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.

How many judgments cite CIT v. RRJ Securities Ltd.?

689 judgments on BharatTax cite CIT v. RRJ Securities Ltd. (380 ITR 612), spanning 2015 to 2026.

Which sections of the Income Tax Act does CIT v. RRJ Securities Ltd. come up under?

It is most often cited in judgments turning on Section 153C, Section 143(3), Section 153A, Section 132, Section 148, Section 147.

CIT v. RRJ Securities Ltd. (380 ITR 612)

Dhiraj Jain, New Delhi vs. DCIT, New Delhi

The appeal of the assessee is allowed

ITA 4711/DEL/2011[2006-07]Status: DisposedITAT Delhi17 Nov 2021AY 2006-07

Bench: Ms Suchitra Kamble & Dr. B. R. R. Kumar(Through Video Conferencing) Vs Dhiraj Jain Dcit C/O. Prakash K. Prakash Central Circle-3, B-1, Sagar Apartments, 6, 3Rd Floor, Ara Centre, Tilak Marg, New Delhi Jhandewalan Extension, Pan: Aadpj4043R New Delhi (Appellant) (Respondent) C. O.No. 16/Del/2012 In (Ita No. 5525/Del/2011 ( A.Y 2005-06) Vs Dheeraj Kumar Jain Acit C/215, Vivek Vihar, Central Circle-3 New Delhi Room No. 355, Ara Pan: Aadpj4043R Centre,E-2,Jhandewalan (Appellant) Extension, New Delhi (Respondent) Vs Dhiraj Jain Dcit C/O. Prakash K. Prakash Central Circle-3, B-1, Sagar Apartments, 6, 3Rd Floor, Ara Centre, Tilak Marg, New Delhi Jhandewalan Extension, Pan: Aadpj4043R New Delhi (Appellant) (Respondent) Acit Vs Dheeraj Kumar Jain Central Circle-3 C/215, Vivek Vihar, Room No. 355, New Delhi Ara Centre,E-2, Jhandewalan Pan: Aadpj4043R (Respondent) Extension, New Delhi (Appellant) C.O No. 19/Del/2012 ( A.Y 2007-08) In (In Ita No. 5527/Del/2011 (A.Y 2007-08 ) Dheeraj Kumar Jain Vs Acit C/215, Vivek Vihar, Central Circle-3 New Delhi Room No. 355, Ara Pan: Aadpj4043R Centre,E-2,Jhandewalan (Appellant) Extension, New Delhi (Respondent)

Section 153Section 153CSection 2Section 68Section 69

…1 ITA Nos. 4710/Del/2011 & Ors IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘B’ NEW DELHI BEFORE MS SUCHITRA KAMBLE, JUDICIAL MEMBER AND DR. B. R. R. KUMAR, ACCOUNTANT MEMBER (THROUGH VIDEO CONFERENCING) Vs Dhiraj Jain DCIT C/o. Prakash K. Prakash Central Circle-3, B-1, Sagar Apartments, 6, 3rd Floor, ARA Centre, Tilak Marg, New Delhi Jhandewalan Extension, PAN: AADPJ4043R New Delhi (APPELLANT) (RESPONDENT) C. O.No. 16/Del/2012 in (ITA No. 5525/DEL/2011 ( A.Y 2005-06) Vs Dheeraj Kumar Jain ACIT C/215, Vivek Vihar, Central Circle-3 New Delhi Room No. 355, ARA PAN: AADPJ4043R Centre,E-2,Jhandewalan (APPEL…

