CIT v. S. Ajit Kumar

404 ITR 526Supreme Court of India2018#3756 most cited

What is CIT v. S. Ajit Kumar authority for?

When a search under section 132 and a survey under section 133A are conducted simultaneously, material found during the survey can be considered for assessment under section 153A.

32

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2018 to 2025.

Also referred to as

CIT v. S. Ajit Kumar · 404 ITR 526 · SC · section 132 · section 133A · section 153A · simultaneous search and survey · material found during survey · assessment under section 153A

Sections most often in play

Section 153ASection 132Section 143(3)Section 153CSection 132(4)Section 143(2)Section 158BBSection 68

Issues it is cited on

section 292cccash found during searchsummons under section 131interest u/s 234csection 158bbpanchnamasection 292csection 271aabunexplained jewellerypreponderance of probabilitybogus long term capital gainsection 149(1)(b)

Judgments citing CIT v. S. Ajit Kumar

V S A INFRA PROJECTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of assessee in ITA Nos

ITA 906/HYD/2025[2019-20]Status: DisposedITAT Hyderabad26 Nov 2025AY 2019-20
Section 132Section 132ASection 133ASection 143(3)Section 153A

…f the Act, is bad in law and liable to be quashed. 24. The Learned Counsel for the Revenue had also argued the issue at length in light of certain judicial precedents, including the decision of Hon’ble Supreme Court in the case of CIT Vs. S. Ajit Kumar (2018) 404 ITR 526 and also the decision of Hon’ble Madras High Court in the case of M/s. S.R. Trust Vs. ACIT/DCIT, Madurai in W.P. (MD) No. 22213 to 22224 of 2018 dated 12.03.2021 and argued that, when there was a simultaneous search action under Section 132 and survey action under Section 133A of the Income Tax Act, 1961, then the A.O. can consider the material f…

V S A INFRA PROJECTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of assessee in ITA Nos

ITA 905/HYD/2025[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19
Section 132Section 132ASection 133ASection 143(3)Section 153A

…f the Act, is bad in law and liable to be quashed. 24. The Learned Counsel for the Revenue had also argued the issue at length in light of certain judicial precedents, including the decision of Hon’ble Supreme Court in the case of CIT Vs. S. Ajit Kumar (2018) 404 ITR 526 and also the decision of Hon’ble Madras High Court in the case of M/s. S.R. Trust Vs. ACIT/DCIT, Madurai in W.P. (MD) No. 22213 to 22224 of 2018 dated 12.03.2021 and argued that, when there was a simultaneous search action under Section 132 and survey action under Section 133A of the Income Tax Act, 1961, then the A.O. can consider the material f…

V S A INFRA PROJECTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of assessee in ITA Nos

ITA 904/HYD/2025[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

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

…f the Act, is bad in law and liable to be quashed. 24. The Learned Counsel for the Revenue had also argued the issue at length in light of certain judicial precedents, including the decision of Hon’ble Supreme Court in the case of CIT Vs. S. Ajit Kumar (2018) 404 ITR 526 and also the decision of Hon’ble Madras High Court in the case of M/s. S.R. Trust Vs. ACIT/DCIT, Madurai in W.P. (MD) No. 22213 to 22224 of 2018 dated 12.03.2021 and argued that, when there was a simultaneous search action under Section 132 and survey action under Section 133A of the Income Tax Act, 1961, then the A.O. can consider the material f…

V S A INFRA PROJECTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of assessee in ITA Nos

ITA 903/HYD/2025[2016-17]Status: DisposedITAT Hyderabad26 Nov 2025AY 2016-17

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON'BLE (Accountant Member)

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

…f the Act, is bad in law and liable to be quashed. 24. The Learned Counsel for the Revenue had also argued the issue at length in light of certain judicial precedents, including the decision of Hon’ble Supreme Court in the case of CIT Vs. S. Ajit Kumar (2018) 404 ITR 526 and also the decision of Hon’ble Madras High Court in the case of M/s. S.R. Trust Vs. ACIT/DCIT, Madurai in W.P. (MD) No. 22213 to 22224 of 2018 dated 12.03.2021 and argued that, when there was a simultaneous search action under Section 132 and survey action under Section 133A of the Income Tax Act, 1961, then the A.O. can consider the material f…

V S A INFRA PROJECTS PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE -1(2), HYDERABAD

In the result, the appeal of assessee in ITA Nos

ITA 902/HYD/2025[2014-15]Status: DisposedITAT Hyderabad26 Nov 2025AY 2014-15
Section 132Section 132ASection 133ASection 143(3)Section 153A

