CIT v. Kabul Chawla

380 ITR 573High Court2016#3 most cited

What is CIT v. Kabul Chawla authority for?

In a search assessment under Section 153A, additions can only be made for completed or non-abated assessment years if incriminating material relevant to those years is found during the search, although notice under Section 153A(1) is mandatorily issued for six assessment years preceding the search.

3,235

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2015 to 2026.

Also referred to as

CIT v. Kabul Chawla · Kabul Chawla · section 153A · section 132 · incriminating material · search assessment · non-abated years · scope of assessment · additions · undisclosed income

Also reported as

61 Taxmann.com 412234 Taxmann 300281 CTR 45

Sections most often in play

Section 153ASection 132Section 143(3)Section 147Section 148Section 153CSection 132ASection 143(2)
Read the full judgment

Issues it is cited on

section 158bcstatement under section 132(4)section 132asection 158bblock periodsection 132(1)section 153a(1)section 158section 153bsearch assessmentpanchnamaincriminating material

Judgments citing CIT v. Kabul Chawla

Asst CIT Cir 2, Thane vs. Salasar Developers, Thane

The appeals of the Revenue are dismissed

ITA 4513/MUM/2014[2006-07]Status: DisposedITAT Mumbai04 Apr 2017AY 2006-07

Bench: Shri Joginder Singh & Shri N.K. Pradhan

Section 132Section 132(3)Section 133ASection 143(3)Section 153A

…आयकर अपील"य अ"धकरण, मुंबई "यायपीठ, ई, मुंबई । IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCHES “E”, MUMBAI "ी जो"ग"दर "संह, "या"यक सद"य एवं "ी एन. के. "धान, लेखा सद"य, के सम" Before Shri Joginder Singh, Judicial Member, and Shri N.K. Pradhan, Accountant Member ITA NOs.4511 to 4513/Mum/2014 Assessment Years: 2004-05 to 2006-07 ACIT, M/s Salasar Developers, Circle-2, Ground Floor, Vrindavan, बनाम/ Thane Salasar Brijbhoomi, Temba Vs. Hospital Road, Bhayandar(W), Dist:-Thane-401101 (राज"व /Revenue) ("नधा"रती /Assessee) PAN. No. AAKFS6465R "नधा"रती क" ओर से / Assessee by Shri Virag H. Shah Shri H.N. Singh CIT-DR…

Asst CIT Cir 2, Thane vs. Salasar Developers, Thane

The appeals of the Revenue are dismissed

ITA 4512/MUM/2014[2005-06]Status: DisposedITAT Mumbai04 Apr 2017AY 2005-06

Bench: Shri Joginder Singh & Shri N.K. Pradhan

Section 132Section 132(3)Section 133ASection 143(3)Section 153A

…आयकर अपील"य अ"धकरण, मुंबई "यायपीठ, ई, मुंबई । IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCHES “E”, MUMBAI "ी जो"ग"दर "संह, "या"यक सद"य एवं "ी एन. के. "धान, लेखा सद"य, के सम" Before Shri Joginder Singh, Judicial Member, and Shri N.K. Pradhan, Accountant Member ITA NOs.4511 to 4513/Mum/2014 Assessment Years: 2004-05 to 2006-07 ACIT, M/s Salasar Developers, Circle-2, Ground Floor, Vrindavan, बनाम/ Thane Salasar Brijbhoomi, Temba Vs. Hospital Road, Bhayandar(W), Dist:-Thane-401101 (राज"व /Revenue) ("नधा"रती /Assessee) PAN. No. AAKFS6465R "नधा"रती क" ओर से / Assessee by Shri Virag H. Shah Shri H.N. Singh CIT-DR…

Asst CIT Cir 2, Thane vs. Salasar Developers, Thane

The appeals of the Revenue are dismissed

ITA 4511/MUM/2014[2004-05]Status: DisposedITAT Mumbai04 Apr 2017AY 2004-05

Bench: Shri Joginder Singh & Shri N.K. Pradhan

Section 132Section 132(3)Section 133ASection 143(3)Section 153A

…आयकर अपील"य अ"धकरण, मुंबई "यायपीठ, ई, मुंबई । IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCHES “E”, MUMBAI "ी जो"ग"दर "संह, "या"यक सद"य एवं "ी एन. के. "धान, लेखा सद"य, के सम" Before Shri Joginder Singh, Judicial Member, and Shri N.K. Pradhan, Accountant Member ITA NOs.4511 to 4513/Mum/2014 Assessment Years: 2004-05 to 2006-07 ACIT, M/s Salasar Developers, Circle-2, Ground Floor, Vrindavan, बनाम/ Thane Salasar Brijbhoomi, Temba Vs. Hospital Road, Bhayandar(W), Dist:-Thane-401101 (राज"व /Revenue) ("नधा"रती /Assessee) PAN. No. AAKFS6465R "नधा"रती क" ओर से / Assessee by Shri Virag H. Shah Shri H.N. Singh CIT-DR…

