Them Together Raising Similar Arguments On These Issues. Accordingly, For The Sake Of Convenience & Brevity, We Dispose All The Appeals By This Consolidated Order. 2. Before We Advert To The Grounds Taken In The Cross Appeals, It Would First Be Relevant To Cull Out The Basic Facts Of The Case & Effect Of Law In Brief In Respect Of Certain Ay’S. The Assessee Is A Primarily

For Appellant: Shri Rashmikant ModiFor Respondent: Shri Vinay Sinha (DR)
Section 132(4)Section 143(2)Section 143(3)Section 153A

…of Continental Warehousing A.Ys. 2008-09 to 2014-15 Kamla Landmarc Infra Corporation (Nhava Sheva) Ltd (supra), CIT vs Murli Agro Products Ltd (49 taxmann.com 172) and the Special Bench of this Tribunal in the case of All Cargo Global Logistics Ltd vs DCIT (137 ITD 287). The Revenue had alternatively contended that, the statements recorded u/s 132(4) carries sufficient evidentiary value and therefore any admission by the assessee to any wrong doing itself constitutes incriminating material to justify additions in unabated assessments. The Revenue further contended that, the decisions relied upon by the assessee…

Kamla Landmarc Infra, Mumbai vs. DCIT(3)(4) Central Circle, Mumbai

In the result, the appeals of the assessee for AYs 2008-09,

ITA 1631/MUM/2019[2013-14]Status: DisposedITAT Mumbai30 Aug 2022AY 2013-14

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकर अपील सं/ I.T.A. Nos. 1626 To 1632/Mum/2019 (निर्धारण वर्ा / Assessment Years:2008-09 To 2014-15) Kamla Landmarc Infra बिधम/ Dcit, Central Circle-3(4) 19Th Floor, Air India Ground Floor, Shanti Vimal, P. Vs. M. Road, Vile Parle East, Building, Nariman Point, Mumbai-400057. Mumbai-400021. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aahfk9340C (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri Rashmikant Modi Ms. Ketki Rajeshirke Revenue By: Shri Vinay Sinha (Dr) सुनवाई की तारीख / Date Of Hearing: 15/07/2022 घोषणा की तारीख /Date Of Pronouncement: 30/08/2022 आदेश / O R D E R Per Bench These Appeals Preferred By The Assessee Are Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals)-51, Mumbai [Hereinafter In Short “Ld. Cit(A)”] Dated 10.01.2019 For A.Y. 2008- 09 To Ay. 2014-15. Since Issues Involved Are Common, All The Appeals For All The Assessment Year/Years (Hereinafter Referred To As “Ay”) Were Heard Together. Both The Parties Also Argued Them Together Raising Similar Arguments On These Issues. Accordingly, For The Sake Of Convenience & Brevity, We Dispose All The Appeals By This Consolidated Order. 2. Before We Advert To The Grounds Taken In The Cross Appeals, It Would First Be Relevant To Cull Out The Basic Facts Of The Case & Effect Of Law In Brief In Respect Of Certain Ay’S. The Assessee Is A Primarily

For Appellant: Shri Rashmikant ModiFor Respondent: Shri Vinay Sinha (DR)
Section 132(4)Section 143(2)Section 143(3)Section 153A

…of Continental Warehousing A.Ys. 2008-09 to 2014-15 Kamla Landmarc Infra Corporation (Nhava Sheva) Ltd (supra), CIT vs Murli Agro Products Ltd (49 taxmann.com 172) and the Special Bench of this Tribunal in the case of All Cargo Global Logistics Ltd vs DCIT (137 ITD 287). The Revenue had alternatively contended that, the statements recorded u/s 132(4) carries sufficient evidentiary value and therefore any admission by the assessee to any wrong doing itself constitutes incriminating material to justify additions in unabated assessments. The Revenue further contended that, the decisions relied upon by the assessee…