…f the Act, is bad in law and liable to be quashed. 24. The Learned Counsel for the Revenue had also argued the issue at length in light of certain judicial precedents, including the decision of Hon’ble Supreme Court in the case of CIT Vs. S. Ajit Kumar (2018) 404 ITR 526 and also the decision of Hon’ble Madras High Court in the case of M/s. S.R. Trust Vs. ACIT/DCIT, Madurai in W.P. (MD) No. 22213 to 22224 of 2018 dated 12.03.2021 and argued that, when there was a simultaneous search action under Section 132 and survey action under Section 133A of the Income Tax Act, 1961, then the A.O. can consider the material f…

AMRISH TYAGI,GHAZIABAD vs. DCIT, CENTRAL CIRCLE, GHAZIABAD

In the result, both the appeals of the assessee are allowed

ITA 1949/DEL/2023[2011-12]Status: DisposedITAT Delhi27 Dec 2024AY 2011-12

Bench: BEFORESHRI S RIFAUR RAHMAN, ACCOUNTANT MEMBER ANDSHRI SUDHIR KUMAR (Judicial Member)

Section 143(3)Section 153ASection 153DSection 69A

…searched as part of VVIP group along with premises of Shri Praveen Tyagi and the premises of VVIP Ltd, has no substance. We have also found that the ld DR has relied on the decision of the Hon'ble Supreme Court in the case of CIT Vs. S Ajit Kumar reported in 404 ITR 526 (SC) wherein, it was held that any material or evidence found/ collected in a survey which has been simultaneously made at premises of connected person can be utilized while making block assessment in respect of an assessee u/s 158BB read with section 158BH of the Act as it would fall under words “and such other materials or information as are av…

SARIKA TYAGI,GHAZIBAD vs. DCIT, CENTRAL CIRCLE, GHAZAIBAD

Accordingly, Ground No. 2 raised by the revenue is dismissed

ITA 1414/DEL/2022[2016-17]Status: DisposedITAT Delhi10 Oct 2024AY 2016-17

Bench: Shri M. Balaganesh & Shri Vimal Kumardcit, Vs. Sushil Tyagi, Central Circle, A-2, Ganpati Ghaziabad Apartments, Civil Lines, New Delhi (Appellant) (Respondent) Pan:Aejpt6739A Dcit, Vs. Yogender Singh, Central Circle, J-6A, Sector-23, Ghaziabad Sanjay Nagar, Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Yogender Singh, Vs. Dcit, J-6A, Sector-23, Central Circle, Sanjay Nagar, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Naveen Tyagi, Vs. Dcit, G-302, Vvip Central Circle, Addresses, Raj Nagar Ghaziabad Extention, Ghaziabad (Appellant) (Respondent) Pan:Admpt6420A Sarika Tyagi, Vs. Dcit, H-100, Patel Nagar,- Central Circle, 3, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Afapt5986P Assessee By : Shri Rajeev Khandelwal, Ca Shri Gagan Khandelwal, Adv Shri Jaind Jaiswal, Adv Revenue By: Ms. Sapna Bhatia, Cit Dr Date Of Hearing 23/08/2024 Date Of Pronouncement /10/2024

For Appellant: Shri Rajeev Khandelwal, CAFor Respondent: Ms. Sapna Bhatia, CIT DR
Section 132Section 143(2)Section 68

…searched as part of VVIP group along with premises of Shri Praveen Tyagi and the premises of VVIP Ltd, has no substance. We have also found that the ld DR has relied on the decision of the Hon'ble Supreme Court in the case of CIT Vs. S Ajit Kumar reported in 404 ITR 526 (SC) wherein, it was held that any material or evidence found/ collected in a survey which has been simultaneously made at premises of connected person can be utilized while making block assessment in respect of an assessee u/s 158BB read with section 158BH of the Act as it would fall under words “and such other materials or information as are av…

