CIT v. RRJ Securities Ltd.

380 ITR 612High Court2016#80 most cited

What is CIT v. RRJ Securities Ltd. authority for?

Completed assessments can be interfered with under Section 153A or 153C only on the basis of incriminating material unearthed during the search, necessitating a direct correlation between the discovered material and the power to assess or reopen concluded assessments.

689

judgments rely on this decision, according to BharatTax’s citation analysis of 367,735 Indian tax judgments — from 2015 to 2026.

Also referred to as

CIT v. RRJ Securities Ltd. · Section 153A · Section 153C · incriminating material · reopening completed assessments · correlation between discovered material and assessment · power to assess · validity of search assessments · block assessment · satisfaction note

Also reported as

62 Taxmann.com 3912015 SCC OnLine DEL 13085128 DTR 57

Sections most often in play

Section 153CSection 143(3)Section 153ASection 132Section 148Section 147Section 151Section 149
Read the full judgment

Issues it is cited on

section 153atosection 153b(1)(a)abatement of assessmentsection 153(c)(1)section 153c(1)section 153c proceedingssection 153(c)section 153b(1)section 113section 158bdblock periodsatisfaction note

Judgments citing CIT v. RRJ Securities Ltd.

ACIT, Central Circle-II, Gurgaon vs. Sanjay Jindal, Delhi

In the result, appeals are dismissed

ITA 8512/DEL/2019[2012-13]Status: DisposedITAT Delhi14 Dec 2023AY 2012-13

Bench: Shri Saktijit Dey, Vice- & Shri M. Balaganesh

Section 153ASection 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘G’ NEW DELHI BEFORE SHRI SAKTIJIT DEY, VICE-PRESIDENT AND SHRI M. BALAGANESH, ACCOUNTANT MEMBER ITA Nos.8511 to 8516 /Del/2019 Assessment Years: 2011-12 to 2016-17 ACIT, Vs. Sh. Sanjay Jindal, Central Circle-II, S-34, Okhla Industrial Area, Gurgaon Phase-II, Delhi PAN :ADKPJ3514F (Appellant) (Respondent) With Cross Objection Nos. 17 to 22/Del/2020 [Arising out of ITA Nos.8511 to 8516 /Del/2019] Assessment Years: 2011-12 to 2016-17 Sh. Sanjay Jindal, Vs. ACIT, S-34, Okhla Industrial Area, Central Circle-II, Phase-II, Gurgaon Delhi PAN :ADKPJ3514F (Appellant)…

ACIT, Central Circle-II, Gurgaon vs. Sanjay Jindal, Delhi

In the result, appeals are dismissed

ITA 8511/DEL/2019[2011-12]Status: DisposedITAT Delhi14 Dec 2023AY 2011-12

Bench: Shri Saktijit Dey, Vice- & Shri M. Balaganesh

Section 153ASection 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘G’ NEW DELHI BEFORE SHRI SAKTIJIT DEY, VICE-PRESIDENT AND SHRI M. BALAGANESH, ACCOUNTANT MEMBER ITA Nos.8511 to 8516 /Del/2019 Assessment Years: 2011-12 to 2016-17 ACIT, Vs. Sh. Sanjay Jindal, Central Circle-II, S-34, Okhla Industrial Area, Gurgaon Phase-II, Delhi PAN :ADKPJ3514F (Appellant) (Respondent) With Cross Objection Nos. 17 to 22/Del/2020 [Arising out of ITA Nos.8511 to 8516 /Del/2019] Assessment Years: 2011-12 to 2016-17 Sh. Sanjay Jindal, Vs. ACIT, S-34, Okhla Industrial Area, Central Circle-II, Phase-II, Gurgaon Delhi PAN :ADKPJ3514F (Appellant)…