Kamla Landmarc Infra, Mumbai vs. DCIT(3)(4) Central Circle, Mumbai

In the result, the appeals of the assessee for AYs 2008-09,

ITA 1630/MUM/2019[2012-13]Status: DisposedITAT Mumbai30 Aug 2022AY 2012-13

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकर अपील सं/ I.T.A. Nos. 1626 To 1632/Mum/2019 (निर्धारण वर्ा / Assessment Years:2008-09 To 2014-15) Kamla Landmarc Infra बिधम/ Dcit, Central Circle-3(4) 19Th Floor, Air India Ground Floor, Shanti Vimal, P. Vs. M. Road, Vile Parle East, Building, Nariman Point, Mumbai-400057. Mumbai-400021. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aahfk9340C (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri Rashmikant Modi Ms. Ketki Rajeshirke Revenue By: Shri Vinay Sinha (Dr) सुनवाई की तारीख / Date Of Hearing: 15/07/2022 घोषणा की तारीख /Date Of Pronouncement: 30/08/2022 आदेश / O R D E R Per Bench These Appeals Preferred By The Assessee Are Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals)-51, Mumbai [Hereinafter In Short “Ld. Cit(A)”] Dated 10.01.2019 For A.Y. 2008- 09 To Ay. 2014-15. Since Issues Involved Are Common, All The Appeals For All The Assessment Year/Years (Hereinafter Referred To As “Ay”) Were Heard Together. Both The Parties Also Argued Them Together Raising Similar Arguments On These Issues. Accordingly, For The Sake Of Convenience & Brevity, We Dispose All The Appeals By This Consolidated Order. 2. Before We Advert To The Grounds Taken In The Cross Appeals, It Would First Be Relevant To Cull Out The Basic Facts Of The Case & Effect Of Law In Brief In Respect Of Certain Ay’S. The Assessee Is A Primarily

For Appellant: Shri Rashmikant ModiFor Respondent: Shri Vinay Sinha (DR)
Section 132(4)Section 143(2)Section 143(3)Section 153A

…of Continental Warehousing A.Ys. 2008-09 to 2014-15 Kamla Landmarc Infra Corporation (Nhava Sheva) Ltd (supra), CIT vs Murli Agro Products Ltd (49 taxmann.com 172) and the Special Bench of this Tribunal in the case of All Cargo Global Logistics Ltd vs DCIT (137 ITD 287). The Revenue had alternatively contended that, the statements recorded u/s 132(4) carries sufficient evidentiary value and therefore any admission by the assessee to any wrong doing itself constitutes incriminating material to justify additions in unabated assessments. The Revenue further contended that, the decisions relied upon by the assessee…

Kamla Landmarc Infra, Mumbai vs. DCIT(3)(4) Central Circle, Mumbai

In the result, the appeals of the assessee for AYs 2008-09,

ITA 1629/MUM/2019[2011-12]Status: DisposedITAT Mumbai30 Aug 2022AY 2011-12

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकर अपील सं/ I.T.A. Nos. 1626 To 1632/Mum/2019 (निर्धारण वर्ा / Assessment Years:2008-09 To 2014-15) Kamla Landmarc Infra बिधम/ Dcit, Central Circle-3(4) 19Th Floor, Air India Ground Floor, Shanti Vimal, P. Vs. M. Road, Vile Parle East, Building, Nariman Point, Mumbai-400057. Mumbai-400021. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aahfk9340C (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri Rashmikant Modi Ms. Ketki Rajeshirke Revenue By: Shri Vinay Sinha (Dr) सुनवाई की तारीख / Date Of Hearing: 15/07/2022 घोषणा की तारीख /Date Of Pronouncement: 30/08/2022 आदेश / O R D E R Per Bench These Appeals Preferred By The Assessee Are Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals)-51, Mumbai [Hereinafter In Short “Ld. Cit(A)”] Dated 10.01.2019 For A.Y. 2008- 09 To Ay. 2014-15. Since Issues Involved Are Common, All The Appeals For All The Assessment Year/Years (Hereinafter Referred To As “Ay”) Were Heard Together. Both The Parties Also Argued Them Together Raising Similar Arguments On These Issues. Accordingly, For The Sake Of Convenience & Brevity, We Dispose All The Appeals By This Consolidated Order. 2. Before We Advert To The Grounds Taken In The Cross Appeals, It Would First Be Relevant To Cull Out The Basic Facts Of The Case & Effect Of Law In Brief In Respect Of Certain Ay’S. The Assessee Is A Primarily

For Appellant: Shri Rashmikant ModiFor Respondent: Shri Vinay Sinha (DR)
Section 132(4)Section 143(2)Section 143(3)Section 153A

