CIT v. Continental Warehousing Corporation (Nhava Sheva) Ltd.

374 ITR 645High Court2015#14 most cited

What is CIT v. Continental Warehousing Corporation (Nhava Sheva) Ltd. authority for?

In Section 153A proceedings, the scope of assessment extends to abated proceedings, enabling an assessee to raise fresh legal claims that could have been made in regular assessment proceedings.

1,823

judgments rely on this decision, according to BharatTax’s citation analysis of 367,302 Indian tax judgments — from 2015 to 2026.

Also referred to as

Continental Warehousing Corporation · Section 153A · scope of 153A assessment · abated proceedings · fresh claims in search assessment · assessee's claims 153A · Section 132 · assessment procedure · search and seizure assessment

Also reported as

58 Taxmann.com 78

Sections most often in play

Section 153ASection 132Section 143(3)Section 147Section 148Section 153CSection 68Section 69A

Issues it is cited on

casus omissussection 158b(b)section 158bb(1)section 153(a)section 153a(1)(b)section 158bbdeemed dividendsection 153(1)section 2(22)section 2(22)(e)section 153a(1)section 132a

Judgments citing CIT v. Continental Warehousing Corporation (Nhava Sheva) Ltd.

Shree Raj Exports P.Ltd, Mumbai vs. DCIT Cen Cir 12, Mumbai

In the result, the appeals of assessee are allowed

ITA 4027/MUM/2014[2008-09]Status: DisposedITAT Mumbai28 Sept 2018AY 2008-09

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

For Appellant: Shri K Gopal, ARFor Respondent: Shri DG Pansari, DR
Section 143(3)Section 153A

…rtment on 31.08.2010 which was issued before the date of search by the Income Tax Department on 10.03.2010. 13. We have gone through the case law of Hon’ble Bombay High Court in the case of CIT vs. Continental Warehousing Corporation (Nhava Sheva) Ltd. (2015) 374 ITR 645 (Bom). Despite a specific query raised by the Bench, the learned CIT Departmental Representative, could not produce or could not state that there is incriminating material was found during the search relating to these additions made by AO of Gross Profit estimated on alleged unrecorded sales and addition on account of undisclosed initial investme…

Shree Raj Exports P.Ltd, Mumbai vs. DCIT Cen Cir 12, Mumbai

In the result, the appeals of assessee are allowed

ITA 4026/MUM/2014[2007-08]Status: DisposedITAT Mumbai28 Sept 2018AY 2007-08

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

For Appellant: Shri K Gopal, ARFor Respondent: Shri DG Pansari, DR
Section 143(3)Section 153A

…rtment on 31.08.2010 which was issued before the date of search by the Income Tax Department on 10.03.2010. 13. We have gone through the case law of Hon’ble Bombay High Court in the case of CIT vs. Continental Warehousing Corporation (Nhava Sheva) Ltd. (2015) 374 ITR 645 (Bom). Despite a specific query raised by the Bench, the learned CIT Departmental Representative, could not produce or could not state that there is incriminating material was found during the search relating to these additions made by AO of Gross Profit estimated on alleged unrecorded sales and addition on account of undisclosed initial investme…

Shree Raj Exports P.Ltd, Mumbai vs. DCIT Cen Cir 12, Mumbai

In the result, the appeals of assessee are allowed

ITA 4025/MUM/2014[2006-07]Status: DisposedITAT Mumbai28 Sept 2018AY 2006-07

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

For Appellant: Shri K Gopal, ARFor Respondent: Shri DG Pansari, DR
Section 143(3)Section 153A

…rtment on 31.08.2010 which was issued before the date of search by the Income Tax Department on 10.03.2010. 13. We have gone through the case law of Hon’ble Bombay High Court in the case of CIT vs. Continental Warehousing Corporation (Nhava Sheva) Ltd. (2015) 374 ITR 645 (Bom). Despite a specific query raised by the Bench, the learned CIT Departmental Representative, could not produce or could not state that there is incriminating material was found during the search relating to these additions made by AO of Gross Profit estimated on alleged unrecorded sales and addition on account of undisclosed initial investme…

Shree Raj Exports P.Ltd, Mumbai vs. DCIT Cen Cir 12, Mumbai

In the result, the appeals of assessee are allowed

ITA 4024/MUM/2014[2005-06]Status: DisposedITAT Mumbai28 Sept 2018AY 2005-06

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

For Appellant: Shri K Gopal, ARFor Respondent: Shri DG Pansari, DR
Section 143(3)Section 153A