DCIT, Dehradun vs. Sh. Ramesh Batta, Dehradun

In the result, the Cross

ITA 3966/DEL/2013[2007-08]Status: DisposedITAT Delhi29 Mar 2017AY 2007-08

Bench: Shri S.V. Mehrotra & Ms. Suchitra Kambleassessment Year : 2007-08 Dcit, Central Circle, Ramesh Batta, Dehradun. Vs. 81/210, Kaulagarh Road, Dehradun.

Section 139Section 142(1)Section 143(2)Section 143(3)Section 153A(1)(a)Section 153A(1)(b)Section 288ASection 292CSection 80C

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “F”, NEW DELHI BEFORE SHRI S.V. MEHROTRA, ACCOUNTANT MEMBER AND MS. SUCHITRA KAMBLE, JUDICIAL MEMBER Assessment Year : 2007-08 DCIT, Central Circle, Ramesh Batta, Dehradun. Vs. 81/210, Kaulagarh Road, Dehradun. PAN : ABGPB 1527 N (Appellant) (Respondent) C.O. No.242/Del/2013 (In ITA No.3966/Del/2013) Assessment Year : 2007-08 Ramesh Batta, DCIT, Central Circle, 81/210, Kaulagarh Road, Dehradun. Vs. Dehradun. PAN : ABGPB 1527 N (Appellant) (Respondent) : Department by Shri S. S. Rana, CIT(DR) : Assessee by Shri Salil Kapoor & Shri Sumit Lalchandani, Adv. Dat…

Pr. Commissioner of Income Tax (Central) - 3 vs. Orchid Infrastructure Developers Pvt. Ltd

The appeal is dismissed

ITA/161/2017HC Delhi28 Mar 2017

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE NAJMI WAZIRI

Section 143(3)Section 153A

…the valuation was of the aggregate, without excluding the area that fell to the share of the collaborator. The CIT(A) endorsed the opinion of the AO and rejected the assessee’s appeal. The ITAT noticed the facts and ruling of this Court in CIT v. Kabul Chawla 380 ITR 573 and thereafter found as follows: ITA 161/2017 Page 1 of 2 “7. In this case, return of income for the year under consideration was filed on 06.11.2007 has attained finality on passing the assessment order u/s 143(3) on 30.12.2008. As it is observed from the records placed before us that there has been no reference to any incriminating document i…

ACIT, New Delhi vs. M/S. Victory Township Pvt. Ltd., New Delhi

In the result, the appeals of the assessees are allowed and that of the department are dismissed

ITA 6235/DEL/2014[2008-09]Status: DisposedITAT Delhi24 Mar 2017AY 2008-09

Bench: Sh. N. K. Saini, Am & Smt. Beena Pillai, Jm Ita Nos. 6208 & 6209/Del/2014 : Asstt. Years : 2009-10 & 2010-11 Victory Dwellings Pvt. Ltd., Vs Acit, 208, Gupta Tower, Azadpur Central Circle-09, Commercial Complex, Azadpur, New Delhi New Delhi-110033 (Appellant) (Respondent)

Section 68

…s those were made out of the regular books of accounts of the assessee and the return of income was filed on the basis of those documents only. 18. On a similar issue the Hon’ble Jurisdictional High Court in the case of CIT Vs Kabul Chawla reported at (2016) 380 ITR 573 held as under: ''The legal position that emerges on a perusal of section 153A and section 132 of the Income-tax Act, 1961, is as under : (i) Once a search takes place under section 132 of the Act, notice under section 153A(1) will have to be mandatorily issued to the person in respect of whom ITA Nos. 6208 to 6213 /Del/2014 Townsip & Accommodat…

ACIT, New Delhi vs. M/S. Victory Dwellings Pvt. Ltd., New Delhi

In the result, the appeals of the assessees are allowed and that of the department are dismissed