YOGENDER SINGH,GHAZIABAD vs. DCIT, CENTRAL CIRCLE, GHAZIABAD

Accordingly, Ground No. 2 raised by the revenue is dismissed

ITA 1413/DEL/2022[2017-18]Status: DisposedITAT Delhi10 Oct 2024AY 2017-18

Bench: Shri M. Balaganesh & Shri Vimal Kumardcit, Vs. Sushil Tyagi, Central Circle, A-2, Ganpati Ghaziabad Apartments, Civil Lines, New Delhi (Appellant) (Respondent) Pan:Aejpt6739A Dcit, Vs. Yogender Singh, Central Circle, J-6A, Sector-23, Ghaziabad Sanjay Nagar, Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Yogender Singh, Vs. Dcit, J-6A, Sector-23, Central Circle, Sanjay Nagar, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Naveen Tyagi, Vs. Dcit, G-302, Vvip Central Circle, Addresses, Raj Nagar Ghaziabad Extention, Ghaziabad (Appellant) (Respondent) Pan:Admpt6420A Sarika Tyagi, Vs. Dcit, H-100, Patel Nagar,- Central Circle, 3, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Afapt5986P Assessee By : Shri Rajeev Khandelwal, Ca Shri Gagan Khandelwal, Adv Shri Jaind Jaiswal, Adv Revenue By: Ms. Sapna Bhatia, Cit Dr Date Of Hearing 23/08/2024 Date Of Pronouncement /10/2024

For Appellant: Shri Rajeev Khandelwal, CAFor Respondent: Ms. Sapna Bhatia, CIT DR
Section 132Section 143(2)Section 68

…searched as part of VVIP group along with premises of Shri Praveen Tyagi and the premises of VVIP Ltd, has no substance. We have also found that the ld DR has relied on the decision of the Hon'ble Supreme Court in the case of CIT Vs. S Ajit Kumar reported in 404 ITR 526 (SC) wherein, it was held that any material or evidence found/ collected in a survey which has been simultaneously made at premises of connected person can be utilized while making block assessment in respect of an assessee u/s 158BB read with section 158BH of the Act as it would fall under words “and such other materials or information as are av…

NAVEEN TYAGI,GHAZIABAD vs. DCIT, CENTRAL CIRCLE , GHAZIABAD

Accordingly, Ground No. 2 raised by the revenue is dismissed

ITA 1412/DEL/2022[2016-17]Status: DisposedITAT Delhi10 Oct 2024AY 2016-17

Bench: Shri M. Balaganesh & Shri Vimal Kumardcit, Vs. Sushil Tyagi, Central Circle, A-2, Ganpati Ghaziabad Apartments, Civil Lines, New Delhi (Appellant) (Respondent) Pan:Aejpt6739A Dcit, Vs. Yogender Singh, Central Circle, J-6A, Sector-23, Ghaziabad Sanjay Nagar, Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Yogender Singh, Vs. Dcit, J-6A, Sector-23, Central Circle, Sanjay Nagar, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Naveen Tyagi, Vs. Dcit, G-302, Vvip Central Circle, Addresses, Raj Nagar Ghaziabad Extention, Ghaziabad (Appellant) (Respondent) Pan:Admpt6420A Sarika Tyagi, Vs. Dcit, H-100, Patel Nagar,- Central Circle, 3, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Afapt5986P Assessee By : Shri Rajeev Khandelwal, Ca Shri Gagan Khandelwal, Adv Shri Jaind Jaiswal, Adv Revenue By: Ms. Sapna Bhatia, Cit Dr Date Of Hearing 23/08/2024 Date Of Pronouncement /10/2024

For Appellant: Shri Rajeev Khandelwal, CAFor Respondent: Ms. Sapna Bhatia, CIT DR
Section 132Section 143(2)Section 68

…searched as part of VVIP group along with premises of Shri Praveen Tyagi and the premises of VVIP Ltd, has no substance. We have also found that the ld DR has relied on the decision of the Hon'ble Supreme Court in the case of CIT Vs. S Ajit Kumar reported in 404 ITR 526 (SC) wherein, it was held that any material or evidence found/ collected in a survey which has been simultaneously made at premises of connected person can be utilized while making block assessment in respect of an assessee u/s 158BB read with section 158BH of the Act as it would fall under words “and such other materials or information as are av…