Dhiraj Jain, New Delhi vs. DCIT, New Delhi

The appeal of the assessee is allowed

ITA 4710/DEL/2011[2003-04]Status: DisposedITAT Delhi17 Nov 2021AY 2003-04

Bench: Ms Suchitra Kamble & Dr. B. R. R. Kumar(Through Video Conferencing) Vs Dhiraj Jain Dcit C/O. Prakash K. Prakash Central Circle-3, B-1, Sagar Apartments, 6, 3Rd Floor, Ara Centre, Tilak Marg, New Delhi Jhandewalan Extension, Pan: Aadpj4043R New Delhi (Appellant) (Respondent) C. O.No. 16/Del/2012 In (Ita No. 5525/Del/2011 ( A.Y 2005-06) Vs Dheeraj Kumar Jain Acit C/215, Vivek Vihar, Central Circle-3 New Delhi Room No. 355, Ara Pan: Aadpj4043R Centre,E-2,Jhandewalan (Appellant) Extension, New Delhi (Respondent) Vs Dhiraj Jain Dcit C/O. Prakash K. Prakash Central Circle-3, B-1, Sagar Apartments, 6, 3Rd Floor, Ara Centre, Tilak Marg, New Delhi Jhandewalan Extension, Pan: Aadpj4043R New Delhi (Appellant) (Respondent) Acit Vs Dheeraj Kumar Jain Central Circle-3 C/215, Vivek Vihar, Room No. 355, New Delhi Ara Centre,E-2, Jhandewalan Pan: Aadpj4043R (Respondent) Extension, New Delhi (Appellant) C.O No. 19/Del/2012 ( A.Y 2007-08) In (In Ita No. 5527/Del/2011 (A.Y 2007-08 ) Dheeraj Kumar Jain Vs Acit C/215, Vivek Vihar, Central Circle-3 New Delhi Room No. 355, Ara Pan: Aadpj4043R Centre,E-2,Jhandewalan (Appellant) Extension, New Delhi (Respondent)

Section 153Section 153CSection 2Section 68Section 69

…1 ITA Nos. 4710/Del/2011 & Ors IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘B’ NEW DELHI BEFORE MS SUCHITRA KAMBLE, JUDICIAL MEMBER AND DR. B. R. R. KUMAR, ACCOUNTANT MEMBER (THROUGH VIDEO CONFERENCING) Vs Dhiraj Jain DCIT C/o. Prakash K. Prakash Central Circle-3, B-1, Sagar Apartments, 6, 3rd Floor, ARA Centre, Tilak Marg, New Delhi Jhandewalan Extension, PAN: AADPJ4043R New Delhi (APPELLANT) (RESPONDENT) C. O.No. 16/Del/2012 in (ITA No. 5525/DEL/2011 ( A.Y 2005-06) Vs Dheeraj Kumar Jain ACIT C/215, Vivek Vihar, Central Circle-3 New Delhi Room No. 355, ARA PAN: AADPJ4043R Centre,E-2,Jhandewalan (APPEL…

Jasmin K Ajmera, Mumbai vs. DCIT CC 2(2), Mumbai

The appeal stand allowed

ITA 983/MUM/2020[2011-12]Status: DisposedITAT Mumbai02 Nov 2021AY 2011-12

Bench: Hon’Ble Shri C.N. Prasad, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am (Hearing Through Video Conferencing Mode) 1. आयकरअपील सं./ I.T.A. No. 983/Mum/2020 (धििाारण वर्ा / Assessment Year: 2011-12) Jasmin K. Ajmera Dcit-2(2), 4Th Floor, Ajmera House R. No. 806, 8Th Floor बिाम/ Pathakwadi, L. T. Marg, Old Cgo Building, Vs. Mumbai-400 002 M.K.Road, Mumbai-400 020 स्थायीलेखासं./ जीआइआरसं./ Pan/Gir No. Aabpa-7827-Q (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : & 2. आयकरअपील सं./ I.T.A. No.1140/Mum/2020 (धििाारण वर्ा / Assessment Year: 2011-12) Shri Ashish K. Ajmera Dcit-2(2), Ajmera House, 4Th Floor R. No. 806, 8Th Floor बिाम Pathakwadi, L.T.Marg Old Cgo Building, / Vs. Mumbai – 400 002 M.K.Road, Mumbai-400 020 स्थायीलेखासं./ जीआइआरसं./ Pan/Gir No. Aabpa-9075-G (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : & 3. आयकरअपील सं./ I.T.A. No.1113/Mum/2020 (धििाारण वर्ा / Assessment Year: 2011-12) Minal M. Ajmera Dcit-2(2), 4Th Floor, Ajmera House, R. No. 806, 8Th Floor बिाम/ Vs. Pathakwadi, L. T. Marg, Old Cgo Building, Mumbai-400 002 M.K.Road, Mumbai-400020 स्थायीलेखासं./ जीआइआरसं./ Pan/Gir No. Adepa-9661-N (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : & 4. आयकरअपील सं./ I.T.A. No. 539/Mum/2020 (धििाारण वर्ा / Assessment Year: 2011-12) Avani J. Ajmera Dcit-2(2), 4Th Floor, Ajmera House, R. No. 806, 8Th Floor बिाम/ Vs. Pathakwadi, L. T. Marg, Old Cgo Building, Mumbai-400 002 M.K.Road, Mumbai-400020 स्थायीलेखासं./ जीआइआरसं./ Pan/Gir No. Addpa-9331-J (अपीलाथी/Appellant) (प्रत्यथी / Respondent) :

