Commissioner of Income Tax v. Ms. Sadhna Chadha

The Commissioner of Income Tax-VI vs. M/S. Uberoi Sons (Machines) Ltd

…cated past transactions. In the circumstances, the assessee could not take shelter under the fact that the arrears were disclosed in the later year. The revenue also relied on the judgment of this Court in Commissioner of Income Tax Vs. Ms. Sadhna Chadha, 270 ITR 534 as well as the judgment reported as B.M. Gupta & sons (HUF) vs ACIT (2008) 299 ITR 410 (Del). 2012:DHC:5352-DB ITAs 166, 168, 243, 778/2006 Page 5 7. Counsel for the assessee, Mr. Sethi, argued that the appeal is bereft of merit, and the ITAT's order does not call for interference. It was argued that having regard to the structure and…

Commissioner of Income Tax vs. M/S Uberoi Sons Machines Ltd

…cated past transactions. In the circumstances, the assessee could not take shelter under the fact that the arrears were disclosed in the later year. The revenue also relied on the judgment of this Court in Commissioner of Income Tax Vs. Ms. Sadhna Chadha, 270 ITR 534 as well as the judgment reported as B.M. Gupta & sons (HUF) vs ACIT (2008) 299 ITR 410 (Del). 2012:DHC:5352-DB ITAs 166, 168, 243, 778/2006 Page 5 7. Counsel for the assessee, Mr. Sethi, argued that the appeal is bereft of merit, and the ITAT's order does not call for interference. It was argued that having regard to the structure and…

The Commissioner of Income Tax -VI vs. M/S. Uberoi Sons (Machines) Ltd

…cated past transactions. In the circumstances, the assessee could not take shelter under the fact that the arrears were disclosed in the later year. The revenue also relied on the judgment of this Court in Commissioner of Income Tax Vs. Ms. Sadhna Chadha, 270 ITR 534 as well as the judgment reported as B.M. Gupta & sons (HUF) vs ACIT (2008) 299 ITR 410 (Del). 2012:DHC:5352-DB ITAs 166, 168, 243, 778/2006 Page 5 7. Counsel for the assessee, Mr. Sethi, argued that the appeal is bereft of merit, and the ITAT's order does not call for interference. It was argued that having regard to the structure and…

B.M.Gupta & Sons vs. ACIT

Appeals are hereby dismissed

Bench: HON'BLE MR. JUSTICE R.C. JAIN

…t was received after the end of the financial year relevant to the assessment year and the ITA No. 1184-91/2006 Page 2 of 5 appellant has relied upon a decision of our own High Court in the case of Commissioner of Income Tax Vs. Ms Sadhna Chadha, 270 ITR 534 as well as the decision of Calcutta High Court in the case of Hamilton & Co. Pvt. Ltd. Vs. CIT, 194 ITR 391. 5. The Commissioner of Income Tax as well as Income Tax Appellate Tribunal did not agree with the contentions of the Appellant and hence the present appeals. 6. The contention of learned counsel for the appellant is that the sum of a…