DCIT, Central Circle-20, New Delhi vs. Rajesh Vashist, New Delhi

In the result, the captioned appeals are dismissed

ITA 1754/DEL/2023[2011-12]Status: DisposedITAT Delhi29 Nov 2023AY 2011-12

Bench: Sh. N. K. Billaiya & Ms. Astha Chandraita No.1754, 1744 & 1745/Del/2023 Assessment Year: 2011-12, 2012-13 & 2013-14 Dcit Rajesh Vashisht Central Circle -20 01, 48 Ganesh Nagar, New Delhi Vs. Extension, Shakarpur, S.O. East, New Delhi-110055 Pan No.Amjpv1087D (Appellant) (Respondent) Appellant By Sh. P.N. Barnwal, Cit Dr Respondent By None Date Of Hearing: 29/11/2023 Date Of Pronouncement: 29/11/2023 Order Per N. K. Billaiya, Am:

Section 153ASection 153C

…he case a perusal of the grounds read with the order of the CIT(A) we find that the first appellate authority has decided the appeal in favour of the assessee following the binding decision of the Hon’ble Delhi High Court in the case of RRJ Securities Limited 380 ITR 612 and subsequent amendment in the section 153C of the Act w.e.f. 01.04.2017. We do not find any merit in the grievance of the revenue. If the revenue is aggrieved by the binding decision of the Hon’ble Jurisdictional High Court of Delhi (supra) the revenue may approach the Hon’ble Supreme Court but in no case the revenue can be aggrieved by the bin…

DCIT Central Circle-20, New Delhi vs. Rajesh Vashist, New Delhi

In the result, the captioned appeals are dismissed

ITA 1745/DEL/2023[2013-14]Status: DisposedITAT Delhi29 Nov 2023AY 2013-14

Bench: Sh. N. K. Billaiya & Ms. Astha Chandraita No.1754, 1744 & 1745/Del/2023 Assessment Year: 2011-12, 2012-13 & 2013-14 Dcit Rajesh Vashisht Central Circle -20 01, 48 Ganesh Nagar, New Delhi Vs. Extension, Shakarpur, S.O. East, New Delhi-110055 Pan No.Amjpv1087D (Appellant) (Respondent) Appellant By Sh. P.N. Barnwal, Cit Dr Respondent By None Date Of Hearing: 29/11/2023 Date Of Pronouncement: 29/11/2023 Order Per N. K. Billaiya, Am:

Section 153ASection 153C

…he case a perusal of the grounds read with the order of the CIT(A) we find that the first appellate authority has decided the appeal in favour of the assessee following the binding decision of the Hon’ble Delhi High Court in the case of RRJ Securities Limited 380 ITR 612 and subsequent amendment in the section 153C of the Act w.e.f. 01.04.2017. We do not find any merit in the grievance of the revenue. If the revenue is aggrieved by the binding decision of the Hon’ble Jurisdictional High Court of Delhi (supra) the revenue may approach the Hon’ble Supreme Court but in no case the revenue can be aggrieved by the bin…

DCIT Central Circle-20, New Delhi vs. Rajesh Vashist, New Delhi

In the result, the captioned appeals are dismissed

ITA 1744/DEL/2023[2012-13]Status: DisposedITAT Delhi29 Nov 2023AY 2012-13

Bench: Sh. N. K. Billaiya & Ms. Astha Chandraita No.1754, 1744 & 1745/Del/2023 Assessment Year: 2011-12, 2012-13 & 2013-14 Dcit Rajesh Vashisht Central Circle -20 01, 48 Ganesh Nagar, New Delhi Vs. Extension, Shakarpur, S.O. East, New Delhi-110055 Pan No.Amjpv1087D (Appellant) (Respondent) Appellant By Sh. P.N. Barnwal, Cit Dr Respondent By None Date Of Hearing: 29/11/2023 Date Of Pronouncement: 29/11/2023 Order Per N. K. Billaiya, Am:

Section 153ASection 153C

…he case a perusal of the grounds read with the order of the CIT(A) we find that the first appellate authority has decided the appeal in favour of the assessee following the binding decision of the Hon’ble Delhi High Court in the case of RRJ Securities Limited 380 ITR 612 and subsequent amendment in the section 153C of the Act w.e.f. 01.04.2017. We do not find any merit in the grievance of the revenue. If the revenue is aggrieved by the binding decision of the Hon’ble Jurisdictional High Court of Delhi (supra) the revenue may approach the Hon’ble Supreme Court but in no case the revenue can be aggrieved by the bin…