Section 143(3)Section 153A

…material was unearthed during the search, no additions could have been made to income already assessed. Consequently, the impugned addition was to be deleted”. 14. The Hon'ble Delhi High Court followed this decision in the case of CIT v. RRJ Securities Ltd., [380 ITR 612]. 15. The Hon'ble Delhi High Court in the case of Pr.CIT v. Meeta Gutgutia (supra) held that invocation of section 153(A) to reopen concluded assessments of assessment years earlier to year of search was not justified in absence of incriminating material found during search qua each such earlier assessment years. 16. In all the above decisions of…

DCIT, Central Circle- 25, New Delhi vs. Htl Ltd., Chennai

Accordingly, appeal of the ld AO is dismissed

ITA 716/DEL/2018[2000-01]Status: DisposedITAT Delhi14 Oct 2021AY 2000-01

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Ms. Sunita Singh, CIT DR

Section 143(3)Section 147Section 153ASection 153CSection 43B

…pending before the coordinate bench. 8. On this issue he submitted that the notice is issued u/s 153C of the Act on 05.11.2009 and therefore, it is the deemed date of search in view of the decision of the Hon'ble Delhi High Court in CIT Vs. RRJ Securities Ltd 380 ITR 612. As on the date of search the assessment was completed u/s 143(3) read with section 147 of the Act by order dated 31.12.2008 and therefore, it was a concluded assessment. He further referred to the assessment order and submitted that the addition has been made on the basis of perusal of the profit and loss account itself and without any incrimina…

DCIT, New Delhi vs. M/S Htl Ltd., Chennai

Accordingly, appeal of the ld AO is dismissed

ITA 3959/DEL/2016[2010-11]Status: DisposedITAT Delhi14 Oct 2021AY 2010-11

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Ms. Sunita Singh, CIT DR

Section 143(3)Section 147Section 153ASection 153CSection 43B

…pending before the coordinate bench. 8. On this issue he submitted that the notice is issued u/s 153C of the Act on 05.11.2009 and therefore, it is the deemed date of search in view of the decision of the Hon'ble Delhi High Court in CIT Vs. RRJ Securities Ltd 380 ITR 612. As on the date of search the assessment was completed u/s 143(3) read with section 147 of the Act by order dated 31.12.2008 and therefore, it was a concluded assessment. He further referred to the assessment order and submitted that the addition has been made on the basis of perusal of the profit and loss account itself and without any incrimina…