DCIT CENTRAL CIRCLE , GHAZIABAD vs. YOGENDER SINGH , GHAZIABAD

Accordingly, Ground No. 2 raised by the revenue is dismissed

ITA 1387/DEL/2022[2017-18]Status: DisposedITAT Delhi10 Oct 2024AY 2017-18

Bench: Shri M. Balaganesh & Shri Vimal Kumardcit, Vs. Sushil Tyagi, Central Circle, A-2, Ganpati Ghaziabad Apartments, Civil Lines, New Delhi (Appellant) (Respondent) Pan:Aejpt6739A Dcit, Vs. Yogender Singh, Central Circle, J-6A, Sector-23, Ghaziabad Sanjay Nagar, Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Yogender Singh, Vs. Dcit, J-6A, Sector-23, Central Circle, Sanjay Nagar, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Naveen Tyagi, Vs. Dcit, G-302, Vvip Central Circle, Addresses, Raj Nagar Ghaziabad Extention, Ghaziabad (Appellant) (Respondent) Pan:Admpt6420A Sarika Tyagi, Vs. Dcit, H-100, Patel Nagar,- Central Circle, 3, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Afapt5986P Assessee By : Shri Rajeev Khandelwal, Ca Shri Gagan Khandelwal, Adv Shri Jaind Jaiswal, Adv Revenue By: Ms. Sapna Bhatia, Cit Dr Date Of Hearing 23/08/2024 Date Of Pronouncement /10/2024

For Appellant: Shri Rajeev Khandelwal, CAFor Respondent: Ms. Sapna Bhatia, CIT DR
Section 132Section 143(2)Section 68

…searched as part of VVIP group along with premises of Shri Praveen Tyagi and the premises of VVIP Ltd, has no substance. We have also found that the ld DR has relied on the decision of the Hon'ble Supreme Court in the case of CIT Vs. S Ajit Kumar reported in 404 ITR 526 (SC) wherein, it was held that any material or evidence found/ collected in a survey which has been simultaneously made at premises of connected person can be utilized while making block assessment in respect of an assessee u/s 158BB read with section 158BH of the Act as it would fall under words “and such other materials or information as are av…

DCIT, CENTRAL CIRCLE, GHAZIABAD vs. SUSHIL TYAGI, DELHI

Accordingly, Ground No. 2 raised by the revenue is dismissed

ITA 1386/DEL/2022[2011-12]Status: DisposedITAT Delhi10 Oct 2024AY 2011-12

Bench: Shri M. Balaganesh & Shri Vimal Kumardcit, Vs. Sushil Tyagi, Central Circle, A-2, Ganpati Ghaziabad Apartments, Civil Lines, New Delhi (Appellant) (Respondent) Pan:Aejpt6739A Dcit, Vs. Yogender Singh, Central Circle, J-6A, Sector-23, Ghaziabad Sanjay Nagar, Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Yogender Singh, Vs. Dcit, J-6A, Sector-23, Central Circle, Sanjay Nagar, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Naveen Tyagi, Vs. Dcit, G-302, Vvip Central Circle, Addresses, Raj Nagar Ghaziabad Extention, Ghaziabad (Appellant) (Respondent) Pan:Admpt6420A Sarika Tyagi, Vs. Dcit, H-100, Patel Nagar,- Central Circle, 3, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Afapt5986P Assessee By : Shri Rajeev Khandelwal, Ca Shri Gagan Khandelwal, Adv Shri Jaind Jaiswal, Adv Revenue By: Ms. Sapna Bhatia, Cit Dr Date Of Hearing 23/08/2024 Date Of Pronouncement /10/2024

For Appellant: Shri Rajeev Khandelwal, CAFor Respondent: Ms. Sapna Bhatia, CIT DR
Section 132Section 143(2)Section 68

…searched as part of VVIP group along with premises of Shri Praveen Tyagi and the premises of VVIP Ltd, has no substance. We have also found that the ld DR has relied on the decision of the Hon'ble Supreme Court in the case of CIT Vs. S Ajit Kumar reported in 404 ITR 526 (SC) wherein, it was held that any material or evidence found/ collected in a survey which has been simultaneously made at premises of connected person can be utilized while making block assessment in respect of an assessee u/s 158BB read with section 158BH of the Act as it would fall under words “and such other materials or information as are av…

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED, HYDERABAD

ITA 1717/HYD/2017[2009-10]Status: HeardITAT Hyderabad07 Oct 2024AY 2009-10

Bench: Justice (Retd.) C.V. Bhadang, Shri Mahavir Singh & Shri G. Manjunatha

For Appellant: Shri K.K. ChaitanyaFor Respondent: Smt. Mamata Choudhary
Section 132Section 139(1)Section 143(3)Section 147Section 153ASection 80I

…ng is expressly made. Section 158BH also makes provisions relating to the computation of income applicable to the undisclosed income for the block period as held in the following decisions : :13: ITA Nos. 1717 to 1720/Hyd/2017 &  CIT v. S. Ajit Kumar [2018] 404 ITR 526  Fenoplast Ltd. Vs. ACIT [2014] 367 ITR 761 (Andhra Pradesh and Telangana)  S. Badrinarayan Kala Vs. ACIT [2005] 96 TTJ 642 (Chennai) 12. The learned counsel for the assessee further referred to the decision of the Hon’ble Supreme Court in the case of PCIT Vs. Abhisar Buildwell (P) Ltd. (supra). He, drew our attention to para. 11 of the judgme…

