CIT v. Sunbeam Auto Ltd.

332 ITR 167High Court2011#54 most cited

What is CIT v. Sunbeam Auto Ltd. authority for?

The Commissioner cannot revise an assessment under Section 263 merely because the assessment order does not explicitly reflect an inquiry, or because the Commissioner holds a different opinion. An inquiry, even if considered inadequate, or an assessment based on a plausible view by the Assessing Officer after due examination, does not automatically make the order erroneous or prejudicial to the interests of the revenue.

897

judgments rely on this decision, according to BharatTax’s citation analysis of 367,514 Indian tax judgments — from 2011 to 2026.

Also referred to as

CIT v. Sunbeam Auto Ltd. · Sunbeam Auto Ltd. · Section 263 · Commissioner revisionary powers · lack of enquiry · inadequate enquiry · plausible view AO · not prejudicial to revenue · assessment order detail · different opinion Commissioner · 143(3) scrutiny assessment

Also reported as

189 Taxmann 436227 CTR 13331 DTR 189 Taxmann.com 191

Sections most often in play

Section 263Section 143(3)Section 142(1)Section 57(iv)Section 56(2)(viii)Section 10(37)Section 143(2)Section 147
Read the full judgment

Issues it is cited on

section 145bsection 45(5)section 145a(b)section 57(iv)inadequate enquirysection 56(2)(viii)lack of enquirysection 10(37)enhanced compensationmalabar industrialsection 263(1)section 145a

Judgments citing CIT v. Sunbeam Auto Ltd.

Raghav Bahl, Delhi vs. Deputy Commissioner of Income Tax, Central Circle- 1, Noida

In the result, the captioned appeals filed by the assessees are allowed

ITA 1823/DEL/2024[2014-15]Status: DisposedITAT Delhi20 Jun 2025AY 2014-15

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2013-14 A.Y. 2014-15 A.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2019-20 A.Y. 2018-19

Section 24Section 263Section 263(1)

…n taken by the AO in the assessment order the same cannot be held to be prejudicial to the interests of Revenue. In support of his contention Ld. AR relied upon the decision of the Hon’ble Delhi High Court in the case of CIT v. Sunbeam Auto Pvt. Ltd. [2011] 332 ITR 167 (Del.), which has been duly considered by us and found to be applicable in the case in hand having regard to the facts and circumstances of the case. Thus, when the claims of the assessee have been duly examined during original assessment proceedings and also the reassessment proceedings under Section 153A of the Act itself, there could have be…

Raghav Bahl, Delhi vs. Deputy Commissioner of Income Tax, Central Circle- 1, Noida

In the result, the captioned appeals filed by the assessees are allowed

ITA 1822/DEL/2024[2013-14]Status: DisposedITAT Delhi20 Jun 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2013-14 A.Y. 2014-15 A.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2019-20 A.Y. 2018-19

Section 24Section 263Section 263(1)

…n taken by the AO in the assessment order the same cannot be held to be prejudicial to the interests of Revenue. In support of his contention Ld. AR relied upon the decision of the Hon’ble Delhi High Court in the case of CIT v. Sunbeam Auto Pvt. Ltd. [2011] 332 ITR 167 (Del.), which has been duly considered by us and found to be applicable in the case in hand having regard to the facts and circumstances of the case. Thus, when the claims of the assessee have been duly examined during original assessment proceedings and also the reassessment proceedings under Section 153A of the Act itself, there could have be…

M/S. Imagicaaworld Entertainment Limited, Mumbai vs. Principal Commissioner of Income Tax - 8, Mumbai

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 2175/MUM/2025[2021-22]Status: DisposedITAT Mumbai16 Jun 2025AY 2021-22