ITA 6230/DEL/2014[2009-10]Status: DisposedITAT Delhi24 Mar 2017AY 2009-10

Bench: Sh. N. K. Saini, Am & Smt. Beena Pillai, Jm Ita Nos. 6208 & 6209/Del/2014 : Asstt. Years : 2009-10 & 2010-11 Victory Dwellings Pvt. Ltd., Vs Acit, 208, Gupta Tower, Azadpur Central Circle-09, Commercial Complex, Azadpur, New Delhi New Delhi-110033 (Appellant) (Respondent)

Section 68

…s those were made out of the regular books of accounts of the assessee and the return of income was filed on the basis of those documents only. 18. On a similar issue the Hon’ble Jurisdictional High Court in the case of CIT Vs Kabul Chawla reported at (2016) 380 ITR 573 held as under: ''The legal position that emerges on a perusal of section 153A and section 132 of the Income-tax Act, 1961, is as under : (i) Once a search takes place under section 132 of the Act, notice under section 153A(1) will have to be mandatorily issued to the person in respect of whom ITA Nos. 6208 to 6213 /Del/2014 Townsip & Accommodat…

ACIT, New Delhi vs. M/S. Victory Dwellings Pvt. Ltd., New Delhi

In the result, the appeals of the assessees are allowed and that of the department are dismissed

ITA 6228/DEL/2014[2007-08]Status: DisposedITAT Delhi24 Mar 2017AY 2007-08

Bench: Sh. N. K. Saini, Am & Smt. Beena Pillai, Jm Ita Nos. 6208 & 6209/Del/2014 : Asstt. Years : 2009-10 & 2010-11 Victory Dwellings Pvt. Ltd., Vs Acit, 208, Gupta Tower, Azadpur Central Circle-09, Commercial Complex, Azadpur, New Delhi New Delhi-110033 (Appellant) (Respondent)

Section 68

…s those were made out of the regular books of accounts of the assessee and the return of income was filed on the basis of those documents only. 18. On a similar issue the Hon’ble Jurisdictional High Court in the case of CIT Vs Kabul Chawla reported at (2016) 380 ITR 573 held as under: ''The legal position that emerges on a perusal of section 153A and section 132 of the Income-tax Act, 1961, is as under : (i) Once a search takes place under section 132 of the Act, notice under section 153A(1) will have to be mandatorily issued to the person in respect of whom ITA Nos. 6208 to 6213 /Del/2014 Townsip & Accommodat…

ACIT, New Delhi vs. M/S. Victory Structures Pvt. Ltd., New Delhi

In the result, the appeals of the assessees are allowed and that of the department are dismissed

ITA 6225/DEL/2014[2008-09]Status: DisposedITAT Delhi24 Mar 2017AY 2008-09

Bench: Sh. N. K. Saini, Am & Smt. Beena Pillai, Jm Ita Nos. 6208 & 6209/Del/2014 : Asstt. Years : 2009-10 & 2010-11 Victory Dwellings Pvt. Ltd., Vs Acit, 208, Gupta Tower, Azadpur Central Circle-09, Commercial Complex, Azadpur, New Delhi New Delhi-110033 (Appellant) (Respondent)

Section 68

…s those were made out of the regular books of accounts of the assessee and the return of income was filed on the basis of those documents only. 18. On a similar issue the Hon’ble Jurisdictional High Court in the case of CIT Vs Kabul Chawla reported at (2016) 380 ITR 573 held as under: ''The legal position that emerges on a perusal of section 153A and section 132 of the Income-tax Act, 1961, is as under : (i) Once a search takes place under section 132 of the Act, notice under section 153A(1) will have to be mandatorily issued to the person in respect of whom ITA Nos. 6208 to 6213 /Del/2014 Townsip & Accommodat…

Victory Township Pvt. Ltd., Delhi vs. DCIT, New Delhi

In the result, the appeals of the assessees are allowed and that of the department are dismissed

ITA 6215/DEL/2014[2010-11]Status: DisposedITAT Delhi24 Mar 2017AY 2010-11

Bench: Sh. N. K. Saini, Am & Smt. Beena Pillai, Jm Ita Nos. 6208 & 6209/Del/2014 : Asstt. Years : 2009-10 & 2010-11 Victory Dwellings Pvt. Ltd., Vs Acit, 208, Gupta Tower, Azadpur Central Circle-09, Commercial Complex, Azadpur, New Delhi New Delhi-110033 (Appellant) (Respondent)