…rtment on 31.08.2010 which was issued before the date of search by the Income Tax Department on 10.03.2010. 13. We have gone through the case law of Hon’ble Bombay High Court in the case of CIT vs. Continental Warehousing Corporation (Nhava Sheva) Ltd. (2015) 374 ITR 645 (Bom). Despite a specific query raised by the Bench, the learned CIT Departmental Representative, could not produce or could not state that there is incriminating material was found during the search relating to these additions made by AO of Gross Profit estimated on alleged unrecorded sales and addition on account of undisclosed initial investme…

DCIT Cen Cir 5(1), Mumbai vs. Anand Rathi Finanical Services Ltd, Mumbai

In the result, appeals of the Revenue are dismissed and appeal of the assessee is partly allowed as indicated above

ITA 958/MUM/2017[2014-15]Status: DisposedITAT Mumbai26 Sept 2018AY 2014-15

Bench: Shri C.N. Prasad, Hon'Ble & Shri Rajesh Kumar, Hon'Ble

For Appellant: Shri Vijay Mehta &For Respondent: Shri R.P. Meena &
Section 132Section 143Section 14ASection 153Section 153A

…overed during the course of search. In holding so, the Ld.CIT(A) followed the decisions of the Hon'ble Jurisdictional High Court in the case of CIT v. Murli Agro Products Ltd., [ITA.No. 36 of 2009 dated 26.10.2010]; CIT v. Continental Warehousing Corporation [374 ITR 645] and the Special Bench decision of the Mumbai in the case of All Cargo Global Logistics Ltd. v. DCIT [137 ITD 287], against this order the Revenue is in appeal before us for the Assessment Years 2008-09, 2010-11 & 2011-12. (A. Ys: 2013-14, 2008-09, 2010-11 TO 2014-15) M/s. Anand Rathi Financial Services Ltd., 6. Ld. DR vehemently supported the or…

DCIT Cen Cir 5(1), Mumbai vs. Anand Rathi Finanical Services Ltd, Mumbai

In the result, appeals of the Revenue are dismissed and appeal of the assessee is partly allowed as indicated above

ITA 957/MUM/2017[2013-14]Status: DisposedITAT Mumbai26 Sept 2018AY 2013-14

Bench: Shri C.N. Prasad, Hon'Ble & Shri Rajesh Kumar, Hon'Ble

For Appellant: Shri Vijay Mehta &For Respondent: Shri R.P. Meena &
Section 132Section 143Section 14ASection 153Section 153A

…overed during the course of search. In holding so, the Ld.CIT(A) followed the decisions of the Hon'ble Jurisdictional High Court in the case of CIT v. Murli Agro Products Ltd., [ITA.No. 36 of 2009 dated 26.10.2010]; CIT v. Continental Warehousing Corporation [374 ITR 645] and the Special Bench decision of the Mumbai in the case of All Cargo Global Logistics Ltd. v. DCIT [137 ITD 287], against this order the Revenue is in appeal before us for the Assessment Years 2008-09, 2010-11 & 2011-12. (A. Ys: 2013-14, 2008-09, 2010-11 TO 2014-15) M/s. Anand Rathi Financial Services Ltd., 6. Ld. DR vehemently supported the or…

DCIT Cen Cir 5(1), Mumbai vs. Anand Rathi Finanical Services Ltd, Mumbai

In the result, appeals of the Revenue are dismissed and appeal of the assessee is partly allowed as indicated above

ITA 956/MUM/2017[2012-13]Status: DisposedITAT Mumbai26 Sept 2018AY 2012-13

Bench: Shri C.N. Prasad, Hon'Ble & Shri Rajesh Kumar, Hon'Ble

For Appellant: Shri Vijay Mehta &For Respondent: Shri R.P. Meena &
Section 132Section 143Section 14ASection 153Section 153A

…overed during the course of search. In holding so, the Ld.CIT(A) followed the decisions of the Hon'ble Jurisdictional High Court in the case of CIT v. Murli Agro Products Ltd., [ITA.No. 36 of 2009 dated 26.10.2010]; CIT v. Continental Warehousing Corporation [374 ITR 645] and the Special Bench decision of the Mumbai in the case of All Cargo Global Logistics Ltd. v. DCIT [137 ITD 287], against this order the Revenue is in appeal before us for the Assessment Years 2008-09, 2010-11 & 2011-12. (A. Ys: 2013-14, 2008-09, 2010-11 TO 2014-15) M/s. Anand Rathi Financial Services Ltd., 6. Ld. DR vehemently supported the or…