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2021-22 M/S Imagicaa World Pr. Cit-8, Entertainment Ltd., Room No. 611, 6Th Floor, Aayakar Admin Building, Mumbai Pune Vs. Bhavan, Maharishi Karve Road, Express Road, Sangadewadi, Mumbai-400020. Raigarh-410203. Pan No. Aaica 2573 P Appellant Respondent Assessee By : Mr. Madhur Agrawal & Mr. Mahesh Rajora Revenue By : Mr. R.A. Dhyani, Cit-Dr

For Appellant: Mr. Madhur Agrawal &For Respondent: Mr. R.A. Dhyani, CIT-DR
Section 143(3)Section 144BSection 263

…re is not claimed and does not impact the computation of income for the year under assessment, the absence of inquiry cannot ipso facto render the assessment erroneous or prejudicial. As held by the Hon‘ble Delhi High Court in CIT v. Sunbeam Auto Ltd. [(2011) 332 ITR 167 (Del)], an assessment order cannot be revised under Section 263 merely because it is not elaborate in its reasoning, if the Assessing Officer has applied his mind to the issue at hand. 5. In light of the above analysis, we are of the considered view that the conditions precedent for invoking jurisdiction under Section M/s Imagicaa World Entertai…

Alliance Nirmaan Limited, Bareilly vs. PCIT, Bareilly

In the result, the appeal of the assessee is allowed

ITA 119/LKW/2022[2017-18]Status: DisposedITAT Lucknow12 Jun 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(3)Section 263

…trial Co. Ltd. [2000] 243 ITR 83 (SC) 2. CIT vs. Gabriel India Ltd. [1993] 203 ITR 108 (Bombay) 3. CIT vs. Land Infrastructure Development Projects Ltd. [2013] 357 ITR 763 (Mad) 4. CIT vs. MAX India Limited [2007] 295 ITR 282 (SC) 5. CIT vs. Sunbeam Auto Ltd. 332 ITR 167 (Del) 6. Income Tax Officer vs. Dg. Housing Projects Ltd., I.T.A. No.179/2011-HC of Delhi -date of order 01/03/2012 343 ITR 329 (Del) 7. CIT vs. Vikas Polymers [2010] 194 Taxman 57 (Delhi High Court) 8. Haryana Coach Body Builders [2006] 10 SOT 736 (Delhi) 9. CIT vs. Mohd. Ishaq Mohd. Gulam 276 ITR 13 (MP) 10. CIT vs. Ganpat Ram Bishnoi 152 Taxma…

Paras Rameshchandra Doshi, Rajkot vs. The PCIT - 1, Rajkot

ITA 280/RJT/2024[2013-14]Status: DisposedITAT Rajkot11 Jun 2025AY 2013-14
Section 115BSection 132Section 133ASection 139(1)Section 143(2)Section 147Section 148Section 263Section 69A

…IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER AND SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER आयकर अपीलसं./ITA No. 280/RJT/2024 (निर्धारणवर्ष / Assessment Year: (2013-14) (Hybrid Hearing) Vs. The Pr. CIT – 1, Aayakar Bhavan, Race Course Ring Road, Rajkot - 360001 Paras Rameshchandra Doshi Prop. Aadhyashakti Trading, Pal Gate Road, Soni Bazar, Rajkot - 360001 (Appellant) स्थायी लेखासं./जीआइआरसं./PAN/GIR No.: ABJPD0346E (Respondent) Appellant by Respondent by Date of Hearing Date of Pronouncement : Shri D. M. Rindani, Ld. AR : Shri Sanjay Punglia, Ld. CIT (DR)…

Satishbhai Mohanbhai Zalavadia, Na vs. Ari, Vs.the Principal Commissioner of Income Tax, Rajkot-1, Rajkot