Section 68

…s those were made out of the regular books of accounts of the assessee and the return of income was filed on the basis of those documents only. 18. On a similar issue the Hon’ble Jurisdictional High Court in the case of CIT Vs Kabul Chawla reported at (2016) 380 ITR 573 held as under: ''The legal position that emerges on a perusal of section 153A and section 132 of the Income-tax Act, 1961, is as under : (i) Once a search takes place under section 132 of the Act, notice under section 153A(1) will have to be mandatorily issued to the person in respect of whom ITA Nos. 6208 to 6213 /Del/2014 Townsip & Accommodat…

Victory Dwellings Pvt. Ltd., Delhi vs. DCIT, New Delhi

In the result, the appeals of the assessees are allowed and that of the department are dismissed

ITA 6208/DEL/2014[2009-10]Status: DisposedITAT Delhi24 Mar 2017AY 2009-10

Bench: Sh. N. K. Saini, Am & Smt. Beena Pillai, Jm Ita Nos. 6208 & 6209/Del/2014 : Asstt. Years : 2009-10 & 2010-11 Victory Dwellings Pvt. Ltd., Vs Acit, 208, Gupta Tower, Azadpur Central Circle-09, Commercial Complex, Azadpur, New Delhi New Delhi-110033 (Appellant) (Respondent)

Section 68

…s those were made out of the regular books of accounts of the assessee and the return of income was filed on the basis of those documents only. 18. On a similar issue the Hon’ble Jurisdictional High Court in the case of CIT Vs Kabul Chawla reported at (2016) 380 ITR 573 held as under: ''The legal position that emerges on a perusal of section 153A and section 132 of the Income-tax Act, 1961, is as under : (i) Once a search takes place under section 132 of the Act, notice under section 153A(1) will have to be mandatorily issued to the person in respect of whom ITA Nos. 6208 to 6213 /Del/2014 Townsip & Accommodat…

M/S. Spiritual Dwellers (P) Ltd., New Delhi vs. DCIT, New Delhi

In the result, the Appeal filed by the Assessee stand allowed

ITA 3028/DEL/2014[2006-07]Status: DisposedITAT Delhi24 Mar 2017AY 2006-07

Bench: Shri H.S. Sidhu & Shri L.P. Sahu

For Appellant: Sh. Somil Aggarwal, CAFor Respondent: Sh. Umesh Chand Dubey, Sr. DR
Section 132Section 153ASection 234BSection 40A(3)

…e validity of the order of assessment passed u/s. 153A on 22.1.2013, is squarely covered in favor of the assessee by the decision dated 28.8.2015 of the Hon’ble Delhi High Court passed in the case Commissioner of Income Tax vs. Kabul Chawla reported (2016) 380 ITR 573 (Del.) wherein the Hon’ble High Court has held that if the additions are made, but not based on any incriminating material found during search operation, then these additions are not sustainable in the eyes of law. He further stated that the additions have no relation with any incriminating material found and undisclosed income or property dis…

M/S. Shape Builders (P) Ltd., New Delhi vs. DCIT, New Delhi

In the result, the Appeal filed by the Assessee stand allowed

ITA 2406/DEL/2014[2006-07]Status: DisposedITAT Delhi24 Mar 2017AY 2006-07

Bench: Shri H.S. Sidhu & Shri L.P. Sahu

For Appellant: Sh. Tarun Kumar, AdvFor Respondent: Ms. Mona Singh, CIT(DR)
Section 132Section 153ASection 234BSection 40A(3)

…e validity of the order of assessment passed u/s. 153A on 14.1.2013, is squarely covered in favor of the assessee by the decision dated 28.8.2015 of the Hon’ble Delhi High Court passed in the case Commissioner of Income Tax vs. Kabul Chawla reported (2016) 380 ITR 573 (Del.) wherein the Hon’ble High Court has held that if the additions are made, but not based on any incriminating material found during search operation, then these additions are not sustainable in the eyes of law. He further stated that the additions have no relation with any incriminating material found and undisclosed income or property dis…

M/S. Spiritual Dwellers (P) Ltd., New Delhi vs. DCIT, New Delhi

In the result, the Appeal filed by the Assessee stand allowed

ITA 2401/DEL/2014[2007-08]Status: DisposedITAT Delhi24 Mar 2017AY 2007-08

Bench: Shri H.S. Sidhu & Shri L.P. Sahu

For Appellant: Sh. Tarun Kumar, AdvFor Respondent: Ms. Mona Singh, CIT(DR)
Section 132Section 153ASection 234BSection 40A(3)

