DCIT, Cir. -7(1), Kolkata vs. M/S Shree Jewellers Pvt. Ltd., Kolkata
In the result, all the three appeals of the Revenue stand dismissed
ITA 593/KOL/2021[2012-13]Status: DisposedITAT Kolkata24 Nov 2022AY 2012-13
Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A Nos.591,592&593/Kol/2021 Assessment Years: 2007-08, 2011-12 & 2012-13 Dcit, Circle-7(1), Kolkata.................................................................……Appellant Vs. M/S Shreejee Jewellers Pvt. Ltd..…...................……........……...…..…..Respondent 103, Park Street, Kolkata-700016. [Pan: Aaecs8312C] Appearances By: Shri Rajeeva Kumar, Ar, Appeared On Behalf Of The Appellant. Shri Partha Pratim Barman, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 11, 2022 Date Of Pronouncing The Order : November 24, 2022 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Appeals Have Been Preferred By The Revenue Against The Separate Orders All Dated 23.06.2021 Of The National Faceless Appeal Centre (Hereinafter Referred To As The ‘Cit(A)’) Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). Since, The Appeals Pertained To The Same Assessee & Common Issues Are Involved & Hence, All These Appeals Have Been Heard Together & Are Being Disposed Off By This Common Order. The Revenue’S Appeal Ita No.591/Kol/2021 For Assessment Year 2007-08 Is Taken As The Lead Case. 2. Ita No.591/Kol/2021 - The Revenue In This Appeal Has Taken The Following Grounds Of Appeal:
Section 132(4)Section 143(1)Section 250Section 69C
…relied upon the following cases: 1. Mohar Singh v. Dy. CIT[2002]77 TTJ(Agra)218 2. Dy. CIT v. Sahara India Financial Corpn. Ltd. [2003] 81 TTJ(Lucknow) 389. 3. ITO v. Matadin Snehlata (HUF) [2003]81 TTJ (AII.) 995. 4. Jagadamba Construction Co. v. ITO [2004] 3 SOT 670 (Jodh.) 5. Sumak Powercap Ltd. v. Asstt. CIT [2005] 90 TTJ (Lucknow) 420 The appellant relied upon on various court cases mentioned in its submission. Moreover I also observed in the assessment order that the AO himself contradicting his finding on the facts mentioned in the assessment order, I am unable to accept AO's conclusions that loan credito…