In the result, the appeal filed by the assessee is allowed

ITA 122/RJT/2022[2017-18]Status: DisposedITAT Rajkot10 Jun 2025AY 2017-18

Bench: Dr. A.L. Saini, Am & Shri Dinesh Mohan Sinha, Jm आयकर अपील सं./Ita No.122/Rjt/2022 ("नधा"रण वष" / Assessment Year: (2017-18) (Physical He Aring) Satishbhai Mohanbhai Zalavadia, The Pr. Cit – 1, Vs. 2622, Sarvoday Park, Khundh Rajkot Khundh, Chikhli, Navsari - 396521 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acnpp0527F (Appellant) (Respondent) Appellant By : Shri Rajendra Singhal, Ar Respondent By : Shri Shramdeep Sinha, Cit-Dr Date Of Hearing : Heard On 23/07/2024 & Refix For Clarification On 24.04.2025

For Appellant: Shri Rajendra Singhal, ARFor Respondent: Shri Shramdeep Sinha, CIT-DR
Section 143(2)Section 143(3)Section 263

…There is difference between ‘Lack of enquiry’ and ‘inadequate enquiry’. It is for the AO to decide the extent of enquiry to be made as it is his satisfaction as what is required under law. Reliance is placed on the decision of CIT v. Sunbeam Auto Ltd. [(2010) 332 ITR 167], wherein Hon’ble Delhi High Court has held that if there was any inquiry, even inadequate, that would not by itself, give occasion to the Commissioner to pass order u/s 263 of the Act, merely because the Commissioner has a different opinion in the matter and that only in cases where there is no enquiry, the power u/s 263 of the Act can be exerci…

Micromax Informatics Ltd, New Delhi vs. PCIT, Delhi

In the result, the appeal of the assessee is allowed

ITA 2524/DEL/2024[2018-19]Status: DisposedITAT Delhi06 Jun 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 142(1)Section 143(3)Section 147Section 14ASection 263

…s of facts arrived at by the Tribunal do not warrant interference of this court. That being the position, the present case would not be one of "lack of inquiry" and, even if the inquiry was termed inadequate, following the decision in Sunbeam Auto Ltd. (2011) 332 ITR 167 (Delhi) (page 180) : "that would not by itself give occasion to the Commissioner to pass orders under section 263 of the Act, merely because he has a different opinion in the matter." No substantial question of law arises for our consideration." 24. In Ashish Rajpal as well, this Court was of the view that the fact that a query was raised during…

The Pr. Commissioner of Income-Tax vs. M/S. Te Connectivity India Pvt. Ltd

Accordingly dispose of the appeal as allowed

ITA/53/2024HC Karnataka05 Jun 2025

Bench: ACTING CHIEF JUSTICE,S RACHAIAH

Section 143(2)Section 143(3)Section 144C(13)Section 260ASection 263Section 40

…aim of the assessee. The relevant finding of the Hon'ble High Court reads as follows: "8. In the backdrop of aforesaid well settled legal principles, we may examine the facts of the case in hand. In CIT v. Sunbeam Auto Ltd. [20101 189 Taxman 436/12011] 332 ITR 167 (Delhi) it has been held by Delhi High Court that Assessing Officer in the order of assessment is not required to give detailed reasoning in respect of each and every item of deduction and therefore, the question whether there has been an application of mind before allowing expenditure has to be examined from the record of the case. The q…

Bharatkumar Ranchodbhai Soni, Na vs. Arivs.PCIT, Valsad

ITA 505/SRT/2024[2017-18]Status: DisposedITAT Surat05 Jun 2025AY 2017-18
Section 143(3)Section 2Section 263

…s made by AO, which has been considered to be inadequate by the Id. PCIT, the same cannot make the order of AO erroneous. The assessee had also relied on the decisions in case of Malabar Industrial Co. Ltd. vs. CIT, 243 ITR 83 (SC), CIT vs. Sunbeam Auto Ltd., 332 ITR 167 (Del), CIT vs. Gabriel India Ltd., 203 ITR 108 (Bom) and a plethora of decisions where the Hon'ble Courts have allowed relief to the assessee on similar facts. Accordingly, it was requested not to invoke provisions of section 263 of the Act. 4. The Id. PCIT considered the submission of the assessee and held that the order passed by the AO on 30.1…