…e validity of the order of assessment passed u/s. 153A on 22.1.2013, is squarely covered in favor of the assessee by the decision dated 28.8.2015 of the Hon’ble Delhi High Court passed in the case Commissioner of Income Tax vs. Kabul Chawla reported (2016) 380 ITR 573 (Del.) wherein the Hon’ble High Court has held that if the additions are made, but not based on any incriminating material found during search operation, then these additions are not sustainable in the eyes of law. He further stated that the additions have no relation with any incriminating material found and undisclosed income or property dis…

DCIT, New Delhi vs. M/S. L.D. Crystal Pvt. Ltd., New Delhi

In the result, the appeals of the department are dismissed and the Cross Objections of the assessee are allowed

ITA 2015/DEL/2014[2006-07]Status: DisposedITAT Delhi23 Mar 2017AY 2006-07

Bench: Sh. N. K. Saini, Am & Sh. Sudhanshu Srivastava, Jm Ita No. 2015/Del/2014 : Asstt. Year : 2006-07 Ita No. 2016/Del/2014 : Asstt. Year : 2008-09 Dcit, Vs M/S L. D. Crystal Pvt. Ltd., Central Circle-5, Tu-70, Pitam Pura, New Delhi New Delhi (Appellant) (Respondent) Pan No. Aabcl1304J Co No. 05/Del/2015 : Asstt. Year : 2006-07 Co No. 06/Del/2015 : Asstt. Year : 2008-09 M/S L. D. Crystal Pvt. Ltd., Vs Dcit, Tu-70, Pitam Pura, Central Circle-5, New Delhi New Delhi (Appellant) (Respondent) Pan No. Aabcl1304J Assessee By : Sh. Gautam Jain, Ca Revenue By : Ms. Seema Raj, Cit Dr Date Of Hearing : 11.01.2017 Date Of Pronouncement : 23.03.2017 Order Per N. K. Saini, Am:

For Appellant: Sh. Gautam Jain, CAFor Respondent: Ms. Seema Raj, CIT DR
Section 132Section 153ASection 68

…in the absence of any incriminating material the CO No. 05 & 06/Del/2015 L. D. Crystal Pvt. Ltd. additions made were not justified. The reliance was placed on the judgment of the Hon’ble Delhi High Court in the case of CIT Vs Kabul Chawla reported at (2016) 380 ITR 573 14. In his rival submissions the ld. DR strongly supported the orders of the authorities below and further submitted that the assessee could not prove the creditworthiness of the share applicant and the depositors. Therefore, the AO rightly made the addition and the ld. CIT(A) was not justified in deleting the same. It was further submitted that…

Sri. H. Nagaraja, Bangalore vs. CIT, Bangalore

In the result, the appeals filed by the assessee are allowed

ITA 613/BANG/2014[2008-09]Status: DisposedITAT Bangalore17 Mar 2017AY 2008-09

Bench: Smt. Asha Vijayaraghavan & Shri Inturi Rama Rao

For Appellant: Shri M.V.Seshachala, AdvocateFor Respondent: Ms. Neera Malhotra, CIT(DR)
Section 139Section 143(3)Section 153ASection 263Section 40A(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, BENGALURU BEFORE SMT. ASHA VIJAYARAGHAVAN, JUDICIAL MEMBER and SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER ITA Nos.613 & 614/Bang/2014 (Assessment years: 2008-09 & 2009-10) Shri H.Nagaraja, No.6 & 7, 5th Cross, ‘Sri Ganesh Krupa’ New Bank Colony, Konankunte, Bengaluru-560062. … Appellant PAN:ABMPN 7731 L Vs. Commissioner of Income-tax, Karnataka (Central), Bengaluru. … Respondent Appellant by : Shri M.V.Seshachala, Advocate. Respondent by : Ms. Neera Malhotra, CIT(DR). Date of hearing : 06/01/2017 Date of pronouncement : 17/03/2017 O R D E R Per INTURI RAMA RAO,…