DCIT, New Delhi vs. M/S Htl Ltd., Chennai

Accordingly, appeal of the ld AO is dismissed

ITA 3958/DEL/2016[2009-10]Status: DisposedITAT Delhi14 Oct 2021AY 2009-10

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Ms. Sunita Singh, CIT DR

Section 143(3)Section 147Section 153ASection 153CSection 43B

…pending before the coordinate bench. 8. On this issue he submitted that the notice is issued u/s 153C of the Act on 05.11.2009 and therefore, it is the deemed date of search in view of the decision of the Hon'ble Delhi High Court in CIT Vs. RRJ Securities Ltd 380 ITR 612. As on the date of search the assessment was completed u/s 143(3) read with section 147 of the Act by order dated 31.12.2008 and therefore, it was a concluded assessment. He further referred to the assessment order and submitted that the addition has been made on the basis of perusal of the profit and loss account itself and without any incrimina…

DCIT, New Delhi vs. M/S Htl Ltd., Chennai

Accordingly, appeal of the ld AO is dismissed

ITA 3957/DEL/2016[2008-09]Status: DisposedITAT Delhi14 Oct 2021AY 2008-09

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Ms. Sunita Singh, CIT DR

Section 143(3)Section 147Section 153ASection 153CSection 43B

…pending before the coordinate bench. 8. On this issue he submitted that the notice is issued u/s 153C of the Act on 05.11.2009 and therefore, it is the deemed date of search in view of the decision of the Hon'ble Delhi High Court in CIT Vs. RRJ Securities Ltd 380 ITR 612. As on the date of search the assessment was completed u/s 143(3) read with section 147 of the Act by order dated 31.12.2008 and therefore, it was a concluded assessment. He further referred to the assessment order and submitted that the addition has been made on the basis of perusal of the profit and loss account itself and without any incrimina…

DCIT, New Delhi vs. M/S Htl Ltd., Chennai

Accordingly, appeal of the ld AO is dismissed

ITA 3956/DEL/2016[2006-07]Status: DisposedITAT Delhi14 Oct 2021AY 2006-07

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Ms. Sunita Singh, CIT DR

Section 143(3)Section 147Section 153ASection 153CSection 43B

…pending before the coordinate bench. 8. On this issue he submitted that the notice is issued u/s 153C of the Act on 05.11.2009 and therefore, it is the deemed date of search in view of the decision of the Hon'ble Delhi High Court in CIT Vs. RRJ Securities Ltd 380 ITR 612. As on the date of search the assessment was completed u/s 143(3) read with section 147 of the Act by order dated 31.12.2008 and therefore, it was a concluded assessment. He further referred to the assessment order and submitted that the addition has been made on the basis of perusal of the profit and loss account itself and without any incrimina…

DCIT, New Delhi vs. M/S Htl Ltd., Chennai

Accordingly, appeal of the ld AO is dismissed

ITA 3955/DEL/2016[2005-06]Status: DisposedITAT Delhi14 Oct 2021AY 2005-06

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Ms. Sunita Singh, CIT DR

Section 143(3)Section 147Section 153ASection 153CSection 43B

…pending before the coordinate bench. 8. On this issue he submitted that the notice is issued u/s 153C of the Act on 05.11.2009 and therefore, it is the deemed date of search in view of the decision of the Hon'ble Delhi High Court in CIT Vs. RRJ Securities Ltd 380 ITR 612. As on the date of search the assessment was completed u/s 143(3) read with section 147 of the Act by order dated 31.12.2008 and therefore, it was a concluded assessment. He further referred to the assessment order and submitted that the addition has been made on the basis of perusal of the profit and loss account itself and without any incrimina…

DCIT, New Delhi vs. M/S Htl Ltd., Chennai

Accordingly, appeal of the ld AO is dismissed

ITA 3954/DEL/2016[2004-05]Status: DisposedITAT Delhi14 Oct 2021AY 2004-05

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Ms. Sunita Singh, CIT DR

Section 143(3)Section 147Section 153ASection 153CSection 43B

…pending before the coordinate bench. 8. On this issue he submitted that the notice is issued u/s 153C of the Act on 05.11.2009 and therefore, it is the deemed date of search in view of the decision of the Hon'ble Delhi High Court in CIT Vs. RRJ Securities Ltd 380 ITR 612. As on the date of search the assessment was completed u/s 143(3) read with section 147 of the Act by order dated 31.12.2008 and therefore, it was a concluded assessment. He further referred to the assessment order and submitted that the addition has been made on the basis of perusal of the profit and loss account itself and without any incrimina…