DCIT Cen Cir 5(1), Mumbai vs. Anand Rathi Finanical Services Ltd, Mumbai

In the result, appeals of the Revenue are dismissed and appeal of the assessee is partly allowed as indicated above

ITA 955/MUM/2017[2011-12]Status: DisposedITAT Mumbai26 Sept 2018AY 2011-12

Bench: Shri C.N. Prasad, Hon'Ble & Shri Rajesh Kumar, Hon'Ble

For Appellant: Shri Vijay Mehta &For Respondent: Shri R.P. Meena &
Section 132Section 143Section 14ASection 153Section 153A

…overed during the course of search. In holding so, the Ld.CIT(A) followed the decisions of the Hon'ble Jurisdictional High Court in the case of CIT v. Murli Agro Products Ltd., [ITA.No. 36 of 2009 dated 26.10.2010]; CIT v. Continental Warehousing Corporation [374 ITR 645] and the Special Bench decision of the Mumbai in the case of All Cargo Global Logistics Ltd. v. DCIT [137 ITD 287], against this order the Revenue is in appeal before us for the Assessment Years 2008-09, 2010-11 & 2011-12. (A. Ys: 2013-14, 2008-09, 2010-11 TO 2014-15) M/s. Anand Rathi Financial Services Ltd., 6. Ld. DR vehemently supported the or…

DCIT Cen Cir 5(1), Mumbai vs. Anand Rathi Finanical Services Ltd, Mumbai

In the result, appeals of the Revenue are dismissed and appeal of the assessee is partly allowed as indicated above

ITA 954/MUM/2017[2010-11]Status: DisposedITAT Mumbai26 Sept 2018AY 2010-11

Bench: Shri C.N. Prasad, Hon'Ble & Shri Rajesh Kumar, Hon'Ble

For Appellant: Shri Vijay Mehta &For Respondent: Shri R.P. Meena &
Section 132Section 143Section 14ASection 153Section 153A

…overed during the course of search. In holding so, the Ld.CIT(A) followed the decisions of the Hon'ble Jurisdictional High Court in the case of CIT v. Murli Agro Products Ltd., [ITA.No. 36 of 2009 dated 26.10.2010]; CIT v. Continental Warehousing Corporation [374 ITR 645] and the Special Bench decision of the Mumbai in the case of All Cargo Global Logistics Ltd. v. DCIT [137 ITD 287], against this order the Revenue is in appeal before us for the Assessment Years 2008-09, 2010-11 & 2011-12. (A. Ys: 2013-14, 2008-09, 2010-11 TO 2014-15) M/s. Anand Rathi Financial Services Ltd., 6. Ld. DR vehemently supported the or…

DCIT Cen Cir 5(1), Mumbai vs. Anand Rathi Finanical Services Ltd, Mumbai

In the result, appeals of the Revenue are dismissed and appeal of the assessee is partly allowed as indicated above

ITA 952/MUM/2017[2008-09]Status: DisposedITAT Mumbai26 Sept 2018AY 2008-09

Bench: Shri C.N. Prasad, Hon'Ble & Shri Rajesh Kumar, Hon'Ble

For Appellant: Shri Vijay Mehta &For Respondent: Shri R.P. Meena &
Section 132Section 143Section 14ASection 153Section 153A

…overed during the course of search. In holding so, the Ld.CIT(A) followed the decisions of the Hon'ble Jurisdictional High Court in the case of CIT v. Murli Agro Products Ltd., [ITA.No. 36 of 2009 dated 26.10.2010]; CIT v. Continental Warehousing Corporation [374 ITR 645] and the Special Bench decision of the Mumbai in the case of All Cargo Global Logistics Ltd. v. DCIT [137 ITD 287], against this order the Revenue is in appeal before us for the Assessment Years 2008-09, 2010-11 & 2011-12. (A. Ys: 2013-14, 2008-09, 2010-11 TO 2014-15) M/s. Anand Rathi Financial Services Ltd., 6. Ld. DR vehemently supported the or…

Anand Rathi Financial Services Ltd, Mumbai vs. DCIT Cen Cir 5(1), Mumbai

In the result, appeals of the Revenue are dismissed and appeal of the assessee is partly allowed as indicated above

ITA 843/MUM/2017[2013-14]Status: DisposedITAT Mumbai26 Sept 2018AY 2013-14

Bench: Shri C.N. Prasad, Hon'Ble & Shri Rajesh Kumar, Hon'Ble

For Appellant: Shri Vijay Mehta &For Respondent: Shri R.P. Meena &
Section 132Section 143Section 14ASection 153Section 153A