DCIT, CC -8, New Delhi vs. Bjn Holdings (Bd) Ltd., Delhi

The appeals of the Revenue are dismissed and the Cross

ITA 63/DEL/2022[2010-11]Status: DisposedITAT Delhi22 Nov 2023AY 2010-11

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaassessment Years: 2010-11 Assessment Year : 2012-13 Dcit, Vs Bjn Holdings (Bd) Ltd., Cc-8, Rehan Basera, New Delhi. 6, Sultanpur Farms, Mehrauli, Delhi – 110 030. Pan: Aafcb9063L Assessment Year : 2011-12 Co No.189/Del/2022 (Ita No.2041/Del/2021) Assessment Year : 2012-13 Bjn Holdings (Bd) Ltd., Vs. Dcit, Rehan Basera, Cc-8, 6, Sultanpur Farms, New Delhi. Mehrauli, Delhi – 110 030. Pan: Aafcb9063L (Appellant/Cross Objector) (Respondents) Assessee By : Shri Pradeep Dinodia, Ca & Shri R.K. Kapoor, Ca Revenue By : Shri Zafarul Haque Tanweer, Cit, Dr

For Appellant: Shri Pradeep Dinodia, CA &For Respondent: Shri Zafarul Haque Tanweer, CIT, DR
Section 143(3)Section 153C

…2006-07 to AY 2011-12. No satisfaction was recorded for AY 2012-13. Thus, relying on the judgement of the Hon’ble Delhi ITA No.2041/Del/2021 & ITA No.1260/Del/2020 CO No.189/Del/2022 DCIT vs. BJN Holdings (BD) Ltd. High Court in CIT vs. RRJ Securities Ltd., 380 ITR 682, it was submitted by the ld. AR that the block period of six years for making assessment u/s 153C were the six previous year prior to the years in which satisfaction note was recorded. In the case in hand, the satisfaction was recorded on 08.10.2013. Therefore, the block period of six years would comprise AY 2008-09 onwards till 2013-14 and the a…

DCIT, CC-8, New Delhi vs. Bjn Holdings (I) Ltd., Delhi

The appeals of the Revenue are dismissed and the Cross

ITA 62/DEL/2022[2010-11]Status: DisposedITAT Delhi22 Nov 2023AY 2010-11

Bench: Shri M. Balaganesh & Shri Anubhav Sharma

For Appellant: Shri Pradeep Dinodia, CA &For Respondent: Shri Zafarul Haque Tanweer, CIT, DR
Section 143(3)Section 153C

…hingra on 16.09.2011. A common satisfaction note was recorded for six assessment years, i.e., AY 2006-07 to AY 2011-12. No satisfaction was recorded for AY 2012-13. Thus, relying on the judgement of the Hon’ble Delhi High Court in CIT vs. RRJ Securities Ltd., 380 ITR 682, it was submitted by the ld. AR that the block period of six years for making assessment u/s 153C were the six previous year prior to the years in which satisfaction note was CO No.190/Del/2022 DCIT vs. BJN Holdings (I) Ltd. recorded. In the case in hand, the satisfaction was recorded on 08.10.2013. Therefore, the block period of six years would…

DCIT, Cetral Circle-8, Delhi vs. Bjn Holding (I) Ltd., Delhi

The appeals of the Revenue are dismissed and the Cross

ITA 2043/DEL/2021[2012-13]Status: DisposedITAT Delhi22 Nov 2023AY 2012-13

Bench: Shri M. Balaganesh & Shri Anubhav Sharma

For Appellant: Shri Pradeep Dinodia, CA &For Respondent: Shri Zafarul Haque Tanweer, CIT, DR
Section 143(3)Section 153C

…hingra on 16.09.2011. A common satisfaction note was recorded for six assessment years, i.e., AY 2006-07 to AY 2011-12. No satisfaction was recorded for AY 2012-13. Thus, relying on the judgement of the Hon’ble Delhi High Court in CIT vs. RRJ Securities Ltd., 380 ITR 682, it was submitted by the ld. AR that the block period of six years for making assessment u/s 153C were the six previous year prior to the years in which satisfaction note was CO No.190/Del/2022 DCIT vs. BJN Holdings (I) Ltd. recorded. In the case in hand, the satisfaction was recorded on 08.10.2013. Therefore, the block period of six years would…