DCIT, New Delhi vs. M/S Htl Ltd., Chennai

Accordingly, appeal of the ld AO is dismissed

ITA 3953/DEL/2016[2003-04]Status: DisposedITAT Delhi14 Oct 2021AY 2003-04

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Ms. Sunita Singh, CIT DR

Section 143(3)Section 147Section 153ASection 153CSection 43B

…pending before the coordinate bench. 8. On this issue he submitted that the notice is issued u/s 153C of the Act on 05.11.2009 and therefore, it is the deemed date of search in view of the decision of the Hon'ble Delhi High Court in CIT Vs. RRJ Securities Ltd 380 ITR 612. As on the date of search the assessment was completed u/s 143(3) read with section 147 of the Act by order dated 31.12.2008 and therefore, it was a concluded assessment. He further referred to the assessment order and submitted that the addition has been made on the basis of perusal of the profit and loss account itself and without any incrimina…

DCIT, New Delhi vs. M/S Htl Ltd., Chennai

Accordingly, appeal of the ld AO is dismissed

ITA 3952/DEL/2016[2002-03]Status: DisposedITAT Delhi14 Oct 2021AY 2002-03

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Ms. Sunita Singh, CIT DR

Section 143(3)Section 147Section 153ASection 153CSection 43B

…pending before the coordinate bench. 8. On this issue he submitted that the notice is issued u/s 153C of the Act on 05.11.2009 and therefore, it is the deemed date of search in view of the decision of the Hon'ble Delhi High Court in CIT Vs. RRJ Securities Ltd 380 ITR 612. As on the date of search the assessment was completed u/s 143(3) read with section 147 of the Act by order dated 31.12.2008 and therefore, it was a concluded assessment. He further referred to the assessment order and submitted that the addition has been made on the basis of perusal of the profit and loss account itself and without any incrimina…

DCIT Central Circle-3, New Delhi vs. Modtech Industries, New Delhi

In the result, since the assessment order is set aside on legal issue, therefore, there is no need to decide the additions on merits which are left with academic discussion only

ITA 8783/DEL/2019[2015-16]Status: DisposedITAT Delhi13 Oct 2021AY 2015-16

Bench: Shri Amit Shukla & Prashant Maharishi

For Appellant: Shri Salil Aggarwal, Sr. AdvFor Respondent: Shri J.K. Mishra, CIT-DR

Section 132(1)Section 143(2)Section 153ASection 153CSection 153DSection 50B

…submitted that the said arguments were specifically taken before learned CIT (A) wherein, judgments of Hon’ble Delhi High Court in the case of Pr. CIT Central-2 Vs. Index Securities Pvt. Ltd. 86 Taxmann.com 84 (Delhi), CIT Vs. RRJ Securities Ltd. reported in 380 ITR 612, and by the Supreme Court in the case of CIT Vs. Sinhgad Technical Education Society reported in 397 ITR 344, were cited before learned CIT (A) (kindly see page 8 to 9 of CIT (A)’s order). However, the learned CIT (A) vide order dated 21.08.2019 dismissed the said ground so raised by the assessee company (kindly see pages 89 to 93 of CIT (A) orde…

Modtech Industries, New Delhi vs. DCIT Central Circle-2, New Delhi

In the result, since the assessment order is set aside on legal issue, therefore, there is no need to decide the additions on merits which are left with academic discussion only

ITA 8045/DEL/2019[2015-16]Status: DisposedITAT Delhi13 Oct 2021AY 2015-16

Bench: Shri Amit Shukla & Prashant Maharishi

For Appellant: Shri Salil Aggarwal, Sr. AdvFor Respondent: Shri J.K. Mishra, CIT-DR