…of Continental Warehousing A.Ys. 2008-09 to 2014-15 Kamla Landmarc Infra Corporation (Nhava Sheva) Ltd (supra), CIT vs Murli Agro Products Ltd (49 taxmann.com 172) and the Special Bench of this Tribunal in the case of All Cargo Global Logistics Ltd vs DCIT (137 ITD 287). The Revenue had alternatively contended that, the statements recorded u/s 132(4) carries sufficient evidentiary value and therefore any admission by the assessee to any wrong doing itself constitutes incriminating material to justify additions in unabated assessments. The Revenue further contended that, the decisions relied upon by the assessee…

Kamla Landmarc Infra, Mumbai vs. DCIT(3)(4) Central Circle, Mumbai

In the result, the appeals of the assessee for AYs 2008-09,

ITA 1628/MUM/2019[2010-11]Status: DisposedITAT Mumbai30 Aug 2022AY 2010-11

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकर अपील सं/ I.T.A. Nos. 1626 To 1632/Mum/2019 (निर्धारण वर्ा / Assessment Years:2008-09 To 2014-15) Kamla Landmarc Infra बिधम/ Dcit, Central Circle-3(4) 19Th Floor, Air India Ground Floor, Shanti Vimal, P. Vs. M. Road, Vile Parle East, Building, Nariman Point, Mumbai-400057. Mumbai-400021. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aahfk9340C (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri Rashmikant Modi Ms. Ketki Rajeshirke Revenue By: Shri Vinay Sinha (Dr) सुनवाई की तारीख / Date Of Hearing: 15/07/2022 घोषणा की तारीख /Date Of Pronouncement: 30/08/2022 आदेश / O R D E R Per Bench These Appeals Preferred By The Assessee Are Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals)-51, Mumbai [Hereinafter In Short “Ld. Cit(A)”] Dated 10.01.2019 For A.Y. 2008- 09 To Ay. 2014-15. Since Issues Involved Are Common, All The Appeals For All The Assessment Year/Years (Hereinafter Referred To As “Ay”) Were Heard Together. Both The Parties Also Argued Them Together Raising Similar Arguments On These Issues. Accordingly, For The Sake Of Convenience & Brevity, We Dispose All The Appeals By This Consolidated Order. 2. Before We Advert To The Grounds Taken In The Cross Appeals, It Would First Be Relevant To Cull Out The Basic Facts Of The Case & Effect Of Law In Brief In Respect Of Certain Ay’S. The Assessee Is A Primarily

For Appellant: Shri Rashmikant ModiFor Respondent: Shri Vinay Sinha (DR)
Section 132(4)Section 143(2)Section 143(3)Section 153A

…of Continental Warehousing A.Ys. 2008-09 to 2014-15 Kamla Landmarc Infra Corporation (Nhava Sheva) Ltd (supra), CIT vs Murli Agro Products Ltd (49 taxmann.com 172) and the Special Bench of this Tribunal in the case of All Cargo Global Logistics Ltd vs DCIT (137 ITD 287). The Revenue had alternatively contended that, the statements recorded u/s 132(4) carries sufficient evidentiary value and therefore any admission by the assessee to any wrong doing itself constitutes incriminating material to justify additions in unabated assessments. The Revenue further contended that, the decisions relied upon by the assessee…