Income Tax Officer, Panipat vs. Dinesh Kaushik, Panipat

In the result, appeal of the assessee is allowed

ITA 5753/DEL/2024[2018-19]Status: DisposedITAT Delhi05 Jun 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2018-19 Vs. Sh. Dinesh Kaushik, Income Tax Officer, Panipat Vpo Baljattan, Panipat, Haryana Pan: Awjpk9483E (Appellant) (Respondent) Assessee By None Department By Sh. Rajesh Kumar Dhanesta, Sr. Dr

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 145BSection 263Section 28Section 45(5)

…ely because in his order the Ld. AO did not make elaborate discussion but was satisfied with the explanation of the assessee, the order could not be held to be erroneous. In support the decisions of Hon'ble Delhi High Court in CIT vs. Sunbeam Auto Ltd. (2011) 332 ITR 167 (Del) and decision of Hon'ble Rajasthan High Court in CIT vs. Ganpat Ram Bisnoi 296 ITR 292 (Raj.) were cited. 6.2 The Ld. AR invited our attention to Audit Memo at pages 399-402 of Paper Book in the case of the assessee wherein ITO (Audit) Hisar raised an audit objection observing that interest under section 28 of Land Acquisition Act of Rs. 3,9…

Actionware India Private Limited, Rajkot vs. The PCIT-1, Rajkot

In the result, the appeal of the assessee is allowed

ITA 317/RJT/2024[2014-15]Status: DisposedITAT Rajkot02 Jun 2025AY 2014-15

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.317/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2014-15 Actionware India Pvt. Ltd. The Pr.Cit-1 बनाम 316, Sagar Arcade Rajkot. Gandal Road Vs. Opp: Union Bank Of India Rajkot 360 002 (Gujarat) Pan : Aacck 3445 Q (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri D.M. Rindani, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

For Appellant: Shri D.M. Rindani, ld.ARFor Respondent: Shri Sanjay Punglia, ld.CIT-DR
Section 115BSection 132Section 132(4)Section 147Section 263Section 68

…Rajkot Trib) held that there is no law which provides the extent of inquiries to be made by the assessing officer. We also derive support for our conclusions, as above, from the decision of the Hon'ble Delhi High Court in the case of CIT Vs. Sunbeam Auto Ltd. 332 ITR 167 (Del.). 18. For reasons stated above, we are of the view that the jurisdiction u/s.263 of the Act was not properly exercised by the ld. PCIT, as the condition precedent for invoking the same viz., that the order of the assessing officer is erroneous and prejudicial to the interest of the revenue, is not shown to be present in the assessee`s case…

Jile Singh, Faridabad vs. Income Tax Officer, Faridabad

In the result, appeal of the assessee is allowed

ITA 2223/DEL/2025[2017-18]Status: DisposedITAT Delhi02 Jun 2025AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 2223/Del/2025 : Asstt. Year : 2017-18 Jile Singh, Vs Income Tax Officer, H. No. 68, Sotai, Near Mahipal Ward-51(3), Nambardar, Ballabgarh, Faridabad, Faridabad, Haryana-121002 Haryana-121004 (Appellant) (Respondent) Pan No. Fzsps8684G Assessee By: None Revenue By : Sh. Akhilesh Kumar Yadav, Sr. Dr Date Of Hearing: 02.06.2025 Date Of Pronouncement: 02.06.2025 Order

For Appellant: NoneFor Respondent: Sh. Akhilesh Kumar Yadav, Sr. DR
Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 263Section 28Section 56(2)(viii)

…ely because in his order the Ld. AO did not make elaborate discussion but was satisfied with the explanation of the assessee, the order could not be held to be erroneous. In support the decisions of Hon'ble Delhi High Court in CIT vs. Sunbeam Auto Ltd. (2011) 332 ITR 167 (Del) and decision of Hon'ble Rajasthan High Court in CIT vs. Ganpat Ram Bisnoi 296 ITR 292 (Raj.) were cited. 4 Jile Singh 6.2 The Ld. AR invited our attention to Audit Memo at pages 399-402 of Paper Book in the case of the assessee wherein ITO (Audit) Hisar raised an audit objection observing that interest under section 28 of Land Acquisition…

