CIT v. Radhey Shyam Bansal

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(1), HYDERABAD

…of the Act, viz. (i). CIT Vs. Calcutta Knitwears, Ludhiana (2014) 362 ITR 673 (SC); (ii). Pr. CIT Vs. Milia Tracon P. Ltd. (2025) 473 ITR 155 (Cal); (iii). CIT Vs. SRM Systems & Software Ltd. (2025) 475 ITR 387 (Mad); (iv). CIT Vs. Radhey Shyam Bansal (2011) 337 ITR 217 (Del). Also, the Ld. AR had relied on the CBDT Circular No. 20/2015, dated 31.12.2015/. 8. Alternatively, it was vehemently submitted by the Ld. AR that the assessment framed is vitiated for non-compliance with the mandatory requirement of obtaining a proper and valid approval under section 153D of the Act, inasmuch as a single, omnibus approval…

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

…Vs. Calcutta Private Limited vs. ACIT Knitwears, Ludhiana (2014) 362 ITR 673 (SC); (ii). Pr. CIT Vs. Milia Tracon P. Ltd. (2025) 473 ITR 155 (Cal); (iii). CIT Vs. SRM Systems & Software Ltd. (2025) 475 ITR 387 (Mad); (iv). CIT Vs. Radhey Shyam Bansal (2011) 337 ITR 217 (Del). Also, the Ld. AR had relied on the CBDT Circular No. 20/2015, dated 31.12.2015/. 8. Alternatively, it was vehemently submitted by the Ld. AR that the assessment framed is vitiated for non-compliance with the mandatory requirement of obtaining a proper and valid approval under section 153D of the Act, inasmuch as a single, omnibus approval…

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

…Vs. Calcutta Private Limited vs. ACIT Knitwears, Ludhiana (2014) 362 ITR 673 (SC); (ii). Pr. CIT Vs. Milia Tracon P. Ltd. (2025) 473 ITR 155 (Cal); (iii). CIT Vs. SRM Systems & Software Ltd. (2025) 475 ITR 387 (Mad); (iv). CIT Vs. Radhey Shyam Bansal (2011) 337 ITR 217 (Del). Also, the Ld. AR had relied on the CBDT Circular No. 20/2015, dated 31.12.2015/. 8. Alternatively, it was vehemently submitted by the Ld. AR that the assessment framed is vitiated for non-compliance with the mandatory requirement of obtaining a proper and valid approval under section 153D of the Act, inasmuch as a single, omnibus approval…

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

…Vs. Calcutta Private Limited vs. ACIT Knitwears, Ludhiana (2014) 362 ITR 673 (SC); (ii). Pr. CIT Vs. Milia Tracon P. Ltd. (2025) 473 ITR 155 (Cal); (iii). CIT Vs. SRM Systems & Software Ltd. (2025) 475 ITR 387 (Mad); (iv). CIT Vs. Radhey Shyam Bansal (2011) 337 ITR 217 (Del). Also, the Ld. AR had relied on the CBDT Circular No. 20/2015, dated 31.12.2015/. 8. Alternatively, it was vehemently submitted by the Ld. AR that the assessment framed is vitiated for non-compliance with the mandatory requirement of obtaining a proper and valid approval under section 153D of the Act, inasmuch as a single, omnibus approval…

SWASTIK VEGETABLE OIL PRODUCTS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(1), HYDERABAD

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

…Vs. Calcutta Private Limited vs. ACIT Knitwears, Ludhiana (2014) 362 ITR 673 (SC); (ii). Pr. CIT Vs. Milia Tracon P. Ltd. (2025) 473 ITR 155 (Cal); (iii). CIT Vs. SRM Systems & Software Ltd. (2025) 475 ITR 387 (Mad); (iv). CIT Vs. Radhey Shyam Bansal (2011) 337 ITR 217 (Del). Also, the Ld. AR had relied on the CBDT Circular No. 20/2015, dated 31.12.2015/. 8. Alternatively, it was vehemently submitted by the Ld. AR that the assessment framed is vitiated for non-compliance with the mandatory requirement of obtaining a proper and valid approval under section 153D of the Act, inasmuch as a single, omnibus approval…

DCIT., CENTRAL CIRCLE-1(2), HYDERABAD vs. VPR MINING INFRASTRUCTURE PRIVATE LIMITED, NELLORE

In the result, appeal of the Revenue is dismissed

Bench: : Shri Vijay Pal Rao & Shri Manjunatha Gआ.अपी.सं /Ita No.939/Hyd./2025 िनधा"रण वष"/Assessment Year 2018-2019 The Dcit, Central Vpr Mining Vs. Infrastructure Private Circle-1(2), Hyderabad. Limited, Nellore. Pin -500 004. Pin – 524003 Andhra Pradesh Telangana. Pan Aaccv6733A (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Mv Prasad राज" व "ारा/Revenue By:: Dr. Narendra Kumar Naik, Cit-Dr

…material on the basis of which, satisfaction is reached should not be vague, indefinite, distant or remote. In support of this contention, the Learned AR relied upon Judgment of Hon’ble Delhi High Court in the case of CIT-XIII vs., Radhey Shyam Bansal [2011] 337 ITR 217 (Del.) and Judgment of Hon’ble Allahabad High Court in the case of CIT-(C), Kanpur vs., Smt. Nirmala Keshwani [2016] 380 ITR 566 (Allahabad) and submitted that the Hon’ble High Court has held that “recording of satisfaction is not a mere formality, but, involves application of mind”. He has submitted that none of seized material have any bearing…