…overed during the course of search. In holding so, the Ld.CIT(A) followed the decisions of the Hon'ble Jurisdictional High Court in the case of CIT v. Murli Agro Products Ltd., [ITA.No. 36 of 2009 dated 26.10.2010]; CIT v. Continental Warehousing Corporation [374 ITR 645] and the Special Bench decision of the Mumbai in the case of All Cargo Global Logistics Ltd. v. DCIT [137 ITD 287], against this order the Revenue is in appeal before us for the Assessment Years 2008-09, 2010-11 & 2011-12. (A. Ys: 2013-14, 2008-09, 2010-11 TO 2014-15) M/s. Anand Rathi Financial Services Ltd., 6. Ld. DR vehemently supported the or…

DCIT, CC-II, Chandigarh vs. M/S Chandigarh Developers Pvt. Ltd., Chandigarh

In the result, the appeal of the Revenue is

ITA 994/CHANDI/2017[2010-11]Status: DisposedITAT Chandigarh24 Sept 2018AY 2010-11

Bench: Ms.Diva Singh & Ms. Annapurna Guptathe D.C.I.T., Vs. M/S Chandigarh Developers Pvt. Ltd., Central Circle-Ii, Sco 49-50, Sector 26, Chandigarh. Chandigarh. Pan: Aadcc6359G (Appellant) (Respondent)

For Appellant: Shri Gulshan Raj, CIT DRFor Respondent: Shri Ashwani Kumar, CA
Section 132Section 153ASection 68

…IN THE INCOME TAX APPELLATE TRIBUNAL DIVISION BENCH ‘A’, CHANDIGARH BEFORE MS.DIVA SINGH, JUDICIAL MEMBER AND MS. ANNAPURNA GUPTA, ACCOUNTANT MEMBER The D.C.I.T., Vs. M/s Chandigarh Developers Pvt. Ltd., Central Circle-II, SCO 49-50, Sector 26, Chandigarh. Chandigarh. PAN: AADCC6359G (Appellant) (Respondent) Appellant by : Shri Gulshan Raj, CIT DR Respondent by : Shri Ashwani Kumar, CA Date of hearing : 09.08.2018 Date of Pronouncement : 24.09.2018 ORDER PER ANNAPURNA GUPTA, A.M.: The present appeal has been filed by the Revenue against the order of Commissioner of Income Tax(Appeals)- 3, Gurgaon [hereina…

DCIT Cen Cir 7(1), Mumbai vs. Rekha Jhunjhunwala, Mumbai

In the result, both the appeals of Revenue are dismissed

ITA 3822/MUM/2016[2006-07]Status: DisposedITAT Mumbai19 Sept 2018AY 2006-07

Bench: Shri R.C.Sharma, Am & Shri Sandeep Gosain, Jm

Section 132Section 139Section 143(3)Section 14ASection 153A

…Whether on the facts and in the circumstances of the case and in law, the CIT(A), was justified in directing the AO to delete the disallowance u/s 14A of Rs.72,44,504/- made, relying on the decision of Bombay High Court in the case of All Cargo Logistics Ltd(374 ITR 645). without appreciating the fact that the decision of the High Court has not been accepted by the department and SLP has been filed and the same is pending. Smt. Rekha Jhunjhunwala 3. Rival contentions have been heard and record perused. 4. Facts in brief are that assessee is earning income from business house property and capital gains. During th…

DCIT Cen Cir 2(1), Mumbai vs. United Stock Exchange of India Ltd, Mumbai

ITA 541/MUM/2017[2009-10]Status: DisposedITAT Mumbai12 Sept 2018AY 2009-10

Bench: Shri Saktijit Dey, Jm & Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./I.T.A. No.541/Mum/2017 (िनधा"रणवष" / Assessment Year: 2009-10) Deputy Commissioner Of Income Tax United Stock Exchange Of India Ltd. (Since Merged With Bse Limited) Central Circle-2(1) बनाम/ 25Th Floor (West Wing), P.J. Towers Room No.804,8Th Floor Vs. Dalal Street, Fort Old Cgo Building, Annex Mumbai-400 001 M.K.Road,Mumbai-400 020 "थायीलेखासं./जीआइआरसं./Pan/Gir No.Aabcu-0464-G (अपीलाथ"/Appellant) (""थ" / Respondent) : & Cross Objection No.103/Mum/2018 (िनधा"रणवष" / Assessment Year: 2009-10) United Stock Exchange Of India Ltd. Deputy Commissioner Of Income (Since Merged With Bse Limited) Tax Central Circle-2(1) बनाम/ 25Th Floor (West Wing), P.J. Towers Room No.804,8Th Floor Vs. Dalal Street, Fort Old Cgo Building, Annex Mumbai-400 001 M.K.Road,Mumbai-400 020 "थायीलेखासं./जीआइआरसं./Pan/Gir No.Aabcu-0464-G (अपीलाथ"/Appellant) (""थ" / Respondent) :