DCIT Cen Cir 8(1), Mumbai vs. Bhuta Investment P.Ltd, Mumbai

ITA 1291/MUM/2015[2008-09]Status: DisposedITAT Mumbai16 Mar 2017AY 2008-09

Bench: Shri Mahavir Singh & Shri Ashwani Tanejaassessment Year: 2008-09

Section 143(3)Section 153A

…ssessment u/s 153A in absence of any incriminating material having been found during the course of search in view of the following decisions:- “All Cargo Global Logistics [374 ITR 645 (Bom)] CIT v. Gurinder Singh Bawa [386 ITR 483 (Bom)] CIT v. Kabul Chawla [380 ITR 573 (Del)] Dy. CIT v. Shri Ramakant Gaggar in ITA Nos 1287 to 1291/Mum/2015 for A.Y.s 2006-07 to 2009-10 dated 21.12.2016 (Pg 69— 80 of P.B.) DCIT v. Smt. Indra Gaggar in ITA Nos 808, 1295, 1294/Mum/2015 for A.Y.'s 2006-07 to 2008-09 dated 30.11.2016 (Pg 102 - 113 of P.B.) Narpat Mehta v. ACIT CC 4(1), Mumbai in ITA Nos. 2151 and 2153/Mum/2015 for A.…

M/S. Sumitra Builders & Developers Pvt. Ltd., New Delhi vs. DCIT, New Delhi

In the result, the Appeal filed by the Assessee stand allowed

ITA 5674/DEL/2013[2007-08]Status: DisposedITAT Delhi03 Mar 2017AY 2007-08

Bench: Shri H.S. Sidhu & Shri Prashant Maharishi

For Appellant: Sh. Somil Aggarwal, AdvFor Respondent: Sh. S.S. Rana, CIT(DR)
Section 132Section 132(1)Section 143(2)Section 153ASection 40A(3)

…upholding the validity of the order of assessment passed u/s. 153A is squarely covered in favor of the assessee by the decision 3 dated 28.8.2015 of the Hon’ble Delhi High Court passed in the case Commissioner of Income Tax vs. Kabul Chawla reported (2016) 380 ITR 573 (Del.) wherein the Hon’ble High Court has held that if the additions are made, but not based on any incriminating material found during search operation, then these additions are not sustainable in the eyes of law. He further stated that the additions have no relation with any incriminating material found and undisclosed income or property dis…

Hazorilal & Sons Jewellers P. Ltd., New Delhi vs. DCIT, New Delhi

Appeals of the assessee are allowed

ITA 4062/DEL/2014[2009-10]Status: DisposedITAT Delhi27 Feb 2017AY 2009-10

Bench: Shri R. K. Panda & Smt Suchitra Kamblei.T.A .No.-4060/Del/2014 (A.Y 2007-08) I.T.A .No.-4061/Del/2014 (A.Y 2008-09) I.T.A .No.-4062/Del/2014 (A.Y 2009-10)

Section 153CSection 271(1)(c)

…assessment were routine assessment and has not been made in pursuance of any material found consequently these type of additions cannot be made in assessment made under u/s 153C/153A. The Ld. AR relied the under mentioned decisions: KABUL CHAWLA V CIT (2016) 380 ITR 573 (DEL) All Cargo Global Logistics Ltd V DCIT (2012) 18 ITR(TRIB) 106 (Mum)(SB). JAI STEEL INDIA v ACIT 259 CTR (RAJ) 281. 13. The Ld. AR further submitted that in the present case two very short dates were given by the CIT(A). Appellant forwarded the notice of hearing to its regular counsel on 12/05/2014 who duly attended the hearing requesting…

Hazorilal & Sons Jewellers P. Ltd., New Delhi vs. DCIT, New Delhi

Appeals of the assessee are allowed

ITA 4061/DEL/2014[2008-09]Status: DisposedITAT Delhi27 Feb 2017AY 2008-09

Bench: Shri R. K. Panda & Smt Suchitra Kamblei.T.A .No.-4060/Del/2014 (A.Y 2007-08) I.T.A .No.-4061/Del/2014 (A.Y 2008-09) I.T.A .No.-4062/Del/2014 (A.Y 2009-10)

Section 153CSection 271(1)(c)

…assessment were routine assessment and has not been made in pursuance of any material found consequently these type of additions cannot be made in assessment made under u/s 153C/153A. The Ld. AR relied the under mentioned decisions: KABUL CHAWLA V CIT (2016) 380 ITR 573 (DEL) All Cargo Global Logistics Ltd V DCIT (2012) 18 ITR(TRIB) 106 (Mum)(SB). JAI STEEL INDIA v ACIT 259 CTR (RAJ) 281. 13. The Ld. AR further submitted that in the present case two very short dates were given by the CIT(A). Appellant forwarded the notice of hearing to its regular counsel on 12/05/2014 who duly attended the hearing requesting…