Devprabha Construction Private Ltd., Dhanbad vs. PCIT, Dhanbad

In the result, this appeal of the assessee is allowed

ITA 27/RAN/2024[2018-19]Status: DisposedITAT Ranchi30 May 2025AY 2018-19

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay(Virtual Hearing) Devprabha Construction Private Ltd., P.C.I.T., Dev Villa, Behind Radha Swamy Arcade, Dhanbad, Vs. Saraidhela, Dhanbad-828127. Aayakar Bhawan, Luby Pan No. Aaecb 2652 A Circular Road, Dhanbad-826001 (Jharkhand) Appellant/ Assessee Respondent/ Revenue

Section 133(6)Section 143(3)Section 263

…he order passed by the Commissioner is not sustainable in law and the same has rightly been set aside by the Tribunal. [Para 8] (Copy of the order is attached at Page 29-31. Commissioner of Income-tax vs. Sunbeam Auto Ltd. [2010] 189 Taxman 436 (Delhi)/[2011] 332 ITR 167 (Delhi)/[2009] 227 CTR 133 (Delhi)[11-09-2009] The submission of the revenue was that while passing the assessment order, the Assessing Officer did not consider the aspect specifically whether the expenditure in question was revenue or capital expenditure. That argument predicated on the assessment order, which apparently did not give any reason…

Sanakari, Village Bhooda Noida vs. Ward 3(4) Sector 24 Noida, Noida

In the result, appeal of the assessee is allowed

ITA 1533/DEL/2025[2015-16]Status: DisposedITAT Delhi29 May 2025AY 2015-16

Bench: Sh. Satbeer Singh Godaraita No. 1533/Del/2025 : Asstt. Year : 2015-16 Sanakari, Vs Income Tax Officer, H. No. 18, Village Bhooda, Noida, Ward-3(4), District Gautam Budh Nagar, Noida, Uttar Pradesh-201301 Uttar Pradesh-201301 (Appellant) (Respondent) Pan No. Etcps4927M Assessee By : Sh. Pawan Sharma, Ca Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 29.05.2025 Date Of Pronouncement: 29.05.2025 Order

For Appellant: Sh. Pawan Sharma, CAFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 263Section 28Section 56(2)(viii)

…ely because in his order the Ld. AO did not make elaborate discussion but was satisfied with the explanation of the assessee, the order could not be held to be erroneous. In support the decisions of Hon'ble Delhi High Court in CIT vs. Sunbeam Auto Ltd. (2011) 332 ITR 167 (Del) and decision of Hon'ble Rajasthan High Court in CIT vs. Ganpat Ram Bisnoi 296 ITR 292 (Raj.) were cited. 6.2 The Ld. AR invited our attention to Audit Memo at pages 399-402 of Paper Book in the case of the assessee wherein ITO (Audit) Hisar raised an audit objection observing that interest under section 28 of Land Acquisition Act of Rs. 3,9…

Baljit Kaur, Ludhiana vs. DCIT, Karnal

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

ITA 4073/DEL/2024[2018-19]Status: DisposedITAT Delhi29 May 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri S Rifaur Rahmanिनधा"रणवष"/Assessment Year: 2018-19 बनाम Baljit Kaur, Pcit, 726, Sector-13, U.E., Karnal, Vs. Office Of The Principal Haryana. Commissioner Of Income Tax, Rohtak, Haryana. Pan No.Aippk7073E अपीलाथ" Appellant ""यथ"/Respondent & िनधा"रणवष"/Assessment Year: 2018-19 बनाम Baljit Kaur, Dcit, H.No.142-B, Model Town Vs. Aaykar Bhawan, Sector-12, Extension, Ludhiana, Karnal, Haryana. Punjab. Pan No.Aippk7073E अपीलाथ" Appellant ""यथ"/Respondent