For Appellant: Vijay Mehta, Ld. ARFor Respondent: Vidisha Kalra, Ld. CIT DR
Section 132Section 132(1)Section 132ASection 139Section 143(3)Section 153ASection 153A(1)Section 3

…al return of income which could not be controverted by the revenue. 6. The aforesaid factual matrix, as rightly noted by Ld. CIT(A), is squarely covered by the decision of Hon’ble Bombay High Court rendered in CIT Vs. Continental Warehousing Corporation [2015 374 ITR 645]. 13 & Co.No.103/Mum/2018 United Stock Exchange of India Ltd. Assessment Year: 2009-10 Similar view has been taken by Hon’ble Delhi High Court in CIT Vs. Kabul Chawla [380 ITR 573]. Further, upon perusal of SLP No. 18560 of 2015 dated 12/10/2015 admitted by Hon’ble Supreme Court against the decision of Hon’ble Bombay High Court rendered in CIT V…

DCIT CC 3(4) Cen RG 3, Mumbai vs. Brianna Infrastructure P.Ltd, Mumbai

ITA 5231/MUM/2015[2011-12]Status: DisposedITAT Mumbai06 Sept 2018AY 2011-12

Bench: Shri Joginder Singh & Shri Rajesh Kumarita Nos.5230 & 5231/Mum/2015 Assessment Years : 2010 – 11 & 2011-12 Dy Cit Cir 3(4) M/S Brianna Infrastructure Pvt Ltd., Mumbai 12/D1, Ground Floor, Vs. Estee Geejay Chs, Saibaba Nagar, Borivali (East), Mumbai 400 092. Pan Aadcb5321R (Appellant) (Respondent)

For Respondent: Shri H N Singh
Section 143(3)

…tions, which were intended to increase the turnover of the assessee only could not have been made. The assessee relied on the decisions of the Bombay high court in defence of his grounds of appeal namely CIT Vs Continental Warehousing Corporation Ltd (2015)374 ITR 645 (Bom) and CIT Vs Murli Agro Products Ltd. (2014) 49 taxmann.com 172(Bom Nag). 10. After perusal of orders of the authorities below and having heard the rival contentions, we find that the additions as made by the Assessing Officer were all on the basis of examination of records and information flowing/coming to him during the course of assess…

DCIT CC 3(4) Cen RG 3, Mumbai vs. Brianna Infrastructure P.Ltd, Mumbai

ITA 5230/MUM/2015[2010-11]Status: DisposedITAT Mumbai06 Sept 2018AY 2010-11

Bench: Shri Joginder Singh & Shri Rajesh Kumarita Nos.5230 & 5231/Mum/2015 Assessment Years : 2010 – 11 & 2011-12 Dy Cit Cir 3(4) M/S Brianna Infrastructure Pvt Ltd., Mumbai 12/D1, Ground Floor, Vs. Estee Geejay Chs, Saibaba Nagar, Borivali (East), Mumbai 400 092. Pan Aadcb5321R (Appellant) (Respondent)

For Respondent: Shri H N Singh
Section 143(3)

…tions, which were intended to increase the turnover of the assessee only could not have been made. The assessee relied on the decisions of the Bombay high court in defence of his grounds of appeal namely CIT Vs Continental Warehousing Corporation Ltd (2015)374 ITR 645 (Bom) and CIT Vs Murli Agro Products Ltd. (2014) 49 taxmann.com 172(Bom Nag). 10. After perusal of orders of the authorities below and having heard the rival contentions, we find that the additions as made by the Assessing Officer were all on the basis of examination of records and information flowing/coming to him during the course of assess…

ACIT, Central Circle- 26, New Delhi vs. Gd Foods Manufacturing (India) Pvt. Ltd., New Delhi

The appeal of the revenue is dismissed

ITA 1470/DEL/2018[2015-16]Status: DisposedITAT Delhi06 Sept 2018AY 2015-16

Bench: Shri Prashant Maharishi & Shri K. N. Chary

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Sanjit Singh, CIT DR
Section 132Section 153A