Bjn Holdings (Bd) Ltd, New Delhi vs. ACIT Central Circle-8, New Delhi

The appeals of the Revenue are dismissed and the Cross

ITA 1260/DEL/2020[2011-12]Status: DisposedITAT Delhi22 Nov 2023AY 2011-12

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaassessment Years: 2010-11 Assessment Year : 2012-13 Dcit, Vs Bjn Holdings (Bd) Ltd., Cc-8, Rehan Basera, New Delhi. 6, Sultanpur Farms, Mehrauli, Delhi – 110 030. Pan: Aafcb9063L Assessment Year : 2011-12 Co No.189/Del/2022 (Ita No.2041/Del/2021) Assessment Year : 2012-13 Bjn Holdings (Bd) Ltd., Vs. Dcit, Rehan Basera, Cc-8, 6, Sultanpur Farms, New Delhi. Mehrauli, Delhi – 110 030. Pan: Aafcb9063L (Appellant/Cross Objector) (Respondents) Assessee By : Shri Pradeep Dinodia, Ca & Shri R.K. Kapoor, Ca Revenue By : Shri Zafarul Haque Tanweer, Cit, Dr

For Appellant: Shri Pradeep Dinodia, CA &For Respondent: Shri Zafarul Haque Tanweer, CIT, DR
Section 143(3)Section 153C

…2006-07 to AY 2011-12. No satisfaction was recorded for AY 2012-13. Thus, relying on the judgement of the Hon’ble Delhi ITA No.2041/Del/2021 & ITA No.1260/Del/2020 CO No.189/Del/2022 DCIT vs. BJN Holdings (BD) Ltd. High Court in CIT vs. RRJ Securities Ltd., 380 ITR 682, it was submitted by the ld. AR that the block period of six years for making assessment u/s 153C were the six previous year prior to the years in which satisfaction note was recorded. In the case in hand, the satisfaction was recorded on 08.10.2013. Therefore, the block period of six years would comprise AY 2008-09 onwards till 2013-14 and the a…

DCIT Central Circle-II, Noida vs. Mg Metalloy Pvt Ltd (Formely Apple Iron Enterprises Pvt. Ltd.), Noida

In the result, appeal of the Revenue is dismissed

ITA 3631/DEL/2019[2012-13]Status: DisposedITAT Delhi01 Nov 2023AY 2012-13

Bench: Dr. Brr Kumar & Ms. Astha Chandraasstt. Year: 2012-13 Dcit, Vs. M/S. M.G. Metalloy Pvt. Ltd. Central Circle-Ii, (Formerly M/S. Apple Iron Noida Enterprises Pvt. Ltd.) B-16, Sector-2, Noida, Uttar Pradesh-201301 Pan Aahca8642G (Appellant) (Respondent)

For Appellant: Shri Pranav Yadav, AdvocateFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 132(1)Section 143(2)Section 143(3)Section 153C

…reopened, the decision of the Supreme Court in Commissioner of Income Tax-III, Pune Vs. Sinhgad Technical Education Society (Supra) seitles the issue and holds this to be an essential requirement. The decision of this Court in CIT-7 Vs RRJ 5 Securitles (2016) 380 ITR 612 (Del) and ARN Infrastructure India Ltd. Vs ACIT [2017] 394 ITR 569 (Del) also held that in order to justify the assumption of Jurisdiction under section 153C of the Act the documents selted must be incriminating and must relate to each of the AYs whose assessments are sought to be reopened." Thus, by now, it is a settelled law that notices u/s 15…

Shree Gopal Landcraft P.Ltd, New Delhi vs. ACIT, Central Circle-13, New Delhi

In the result, the appeals of the assessee are allowed in the manner as indicated above

ITA 1661/DEL/2022[2016-17]Status: DisposedITAT Delhi19 Oct 2023AY 2016-17

Bench: Shri Chandra Mohan Garg & Girish Agrawal

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri H K Choudhary, CIT(DR)
Section 143(3)Section 153Section 153C