Section 10(37)Section 142(1)Section 143(3)Section 263

…PCIT that it is a case of no enquiry' or ‘lack of enquiry'. No doubt that the Ld. AO did not discuss elaborately in the assessment order but that alone cannot make the order erroneous as held by the Hon 'ble Delhi High Court in CIT V. Sunbeam Auto Ltd. (2011) 332 ITR 167 (Del) and Hon'ble Raiasthan High Court in CIT vs. Ganpat Ram Bisnoi 296 ITR 292 (Raj.). An incorrect assumption of facts or an incorrect application of law will satisfy the requirement of the order being erroneous as held by the Hon'ble Supreme Court in Malabar Industrial Co. Ltd. Vs. CIT 243 ITR 83 (SC). None of these elements exist in the case…

Baljit Kaur, Karnal vs. Pr. CIT, Rohtak

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

ITA 1208/DEL/2023[2018-19]Status: DisposedITAT Delhi29 May 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri S Rifaur Rahmanिनधा"रणवष"/Assessment Year: 2018-19 बनाम Baljit Kaur, Pcit, 726, Sector-13, U.E., Karnal, Vs. Office Of The Principal Haryana. Commissioner Of Income Tax, Rohtak, Haryana. Pan No.Aippk7073E अपीलाथ" Appellant ""यथ"/Respondent & िनधा"रणवष"/Assessment Year: 2018-19 बनाम Baljit Kaur, Dcit, H.No.142-B, Model Town Vs. Aaykar Bhawan, Sector-12, Extension, Ludhiana, Karnal, Haryana. Punjab. Pan No.Aippk7073E अपीलाथ" Appellant ""यथ"/Respondent

Section 10(37)Section 142(1)Section 143(3)Section 263

…PCIT that it is a case of no enquiry' or ‘lack of enquiry'. No doubt that the Ld. AO did not discuss elaborately in the assessment order but that alone cannot make the order erroneous as held by the Hon 'ble Delhi High Court in CIT V. Sunbeam Auto Ltd. (2011) 332 ITR 167 (Del) and Hon'ble Raiasthan High Court in CIT vs. Ganpat Ram Bisnoi 296 ITR 292 (Raj.). An incorrect assumption of facts or an incorrect application of law will satisfy the requirement of the order being erroneous as held by the Hon'ble Supreme Court in Malabar Industrial Co. Ltd. Vs. CIT 243 ITR 83 (SC). None of these elements exist in the case…

Sukhbir Singh, Bahadurgarh, Haryana vs. Income Tax Officer Ward 68(5), Delhi

In the result, appeal of the assessee is allowed

ITA 313/DEL/2025[2018-19]Status: DisposedITAT Delhi28 May 2025AY 2018-19

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 781/Del/2024 : Asstt. Year : 2017-18 Devinder Kumar, Vs Pcit, 59, Gurjar Mohalla, Vpo Faridabad, Machhgarh, Ballabgarh, Haryana-121001 Faridabad-121004 (Appellant) (Respondent) Pan No. Djipk4264C

For Appellant: Sh. R. S. Poonia, CAFor Respondent: Ms. Pooja Swaroop, CIT-DR
Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(viii)Section 57

…ely because in his order the Ld. AO did not make elaborate discussion but was satisfied with the explanation of the assessee, the order could not be held to be erroneous. In support the decisions of Hon'ble Delhi High Court in CIT vs. Sunbeam Auto Ltd. (2011) 332 ITR 167 (Del) and decision of Hon'ble Rajasthan High Court in CIT vs. Ganpat Ram Bisnoi 296 ITR 292 (Raj.) were cited. 6.2 The Ld. AR invited our attention to Audit Memo at pages 399-402 of Paper Book in the case of the assessee wherein ITO (Audit) Hisar raised an audit objection observing that interest under section 28 of Land Acquisition Act of Rs. 3,9…

