Smt. Kusum Gupta, New Delhi vs. ITO, New Delhi
In the result, the appeal of the assessee is dismissed
ITA 6633/DEL/2014[2006-07]Status: PendingITAT Delhi06 Apr 2017AY 2006-07
Bench: Shri B.P. Jainassessment Year 2006-07 Smt. Kusum Kapoor, Vs. Ito, Ward-33(4), New 37/8, Ground Floor, Delhi. Old Rajender Nagar, New Delhi. Pan: Ajkpk 0066F (Appellant) (Respondent) Revenue By : S/Shri Kapil Goel & Mukul Gupta, Adv., Assessee(S) By : Ms. Bedobani Chaudhuri, Sr.D.R. सुनवाई क" तारीख/Date Of Hearing : 29/03/2017 घोषणा क" तारीख /Date Of Pronouncement: 06/04/2017 Order This Appeal Of The Assessee Arises From The Order Of Learned Cit(A)- Xxvi, New Delhi Vide Order Dated 27.10.2014 For The Assessment Year 2006-07. 2. The Assessee Is An Individual. The Return Of Income For A.Y. 2006-07 Was Furnished Declaring An Income Of Rs. 2,33,580/- Comprising Of Income From Business, Short Term Capital Gains & Income From Other Sources. An Action Under Section 133A Of The Act Was Conducted In The Case Of The Husband Of The Assessee Sh. Sanjeev Kapoor On 05.12.2005 & On The Basis Of The Information Revealed From The Survey, Notice Under Section 148 Dated 27.02.2013 Was Issued To The Assessee. In The Survey Conducted, An Agreement Pertaining To A Plot In Kundli Measuring 500 2
For Respondent: S/Shri Kapil Goel and Mukul Gupta, Adv
Section 133ASection 147Section 148Section 292CSection 3
…dence or conclusion. The function of the AO is to administerthe statute with solicitude for the public exchequer with an in- built' idea offairness to taxpayers. As observed by the Delhi High Court in Central ProvincesManganese Ore Company. Ltd. v. ITO [1991] 191 ITR 662, for initiation of actionunder section 147(a) (as the provision stood at the relevant time) fulfillment of the two requisite conditions in that regard is essentiet. At that stage, the finaloutcome of the proceeding is not relevant. In other words, ad: the initiation stage what is required is reason to believe, but not the established fact of esca…