Kamla Landmarc Infra, Mumbai vs. DCIT(3)(4) Central Circle, Mumbai

In the result, the appeals of the assessee for AYs 2008-09,

ITA 1627/MUM/2019[2009-10]Status: DisposedITAT Mumbai30 Aug 2022AY 2009-10

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकर अपील सं/ I.T.A. Nos. 1626 To 1632/Mum/2019 (निर्धारण वर्ा / Assessment Years:2008-09 To 2014-15) Kamla Landmarc Infra बिधम/ Dcit, Central Circle-3(4) 19Th Floor, Air India Ground Floor, Shanti Vimal, P. Vs. M. Road, Vile Parle East, Building, Nariman Point, Mumbai-400057. Mumbai-400021. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aahfk9340C (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri Rashmikant Modi Ms. Ketki Rajeshirke Revenue By: Shri Vinay Sinha (Dr) सुनवाई की तारीख / Date Of Hearing: 15/07/2022 घोषणा की तारीख /Date Of Pronouncement: 30/08/2022 आदेश / O R D E R Per Bench These Appeals Preferred By The Assessee Are Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals)-51, Mumbai [Hereinafter In Short “Ld. Cit(A)”] Dated 10.01.2019 For A.Y. 2008- 09 To Ay. 2014-15. Since Issues Involved Are Common, All The Appeals For All The Assessment Year/Years (Hereinafter Referred To As “Ay”) Were Heard Together. Both The Parties Also Argued Them Together Raising Similar Arguments On These Issues. Accordingly, For The Sake Of Convenience & Brevity, We Dispose All The Appeals By This Consolidated Order. 2. Before We Advert To The Grounds Taken In The Cross Appeals, It Would First Be Relevant To Cull Out The Basic Facts Of The Case & Effect Of Law In Brief In Respect Of Certain Ay’S. The Assessee Is A Primarily

For Appellant: Shri Rashmikant ModiFor Respondent: Shri Vinay Sinha (DR)
Section 132(4)Section 143(2)Section 143(3)Section 153A

…of Continental Warehousing A.Ys. 2008-09 to 2014-15 Kamla Landmarc Infra Corporation (Nhava Sheva) Ltd (supra), CIT vs Murli Agro Products Ltd (49 taxmann.com 172) and the Special Bench of this Tribunal in the case of All Cargo Global Logistics Ltd vs DCIT (137 ITD 287). The Revenue had alternatively contended that, the statements recorded u/s 132(4) carries sufficient evidentiary value and therefore any admission by the assessee to any wrong doing itself constitutes incriminating material to justify additions in unabated assessments. The Revenue further contended that, the decisions relied upon by the assessee…

Kamla Landmarc Infra, Mumbai vs. DCIT (3)(4) Central Circle, Mumbai

In the result, the appeals of the assessee for AYs 2008-09,

ITA 1626/MUM/2019[2008-09]Status: DisposedITAT Mumbai30 Aug 2022AY 2008-09

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकर अपील सं/ I.T.A. Nos. 1626 To 1632/Mum/2019 (निर्धारण वर्ा / Assessment Years:2008-09 To 2014-15) Kamla Landmarc Infra बिधम/ Dcit, Central Circle-3(4) 19Th Floor, Air India Ground Floor, Shanti Vimal, P. Vs. M. Road, Vile Parle East, Building, Nariman Point, Mumbai-400057. Mumbai-400021. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aahfk9340C (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri Rashmikant Modi Ms. Ketki Rajeshirke Revenue By: Shri Vinay Sinha (Dr) सुनवाई की तारीख / Date Of Hearing: 15/07/2022 घोषणा की तारीख /Date Of Pronouncement: 30/08/2022 आदेश / O R D E R Per Bench These Appeals Preferred By The Assessee Are Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals)-51, Mumbai [Hereinafter In Short “Ld. Cit(A)”] Dated 10.01.2019 For A.Y. 2008- 09 To Ay. 2014-15. Since Issues Involved Are Common, All The Appeals For All The Assessment Year/Years (Hereinafter Referred To As “Ay”) Were Heard Together. Both The Parties Also Argued Them Together Raising Similar Arguments On These Issues. Accordingly, For The Sake Of Convenience & Brevity, We Dispose All The Appeals By This Consolidated Order. 2. Before We Advert To The Grounds Taken In The Cross Appeals, It Would First Be Relevant To Cull Out The Basic Facts Of The Case & Effect Of Law In Brief In Respect Of Certain Ay’S. The Assessee Is A Primarily

For Appellant: Shri Rashmikant ModiFor Respondent: Shri Vinay Sinha (DR)
Section 132(4)Section 143(2)Section 143(3)Section 153A

…of Continental Warehousing A.Ys. 2008-09 to 2014-15 Kamla Landmarc Infra Corporation (Nhava Sheva) Ltd (supra), CIT vs Murli Agro Products Ltd (49 taxmann.com 172) and the Special Bench of this Tribunal in the case of All Cargo Global Logistics Ltd vs DCIT (137 ITD 287). The Revenue had alternatively contended that, the statements recorded u/s 132(4) carries sufficient evidentiary value and therefore any admission by the assessee to any wrong doing itself constitutes incriminating material to justify additions in unabated assessments. The Revenue further contended that, the decisions relied upon by the assessee…