…from the date of recording of satisfaction note or from the date of search carried out in a case of a person provided in Section 153A. This precise issue has been dealt by the Hon’ble Delhi High Court in the case of CIT vs. RRJ Securities Ltd. as reported in 380 ITR 612 in the context of Section 153C of the Act, wherein it was laid down as under: “Further, the period of six years would also have to be reckoned with respect to the date of recording of satisfaction note - that is. 8th September. 2010 -and not the date of search. 24. As discussed hereinbefore, in terms of proviso to Section 153C of the Act, a refer…

Shree Gopal Landcraft P.Ltd, New Delhi vs. ACIT, Central Circle-13, New Delhi

In the result, the appeals of the assessee are allowed in the manner as indicated above

ITA 1660/DEL/2022[2015-16]Status: DisposedITAT Delhi19 Oct 2023AY 2015-16

Bench: Shri Chandra Mohan Garg & Girish Agrawal

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri H K Choudhary, CIT(DR)
Section 143(3)Section 153Section 153C

…from the date of recording of satisfaction note or from the date of search carried out in a case of a person provided in Section 153A. This precise issue has been dealt by the Hon’ble Delhi High Court in the case of CIT vs. RRJ Securities Ltd. as reported in 380 ITR 612 in the context of Section 153C of the Act, wherein it was laid down as under: “Further, the period of six years would also have to be reckoned with respect to the date of recording of satisfaction note - that is. 8th September. 2010 -and not the date of search. 24. As discussed hereinbefore, in terms of proviso to Section 153C of the Act, a refer…

Shree Gopal Landcraft P.Ltd, New Delhi vs. ACIT, Central Circle-13, New Delhi

In the result, the appeals of the assessee are allowed in the manner as indicated above

ITA 1659/DEL/2022[2013-14]Status: DisposedITAT Delhi19 Oct 2023AY 2013-14

Bench: Shri Chandra Mohan Garg & Girish Agrawal

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri H K Choudhary, CIT(DR)
Section 143(3)Section 153Section 153C

…from the date of recording of satisfaction note or from the date of search carried out in a case of a person provided in Section 153A. This precise issue has been dealt by the Hon’ble Delhi High Court in the case of CIT vs. RRJ Securities Ltd. as reported in 380 ITR 612 in the context of Section 153C of the Act, wherein it was laid down as under: “Further, the period of six years would also have to be reckoned with respect to the date of recording of satisfaction note - that is. 8th September. 2010 -and not the date of search. 24. As discussed hereinbefore, in terms of proviso to Section 153C of the Act, a refer…

Shree Gopal Landcraft (P) Ltd., Delhi vs. ACIT, Central Circle-13, New Delhi

In the result, the appeals of the assessee are allowed in the manner as indicated above

ITA 1658/DEL/2022[2012-13]Status: DisposedITAT Delhi19 Oct 2023AY 2012-13

Bench: Shri Chandra Mohan Garg & Girish Agrawal

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri H K Choudhary, CIT(DR)
Section 143(3)Section 153Section 153C

…from the date of recording of satisfaction note or from the date of search carried out in a case of a person provided in Section 153A. This precise issue has been dealt by the Hon’ble Delhi High Court in the case of CIT vs. RRJ Securities Ltd. as reported in 380 ITR 612 in the context of Section 153C of the Act, wherein it was laid down as under: “Further, the period of six years would also have to be reckoned with respect to the date of recording of satisfaction note - that is. 8th September. 2010 -and not the date of search. 24. As discussed hereinbefore, in terms of proviso to Section 153C of the Act, a refer…

Shree Gopal Landcraft (P) Ltd., New Delhi vs. ACIT, Central Circle-13, New Delhi

In the result, the appeals of the assessee are allowed in the manner as indicated above

ITA 1657/DEL/2022[2011-12]Status: DisposedITAT Delhi19 Oct 2023AY 2011-12

Bench: Shri Chandra Mohan Garg & Girish Agrawal

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri H K Choudhary, CIT(DR)
Section 143(3)Section 153Section 153C