Section 132(1)Section 143(2)Section 153ASection 153CSection 153DSection 50B

…submitted that the said arguments were specifically taken before learned CIT (A) wherein, judgments of Hon’ble Delhi High Court in the case of Pr. CIT Central-2 Vs. Index Securities Pvt. Ltd. 86 Taxmann.com 84 (Delhi), CIT Vs. RRJ Securities Ltd. reported in 380 ITR 612, and by the Supreme Court in the case of CIT Vs. Sinhgad Technical Education Society reported in 397 ITR 344, were cited before learned CIT (A) (kindly see page 8 to 9 of CIT (A)’s order). However, the learned CIT (A) vide order dated 21.08.2019 dismissed the said ground so raised by the assessee company (kindly see pages 89 to 93 of CIT (A) orde…

Smt. Vanita Vaswani, Ahmedabad vs. The Pr. CIT (Central), Ahmedabad

In the result, appeal of the assessee is allowed

ITA 133/AHD/2021[2010-11]Status: DisposedITAT Ahmedabad17 Sept 2021AY 2010-11

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedassessment Years : 2010-11 Smt. Vanita Vaswani, The Pcit (Central), 2, Samprat Co-Op. Housing Vs Ahmedabad Society Limited, Opp. Rivera, 11, Prahladnagar, Ahmedabad - 380015 Pan : Aakpv 7868 D अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "त् "त् यथ" "त् "त् यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Tushar Hemani, Sr. Advocate Shri Parimalsinh B Parmar, Ar & Shri Vijay Govani, Ar Revenue By : Shri Virendra Ojha, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 28/07/2021 घोषणा क" तारीख /Date Of Pronouncement: 17/09/2021 आदेश/O R D E R आदेश आदेश आदेश Per Rajpal Yadav: The Present Appeal Is Directed At The Instance Of The Assessee Against The Order Of The Learned Principal Commissioner Of Income Tax (Central), Ahmedabad Dated 28.03.2021, Passed Under Section 263 Of The Income Tax Act, 1961 (In Short “The Act”), For Assessment Year 2010-2011. The Assessee Has Taken 7 Grounds Of Appeal Which Read As Under:- “1. The Ld. Pcit (Central), Ahmedabad ("The Pcit") Has Erred On Facts & In Law In Invoking Jurisdiction U/S 263 Of The Income Tax Act, 1961 ("The Act") & Has Further Erred In Directing The Ld. Ao To Pass Fresh Assessment Order Incorporating The Market Value Of The Property As Per Section 50C Of The Act. 2. The Ld. Pcit Has Erred On Facts & In Law In Passing Order U/S 263 Of The Income Tax Act, 1961 In The Case Of The Appellant In Failing To Take Smt. Vanita Vaswani Vs. Pr. Cit Ay : 2010-2011 2

For Appellant: Shri Tushar Hemani, Sr. AdvocateFor Respondent: Shri Virendra Ojha, CIT-DR

Section 143(3)Section 153CSection 263Section 50C

…Act either to drop the proceedings u/s. 153C or to issue Smt. Vanita Vaswani Vs. Pr. CIT AY : 2010-2011 15 second set of notices. The appellant has also relied upon the case laws in the case of Pepsico India Holding Pvt. Ltd. Vs. ACIT, RRJ Securities Ltd. [62 Taxmann.com 391] (2015) & Sinhgad Technical Education Society [84 Taxmann.com 290]. The AO has dealt with the argument raised by the appellant in Para 4.9, 4.10 & Para 5 of assessment order. The provision of Section 153C has been amended with effect from 01/06/2015 where if the Assessing Officer is satisfied that any books of account or documents seized p…

DCIT 7(3), Mumbai vs. M/S Trishul Realty Infra Pvt Ltd., Mumbai

In the result, the cross objection filed by the assessee is allowed and the appeal filed by the revenue is dismissed

ITA 4042/MUM/2019[201-13]Status: DisposedITAT Mumbai16 Sept 2021

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Rushabh MehtaFor Respondent: Shri Sanjeev Kashyap

Section 132Section 143(3)Section 153ASection 153A(1)(a)