DCIT,CC-2(4), CHENNAI vs. V.BASKARAN, CHENNAI

In the result, the appeal filed by the assessee in IT(SS)A No

ITA 604/CHNY/2021[2017-18]Status: DisposedITAT Chennai20 Sept 2024AY 2017-18

Bench: Shri Mahavir Singhand Shri S.R. Raghunatha

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri A.P. Srinivas, Sr. Standing Counsel
Section 132Section 142(1)Section 143(3)Section 144Section 158B

…f the assessee is not covered by the above Rule 112F and therefore, notice for all the six years have been validly initiated and served. The ld. CIT DR also relied on the decision of Hon’ble Supreme Court in the case of CIT vs. S.Ajit Kumar reported in [2018] 404 ITR 526(SC). 33. On the other hand, the ld.counsel for the assessee relied on the order of CIT(A). 34. We have heard rival contentions and gone through facts and circumstances of the case. We noted that search and seizure operation was conducted by the Department u/s.132 of the Act on 09.11.2017 in the group case of Shri V. Dhivaharan, uncle of the ass…

BIJENDER SINGH LOHIA,NEW DELHI vs. JCIT (OSD), CENTRAL CIRCLE-26, NEW DELHI

The appeals are allowed

ITA 1529/DEL/2022[2016-17]Status: DisposedITAT Delhi16 Apr 2024AY 2016-17

Bench: Shri M. Balaganesh & Shri Anubhav Sharma

For Appellant: Shri Gaurav Jain, Advocate &For Respondent: Ms Sunita Verma, CIT, DR
Section 132Section 132(1)Section 143(1)Section 143(2)Section 153ASection 153DSection 2(24)(iv)Section 69C

…528 & 1529/Del/2022 the case of Dr. Mansukh Kanjibhai Shah Vs. ACIT: 129 ITD 376 (Ahd.), for the same proposition of law. 13. In the submissions filed, the Ld. AR has specifically distinguished the judgement of Hon’ble Supreme Court in CIT Vs S. Ajit Kumar; 404 ITR 526, as relied by Ld CIT(A) for the following reasons: i) No incriminating material was found from the premises of the assessee; ii) The scope of the aforesaid decision was restricted to the interpretation of erstwhile scheme of search assessment contained in section 158BB r.w.s 158BC of the Act which is different from the scheme of assessment u/s 15…

BIJENDER SINGH LOHIA,NEW DELHI vs. JCIT (OSD), CENTRAL CIRCLE-26, NEW DELHI

The appeals are allowed

ITA 1528/DEL/2022[2015-16]Status: DisposedITAT Delhi16 Apr 2024AY 2015-16

Bench: Shri M. Balaganesh & Shri Anubhav Sharma

For Appellant: Shri Gaurav Jain, Advocate &For Respondent: Ms Sunita Verma, CIT, DR
Section 132Section 132(1)Section 143(1)Section 143(2)Section 153ASection 153DSection 2(24)(iv)Section 69C

…528 & 1529/Del/2022 the case of Dr. Mansukh Kanjibhai Shah Vs. ACIT: 129 ITD 376 (Ahd.), for the same proposition of law. 13. In the submissions filed, the Ld. AR has specifically distinguished the judgement of Hon’ble Supreme Court in CIT Vs S. Ajit Kumar; 404 ITR 526, as relied by Ld CIT(A) for the following reasons: i) No incriminating material was found from the premises of the assessee; ii) The scope of the aforesaid decision was restricted to the interpretation of erstwhile scheme of search assessment contained in section 158BB r.w.s 158BC of the Act which is different from the scheme of assessment u/s 15…

ACIT CENTRAL CIRCLE, PANIPAT vs. KUNDAN RICE MILLS LTD., PANIPAT

In the result, assessee’s appeals are allowed, whereas,

ITA 5176/DEL/2019[2009-10]Status: DisposedITAT Delhi16 May 2023AY 2009-10

Bench: Shri Saktijit Dey & Shri M. Balaganesh

Section 132Section 133(6)Section 139(1)Section 143(1)Section 143(3)Section 153A

…stitute incriminating material. Therefore, the Assessing Officer was justified in making the additions on account of bogus sales. In support of such contention, she relied upon a decision of the Hon’ble Supreme Court in case of CIT Vs. S. Ajit Kumar, [2018] 404 ITR 526. 11. As regards the merits of the addition, learned Departmental Representative submitted, the assessee failed to furnish any evidence to establish on record that the transactions with M/s. Dee Kay Trade Centre and M/s. J.S. Enterprises are genuine. She submitted, the inquiry conducted by the Assessing Officer clearly revealed that both the a…