…from the date of recording of satisfaction note or from the date of search carried out in a case of a person provided in Section 153A. This precise issue has been dealt by the Hon’ble Delhi High Court in the case of CIT vs. RRJ Securities Ltd. as reported in 380 ITR 612 in the context of Section 153C of the Act, wherein it was laid down as under: “Further, the period of six years would also have to be reckoned with respect to the date of recording of satisfaction note - that is. 8th September. 2010 -and not the date of search. 24. As discussed hereinbefore, in terms of proviso to Section 153C of the Act, a refer…

DCIT, CC- 1, Faridabad vs. Sadjyoti Traders Pvt. Ltd., New Delhi

In the result, appeal of the Revenue stands dismissed and the cross-objection

ITA 3854/DEL/2017[2006-07]Status: DisposedITAT Delhi18 Oct 2023AY 2006-07

Bench: Shri Kul Bharat & Shri M. Balaganeshasstt. Yr: 2006-07

Section 143(3)Section 153CSection 68

…1 ITA no. 3854/Del/2017 & CO no. 31/Del/2021 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “G”: NEW DELHI BEFORE SHRI KUL BHARAT, JUDICIAL MEMBER AND SHRI M. BALAGANESH, ACCOUNTANT MEMBER Asstt. Yr: 2006-07 DCIT, Central Circle-1, Vs M/s sadjyoti Traders Pvt. Ltd., Faridabad. 5, Village Tajpur, Badarpur, New Delhi. PAN- AAICS7343F APPELLANT RESPONDENT C.O. No. 31/Del/2021 ( In ITA No. 3854/DEL/2017) Asstt. Yr: 2006-07 M/s sadjyoti Traders Pvt. Ltd., Vs DCIT, Central Circle-1, 5, Village Tajpur, Badarpur, Faridabad. New Delhi. PAN- AAICS7343F Cross objector RESPONDENT Assessee represented by Dr. Rakesh G…

Dinesh V. Shah, Mumbai vs. DCIT Central Cir-3(4, Mumbai

In the result, the appeal by the assessee is allowed

ITA 1153/MUM/2020[2008-09]Status: DisposedITAT Mumbai17 Oct 2023AY 2008-09

Bench: Shri Sandeep Singh Karhail & Shri Gagan Goyal

For Appellant: Shri Rasesh Shah a/wFor Respondent: Smt. Sanyogita Nagpal
Section 132Section 132ASection 143Section 153A(1)Section 153CSection 153C(1)Section 250Section 254(1)Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER AND SHRI GAGAN GOYAL, ACCOUNTANT MEMBER ITA no.1153/Mum./2020 (Assessment Year : 2008–09) Dinesh Shah Flat no.434, Shabri Shikhar ……………. Appellant R.C. Marg, Chembur (West) Mumbai 400 071 PAN – AAEPS1245F v/s Dy. Commissioner of Income Tax ……………. Respondent Central Circle–3(4), Mumbai Assessee by : Shri Rasesh Shah a/w Shri Himanshu Gandhi Revenue by : Smt. Sanyogita Nagpal Date of Hearing – 16/10/2023 Date of Order – 17/10/2023 O R D E R PER SANDEEP SINGH KARHAIL, J.M. The present appeal has been file…

M.K. Realtrade Pvt. Ltd, Faridabad vs. DCIT, Central Circle-II, Faridabad

In the result, the appeals of the assessee are allowed and that of the revenue is dismissed

ITA 3584/DEL/2018[2008-09]Status: DisposedITAT Delhi13 Sept 2023AY 2008-09

Bench: Sh. N. K. Billaiya & Sh. Anubhav Sharmaassessment Year: 2008-09 M/S. Bholeji Infratrade Pvt. Dcit Ltd. (Merged With M/S. Vs Central Circle-Ii Akriti Realtech Ltd. Shop Faridabad No.E-40, Nehru Ground, Faridabad Pan No.Aaccb9666L (Appellant) (Respondent) Assessment Year: 2008-09 M/S. M. K. Realtrade Pvt. Dcit Ltd. Rra Taxindia, D-28, Vs Central Circle-Ii South Extension, Part-1, Faridabad New Delhi Pan No.Aabcj8784C (Appellant) (Respondent) Assessment Year: 2008-09 Perfect Realtech P. Ltd. Dcit Rra Taxindia, D-28, South Vs Central Circle-Ii Extension, Part-1, Faridabad New Delhi Pan No.Aaecp0314K (Appellant) (Respondent)