…IN THE INCOME TAX APPELLATE TRIBUNAL (VIRTUAL COURT) “E” BENCH, MUMBAI BEFORE SHRI C.N. PRASAD, HON'BLE JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, HON'BLE ACCOUNTANT MEMBER ITA.NOs. 4041 & 4042/MUM/2019 (A.Ys: 2011-12 & 2012-13) Dy. CIT – Central Circle -7(3) v. M/s. Trishul Realty Infra Pvt. Ltd., Room No. 655, 6th Floor Office No. 01, 2nd Floor 3, Patel Bhuvan, Aayakar Bhavan, M.K. Road 29, Dr. N.N Shah Lane Mumbai - 400020 Cheera Bazar, Mumbai -400002 PAN: AADCT0412D (Appellant) (Respondent) C.O. No. 73/MUM/2020 [ARISING OUT OF ITA.NO. 4041/MUM/2019 (A.Y. 2011-12)] & C.O.No. 16/MUM/2021 [ARISING OUT OF ITA.NO.…

DCIT CC 7(3), Mumbai vs. M/S Trishul Realty Infra Pvt. Ltd., Mumbai

In the result, the cross objection filed by the assessee is allowed and the appeal filed by the revenue is dismissed

ITA 4041/MUM/2019[2011-12]Status: DisposedITAT Mumbai16 Sept 2021AY 2011-12

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Rushabh MehtaFor Respondent: Shri Sanjeev Kashyap

Section 132Section 143(3)Section 153ASection 153A(1)(a)

…IN THE INCOME TAX APPELLATE TRIBUNAL (VIRTUAL COURT) “E” BENCH, MUMBAI BEFORE SHRI C.N. PRASAD, HON'BLE JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, HON'BLE ACCOUNTANT MEMBER ITA.NOs. 4041 & 4042/MUM/2019 (A.Ys: 2011-12 & 2012-13) Dy. CIT – Central Circle -7(3) v. M/s. Trishul Realty Infra Pvt. Ltd., Room No. 655, 6th Floor Office No. 01, 2nd Floor 3, Patel Bhuvan, Aayakar Bhavan, M.K. Road 29, Dr. N.N Shah Lane Mumbai - 400020 Cheera Bazar, Mumbai -400002 PAN: AADCT0412D (Appellant) (Respondent) C.O. No. 73/MUM/2020 [ARISING OUT OF ITA.NO. 4041/MUM/2019 (A.Y. 2011-12)] & C.O.No. 16/MUM/2021 [ARISING OUT OF ITA.NO.…

DCIT Circle-I(Ltu), New Delhi vs. Dalmia Bharat Sugar and Industries Ltd., New Delhi

Accordingly we dispose of the matters for AY 2007-08 to 2011-12 for the same reasons as under :- i. Thus, For AY 2007-08, Ground no 1 & 2 of the appeal of the ld AO are dismissed

ITA 5406/DEL/2019[2011-12]Status: DisposedITAT Delhi13 Sept 2021AY 2011-12

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Ms. Nidhi Srivatava, CIT DR

Section 153CSection 245

…4. Therefore, he submitted that the assessment order passed u/s 153C for assessment year 2006 – 07 and 2007 – 08 are barred by limitation. For this proposition he referred the decision of the honourable Delhi High Court in CIT versus RRJ securities Ltd (2016) 380 ITR 612, SSP aviation Ltd versus Deputy Commissioner Of Income Tax (2012) 346 ITR 177, Principal Commissioner Of Income Tax versus sarvar Agencies Private Limited (2017) 397 ITR 400 and host of other judicial precedents of the coordinate benches. Therefore, he submitted that the assessment order passed u/s 153C of the act for assessment year 2006 – 07 an…

DCIT Circle-I(Ltu), New Delhi vs. Dalmia Bharat Sugar and Industries Ltd., New Delhi

Accordingly we dispose of the matters for AY 2007-08 to 2011-12 for the same reasons as under :- i. Thus, For AY 2007-08, Ground no 1 & 2 of the appeal of the ld AO are dismissed