ACIT CENTRAL CIRCLE, PANIPAT vs. KUNDAN RICE MILLS LTD., PANIPAT

In the result, assessee’s appeals are allowed, whereas,

ITA 5175/DEL/2019[2008-09]Status: DisposedITAT Delhi16 May 2023AY 2008-09

Bench: Shri Saktijit Dey & Shri M. Balaganesh

Section 132Section 133(6)Section 139(1)Section 143(1)Section 143(3)Section 153A

…stitute incriminating material. Therefore, the Assessing Officer was justified in making the additions on account of bogus sales. In support of such contention, she relied upon a decision of the Hon’ble Supreme Court in case of CIT Vs. S. Ajit Kumar, [2018] 404 ITR 526. 11. As regards the merits of the addition, learned Departmental Representative submitted, the assessee failed to furnish any evidence to establish on record that the transactions with M/s. Dee Kay Trade Centre and M/s. J.S. Enterprises are genuine. She submitted, the inquiry conducted by the Assessing Officer clearly revealed that both the a…

ACIT CENTRAL CIRCLE, PANIPAT vs. KUNDAN RICE MILLS LTD., PANIPAT

In the result, assessee’s appeals are allowed, whereas,

ITA 5174/DEL/2019[2007-08]Status: DisposedITAT Delhi16 May 2023AY 2007-08

Bench: Shri Saktijit Dey & Shri M. Balaganesh

Section 132Section 133(6)Section 139(1)Section 143(1)Section 143(3)Section 153A

…stitute incriminating material. Therefore, the Assessing Officer was justified in making the additions on account of bogus sales. In support of such contention, she relied upon a decision of the Hon’ble Supreme Court in case of CIT Vs. S. Ajit Kumar, [2018] 404 ITR 526. 11. As regards the merits of the addition, learned Departmental Representative submitted, the assessee failed to furnish any evidence to establish on record that the transactions with M/s. Dee Kay Trade Centre and M/s. J.S. Enterprises are genuine. She submitted, the inquiry conducted by the Assessing Officer clearly revealed that both the a…

ACIT CENTRAL CIRCLE, PANIPAT vs. KUNDAN RICE MILLS LTD., PANIPAT

In the result, assessee’s appeals are allowed, whereas,

ITA 5173/DEL/2019[2006-07]Status: DisposedITAT Delhi16 May 2023AY 2006-07

Bench: Shri Saktijit Dey & Shri M. Balaganesh

Section 132Section 133(6)Section 139(1)Section 143(1)Section 143(3)Section 153A

…stitute incriminating material. Therefore, the Assessing Officer was justified in making the additions on account of bogus sales. In support of such contention, she relied upon a decision of the Hon’ble Supreme Court in case of CIT Vs. S. Ajit Kumar, [2018] 404 ITR 526. 11. As regards the merits of the addition, learned Departmental Representative submitted, the assessee failed to furnish any evidence to establish on record that the transactions with M/s. Dee Kay Trade Centre and M/s. J.S. Enterprises are genuine. She submitted, the inquiry conducted by the Assessing Officer clearly revealed that both the a…

ACIT CENTRAL CIRCLE, PANIPAT vs. KUNDAN RICE MILLS LTD., PANIPAT

In the result, assessee’s appeals are allowed, whereas,

ITA 5172/DEL/2019[2005-06]Status: DisposedITAT Delhi16 May 2023AY 2005-06

Bench: Shri Saktijit Dey & Shri M. Balaganesh

Section 132Section 133(6)Section 139(1)Section 143(1)Section 143(3)Section 153A

…stitute incriminating material. Therefore, the Assessing Officer was justified in making the additions on account of bogus sales. In support of such contention, she relied upon a decision of the Hon’ble Supreme Court in case of CIT Vs. S. Ajit Kumar, [2018] 404 ITR 526. 11. As regards the merits of the addition, learned Departmental Representative submitted, the assessee failed to furnish any evidence to establish on record that the transactions with M/s. Dee Kay Trade Centre and M/s. J.S. Enterprises are genuine. She submitted, the inquiry conducted by the Assessing Officer clearly revealed that both the a…

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