…018 ( By Revenue) 1464/Del/2018, 1465/Del/2018, 1466/Del/2018, 1467/Del/2018, 1468/Del/2018, 1469/Del/2018, 1470/Del/2018 Assessment Year 2009-10 to 2015-16 - Commissioner of Income-tax-ll, Thane v. Continental Warehousing Corporation (Nhava Sheva) Ltd [2015] 374 ITR 645 (Bombay); - Commissioner of Income-tax, Bangalore v. Lancy Constructions [2016] 66 taxmann.com 264 (Karnataka); - Principal Commissioner of Income-tax-4 v. Saumya Construction (P.) Ltd. 387 ITR 529 (Gujarat) viii. In search related matters guess work and that too based on absurdity is impermissible. There is plethora of decisions which supports t…

ACIT, Central Circle- 26, New Delhi vs. Gd Foods Manufacturing (India) Pvt. Ltd., New Delhi

The appeal of the revenue is dismissed

ITA 1469/DEL/2018[2014-15]Status: DisposedITAT Delhi06 Sept 2018AY 2014-15

Bench: Shri Prashant Maharishi & Shri K. N. Chary

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Sanjit Singh, CIT DR
Section 132Section 153A

…018 ( By Revenue) 1464/Del/2018, 1465/Del/2018, 1466/Del/2018, 1467/Del/2018, 1468/Del/2018, 1469/Del/2018, 1470/Del/2018 Assessment Year 2009-10 to 2015-16 - Commissioner of Income-tax-ll, Thane v. Continental Warehousing Corporation (Nhava Sheva) Ltd [2015] 374 ITR 645 (Bombay); - Commissioner of Income-tax, Bangalore v. Lancy Constructions [2016] 66 taxmann.com 264 (Karnataka); - Principal Commissioner of Income-tax-4 v. Saumya Construction (P.) Ltd. 387 ITR 529 (Gujarat) viii. In search related matters guess work and that too based on absurdity is impermissible. There is plethora of decisions which supports t…

ACIT, Central Circle- 26, New Delhi vs. Gd Foods Manufacturing (India) Pvt. Ltd., New Delhi

The appeal of the revenue is dismissed

ITA 1467/DEL/2018[2012-13]Status: DisposedITAT Delhi06 Sept 2018AY 2012-13

Bench: Shri Prashant Maharishi & Shri K. N. Chary

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Sanjit Singh, CIT DR
Section 132Section 153A

…018 ( By Revenue) 1464/Del/2018, 1465/Del/2018, 1466/Del/2018, 1467/Del/2018, 1468/Del/2018, 1469/Del/2018, 1470/Del/2018 Assessment Year 2009-10 to 2015-16 - Commissioner of Income-tax-ll, Thane v. Continental Warehousing Corporation (Nhava Sheva) Ltd [2015] 374 ITR 645 (Bombay); - Commissioner of Income-tax, Bangalore v. Lancy Constructions [2016] 66 taxmann.com 264 (Karnataka); - Principal Commissioner of Income-tax-4 v. Saumya Construction (P.) Ltd. 387 ITR 529 (Gujarat) viii. In search related matters guess work and that too based on absurdity is impermissible. There is plethora of decisions which supports t…

ACIT, Central Circle- 26, New Delhi vs. Gd Foods Manufacturing (India) Pvt. Ltd., New Delhi

The appeal of the revenue is dismissed

ITA 1466/DEL/2018[2011-12]Status: DisposedITAT Delhi06 Sept 2018AY 2011-12

Bench: Shri Prashant Maharishi & Shri K. N. Chary

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Sanjit Singh, CIT DR
Section 132Section 153A

…018 ( By Revenue) 1464/Del/2018, 1465/Del/2018, 1466/Del/2018, 1467/Del/2018, 1468/Del/2018, 1469/Del/2018, 1470/Del/2018 Assessment Year 2009-10 to 2015-16 - Commissioner of Income-tax-ll, Thane v. Continental Warehousing Corporation (Nhava Sheva) Ltd [2015] 374 ITR 645 (Bombay); - Commissioner of Income-tax, Bangalore v. Lancy Constructions [2016] 66 taxmann.com 264 (Karnataka); - Principal Commissioner of Income-tax-4 v. Saumya Construction (P.) Ltd. 387 ITR 529 (Gujarat) viii. In search related matters guess work and that too based on absurdity is impermissible. There is plethora of decisions which supports t…