Hardayal Milk Products Private Limited, Shikohabad vs. DCIT, Circle-2(2)(1), Firozabad
In the result, both the appeals filed by assessee are allowed
ITA 344/AGR/2025[2013-14]Status: DisposedITAT Agra29 Dec 2025AY 2013-14
Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh
Section 143(3)Section 145(3)Section 147Section 148Section 151Section 250Section 68
…riginal assessment. Allowing the petition the Court held that it cannot be said that there was any failure on part of the assessee to produce any material particulars, accordingly the notice issued by the AO is quashed. (c). ACIT v. Kad Housing P. Ltd. (2019) 69 ITR 550 (Delhi) ( Trib), wherein Hon’ble ITAT has observed that during the course of original assessment proceedings u/s. 143(3), the Assessee was specifically asked by the AO to discharge its onus u/s. 68 of the Act for the share application money received by it and after satisfying himself, he had accepted the transaction as genuine. Therefore, in the l…