Section 132Section 153ASection 153C

…the case of the captioned assessees (being person other than the search person) would have to be construed from the date of the recording of the satisfaction. This view is as per the decision of the Hon’ble Delhi High Court in the case of M/s. RRJ Securities 380 ITR 612. The relevant findings reads as under : - “In terms of proviso to Section 153C of the Act, a reference to the date of the search under the second proviso to Section 153A of the Act has to be construed as the date of handing over of assets/documents belonging to the Assessee (being the person other than the one searched) to the AO having jurisdic…

Perfect Realtech P.Ltd, Faridabad vs. DCIT, Central Circle-II, Faridabad

In the result, the appeals of the assessee are allowed and that of the revenue is dismissed

ITA 3583/DEL/2018[2008-09]Status: DisposedITAT Delhi13 Sept 2023AY 2008-09

Bench: Sh. N. K. Billaiya & Sh. Anubhav Sharmaassessment Year: 2008-09 M/S. Bholeji Infratrade Pvt. Dcit Ltd. (Merged With M/S. Vs Central Circle-Ii Akriti Realtech Ltd. Shop Faridabad No.E-40, Nehru Ground, Faridabad Pan No.Aaccb9666L (Appellant) (Respondent) Assessment Year: 2008-09 M/S. M. K. Realtrade Pvt. Dcit Ltd. Rra Taxindia, D-28, Vs Central Circle-Ii South Extension, Part-1, Faridabad New Delhi Pan No.Aabcj8784C (Appellant) (Respondent) Assessment Year: 2008-09 Perfect Realtech P. Ltd. Dcit Rra Taxindia, D-28, South Vs Central Circle-Ii Extension, Part-1, Faridabad New Delhi Pan No.Aaecp0314K (Appellant) (Respondent)

Section 132Section 153ASection 153C

…the case of the captioned assessees (being person other than the search person) would have to be construed from the date of the recording of the satisfaction. This view is as per the decision of the Hon’ble Delhi High Court in the case of M/s. RRJ Securities 380 ITR 612. The relevant findings reads as under : - “In terms of proviso to Section 153C of the Act, a reference to the date of the search under the second proviso to Section 153A of the Act has to be construed as the date of handing over of assets/documents belonging to the Assessee (being the person other than the one searched) to the AO having jurisdic…

Daksh Developers Pvt. Ltd., Faridabad vs. DCIT, Central Circle- II, Faridabad

In the result, the appeals of the assessee are allowed and that of the revenue is dismissed

ITA 3582/DEL/2018[2008-09]Status: DisposedITAT Delhi13 Sept 2023AY 2008-09

Bench: Sh. N. K. Billaiya & Sh. Anubhav Sharmaassessment Year: 2008-09 M/S. Bholeji Infratrade Pvt. Dcit Ltd. (Merged With M/S. Vs Central Circle-Ii Akriti Realtech Ltd. Shop Faridabad No.E-40, Nehru Ground, Faridabad Pan No.Aaccb9666L (Appellant) (Respondent) Assessment Year: 2008-09 M/S. M. K. Realtrade Pvt. Dcit Ltd. Rra Taxindia, D-28, Vs Central Circle-Ii South Extension, Part-1, Faridabad New Delhi Pan No.Aabcj8784C (Appellant) (Respondent) Assessment Year: 2008-09 Perfect Realtech P. Ltd. Dcit Rra Taxindia, D-28, South Vs Central Circle-Ii Extension, Part-1, Faridabad New Delhi Pan No.Aaecp0314K (Appellant) (Respondent)

Section 132Section 153ASection 153C

…the case of the captioned assessees (being person other than the search person) would have to be construed from the date of the recording of the satisfaction. This view is as per the decision of the Hon’ble Delhi High Court in the case of M/s. RRJ Securities 380 ITR 612. The relevant findings reads as under : - “In terms of proviso to Section 153C of the Act, a reference to the date of the search under the second proviso to Section 153A of the Act has to be construed as the date of handing over of assets/documents belonging to the Assessee (being the person other than the one searched) to the AO having jurisdic…