ITA 5405/DEL/2019[2010-11]Status: DisposedITAT Delhi13 Sept 2021AY 2010-11

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Ms. Nidhi Srivatava, CIT DR

Section 153CSection 245

…4. Therefore, he submitted that the assessment order passed u/s 153C for assessment year 2006 – 07 and 2007 – 08 are barred by limitation. For this proposition he referred the decision of the honourable Delhi High Court in CIT versus RRJ securities Ltd (2016) 380 ITR 612, SSP aviation Ltd versus Deputy Commissioner Of Income Tax (2012) 346 ITR 177, Principal Commissioner Of Income Tax versus sarvar Agencies Private Limited (2017) 397 ITR 400 and host of other judicial precedents of the coordinate benches. Therefore, he submitted that the assessment order passed u/s 153C of the act for assessment year 2006 – 07 an…

DCIT Circle-I(Ltu), New Delhi vs. Dalmia Bharat Sugar and Industries Ltd., New Delhi

Accordingly we dispose of the matters for AY 2007-08 to 2011-12 for the same reasons as under :- i. Thus, For AY 2007-08, Ground no 1 & 2 of the appeal of the ld AO are dismissed

ITA 5404/DEL/2019[2009-10]Status: DisposedITAT Delhi13 Sept 2021AY 2009-10

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Ms. Nidhi Srivatava, CIT DR

Section 153CSection 245

…4. Therefore, he submitted that the assessment order passed u/s 153C for assessment year 2006 – 07 and 2007 – 08 are barred by limitation. For this proposition he referred the decision of the honourable Delhi High Court in CIT versus RRJ securities Ltd (2016) 380 ITR 612, SSP aviation Ltd versus Deputy Commissioner Of Income Tax (2012) 346 ITR 177, Principal Commissioner Of Income Tax versus sarvar Agencies Private Limited (2017) 397 ITR 400 and host of other judicial precedents of the coordinate benches. Therefore, he submitted that the assessment order passed u/s 153C of the act for assessment year 2006 – 07 an…

CIT v. RRJ Securities Ltd.

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Judgments citing CIT v. RRJ Securities Ltd.

Dhiraj Jain, New Delhi vs. DCIT, New Delhi

Dhiraj Jain, New Delhi vs. DCIT, New Delhi

Jasmin K Ajmera, Mumbai vs. DCIT CC 2(2), Mumbai

DCIT, Central Circle- 25, New Delhi vs. Htl Ltd., Chennai

DCIT, New Delhi vs. M/S Htl Ltd., Chennai

DCIT, New Delhi vs. M/S Htl Ltd., Chennai

DCIT, New Delhi vs. M/S Htl Ltd., Chennai

DCIT, New Delhi vs. M/S Htl Ltd., Chennai

DCIT, New Delhi vs. M/S Htl Ltd., Chennai

DCIT, New Delhi vs. M/S Htl Ltd., Chennai

DCIT, New Delhi vs. M/S Htl Ltd., Chennai

DCIT, New Delhi vs. M/S Htl Ltd., Chennai

DCIT Central Circle-3, New Delhi vs. Modtech Industries, New Delhi

Modtech Industries, New Delhi vs. DCIT Central Circle-2, New Delhi

Smt. Vanita Vaswani, Ahmedabad vs. The Pr. CIT (Central), Ahmedabad

DCIT 7(3), Mumbai vs. M/S Trishul Realty Infra Pvt Ltd., Mumbai

DCIT CC 7(3), Mumbai vs. M/S Trishul Realty Infra Pvt. Ltd., Mumbai

DCIT Circle-I(Ltu), New Delhi vs. Dalmia Bharat Sugar and Industries Ltd., New Delhi

DCIT Circle-I(Ltu), New Delhi vs. Dalmia Bharat Sugar and Industries Ltd., New Delhi

DCIT Circle-I(Ltu), New Delhi vs. Dalmia Bharat Sugar and Industries Ltd., New Delhi