Vinod, Faridabad vs. PCIT, Faridabad

In the result, appeal of the assessee is allowed

ITA 786/DEL/2024[2017-18]Status: DisposedITAT Delhi28 May 2025AY 2017-18

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 781/Del/2024 : Asstt. Year : 2017-18 Devinder Kumar, Vs Pcit, 59, Gurjar Mohalla, Vpo Faridabad, Machhgarh, Ballabgarh, Haryana-121001 Faridabad-121004 (Appellant) (Respondent) Pan No. Djipk4264C

For Appellant: Sh. R. S. Poonia, CAFor Respondent: Ms. Pooja Swaroop, CIT-DR
Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(viii)Section 57

…ely because in his order the Ld. AO did not make elaborate discussion but was satisfied with the explanation of the assessee, the order could not be held to be erroneous. In support the decisions of Hon'ble Delhi High Court in CIT vs. Sunbeam Auto Ltd. (2011) 332 ITR 167 (Del) and decision of Hon'ble Rajasthan High Court in CIT vs. Ganpat Ram Bisnoi 296 ITR 292 (Raj.) were cited. 6.2 The Ld. AR invited our attention to Audit Memo at pages 399-402 of Paper Book in the case of the assessee wherein ITO (Audit) Hisar raised an audit objection observing that interest under section 28 of Land Acquisition Act of Rs. 3,9…

Devinder Kumar, Faridabad vs. Principal Commissioner, Faridabad

In the result, appeal of the assessee is allowed

ITA 781/DEL/2024[2017-18]Status: DisposedITAT Delhi28 May 2025AY 2017-18

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 781/Del/2024 : Asstt. Year : 2017-18 Devinder Kumar, Vs Pcit, 59, Gurjar Mohalla, Vpo Faridabad, Machhgarh, Ballabgarh, Haryana-121001 Faridabad-121004 (Appellant) (Respondent) Pan No. Djipk4264C

For Appellant: Sh. R. S. Poonia, CAFor Respondent: Ms. Pooja Swaroop, CIT-DR
Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(viii)Section 57

…ely because in his order the Ld. AO did not make elaborate discussion but was satisfied with the explanation of the assessee, the order could not be held to be erroneous. In support the decisions of Hon'ble Delhi High Court in CIT vs. Sunbeam Auto Ltd. (2011) 332 ITR 167 (Del) and decision of Hon'ble Rajasthan High Court in CIT vs. Ganpat Ram Bisnoi 296 ITR 292 (Raj.) were cited. 6.2 The Ld. AR invited our attention to Audit Memo at pages 399-402 of Paper Book in the case of the assessee wherein ITO (Audit) Hisar raised an audit objection observing that interest under section 28 of Land Acquisition Act of Rs. 3,9…

Kharak Singh, Noida vs. Income Tax Officer, Noida

In the result, appeal of the assessee is allowed

ITA 776/DEL/2025[2015-16]Status: HeardITAT Delhi26 May 2025AY 2015-16

Bench: Shri Satbeer Singh Godara

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 263Section 28Section 56(2)(viii)

…ely because in his order the Ld. AO did not make elaborate discussion but was satisfied with the explanation of the assessee, the order could not be held to be erroneous. In support the decisions of Hon'ble Delhi High Court in CIT vs. Sunbeam Auto Ltd. (2011) 332 ITR 167 (Del) and decision of Hon'ble Rajasthan High Court in CIT vs. Ganpat Ram Bisnoi 296 ITR 292 (Raj.) were cited. 6.2 The Ld. AR invited our attention to Audit Memo at pages 399-402 of Paper Book in the case of the assessee wherein ITO (Audit) Hisar raised an audit objection observing that interest under section 28 of Land Acquisition Act of Rs. 3,9…