Friends Clearing Agency (P.) Ltd. v. Commissioner of Income

332 ITR 269High Court2011#2893 most cited

What is Friends Clearing Agency (P.) Ltd. v. Commissioner of Income authority for?

An ad-hoc disallowance of expenses is deleted where the Assessing Officer (AO) has not established or spelt out the specific expenses that were not vouched, especially when the assessee's accounts were duly audited. The reliance on the Friends Clearing Agency case supports this.

41

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2023.

Also referred to as

Friends Clearing Agency P. Ltd. v. CIT · 332 ITR 269 · expenses · disallowance · ad-hoc disallowance · vouched expenses · audited accounts · Assessing Officer

Issues it is cited on

circular tradingsection 40a(2)(a)corporate guaranteesurvey under section 133asection 80ibsection 2(24)(x)commercial expediencyprincipal officersection 35section 40a(2)(b)section 2(24)section 80i

Judgments citing Friends Clearing Agency (P.) Ltd. v. Commissioner of Income

ACIT CENTRAL-2, INDORE vs. SARTHAK INNOVATION (P) LTD., INDORE

ITA 230/IND/2021[2017-18]Status: DisposedITAT Indore30 Mar 2023AY 2017-18

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: 28.02.2023For Respondent: Shri P. K. Mishra, CIT.D.R
Section 127Section 142(1)Section 143(2)Section 143(3)Section 404(2)Section 40ASection 40A(2)Section 40A(2)(a)Section 40A(2)(b)

…. Ltd. Vs. ITO in ITA Nos. 8136, 8138 & 8137/Mum/2011. iii. Sanghi Brothers (India) P. Ltd. vs. Department of Income Tax in ITA No. 286/Ind/2011 iv. J. J. Enterprises vs. CIT, reported in 254 ITR 216 (SC) v. Friends Clearing Agency P. Ltd. v. CIT, reported in 332 ITR 269 16. Considering the entire aspect of the matter, the Ld. CIT(A) deleted the addition with the following observation: “4.2.1 I have considered the facts of the case, plea raised by the appellant and findings of the AO. On perusal of the profit and loss account filed by the appellant it is seen that the appellant has claimed cost of purchases only…

ACIT CENTRAL-2, INDORE vs. SARTHAK INNOVATION (P) LTD., INDORE

ITA 229/IND/2021[2014-15]Status: DisposedITAT Indore30 Mar 2023AY 2014-15

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: 28.02.2023For Respondent: Shri P. K. Mishra, CIT.D.R
Section 127Section 142(1)Section 143(2)Section 143(3)Section 404(2)Section 40ASection 40A(2)Section 40A(2)(a)Section 40A(2)(b)

…. Ltd. Vs. ITO in ITA Nos. 8136, 8138 & 8137/Mum/2011. iii. Sanghi Brothers (India) P. Ltd. vs. Department of Income Tax in ITA No. 286/Ind/2011 iv. J. J. Enterprises vs. CIT, reported in 254 ITR 216 (SC) v. Friends Clearing Agency P. Ltd. v. CIT, reported in 332 ITR 269 16. Considering the entire aspect of the matter, the Ld. CIT(A) deleted the addition with the following observation: “4.2.1 I have considered the facts of the case, plea raised by the appellant and findings of the AO. On perusal of the profit and loss account filed by the appellant it is seen that the appellant has claimed cost of purchases only…

DCIT CENTRAL-1, INDORE vs. SARTHAK INNOVATION (P) LTD., INDORE

ITA 228/IND/2021[2013-14]Status: DisposedITAT Indore30 Mar 2023AY 2013-14

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: 28.02.2023For Respondent: Shri P. K. Mishra, CIT.D.R
Section 127Section 142(1)Section 143(2)Section 143(3)Section 404(2)Section 40ASection 40A(2)Section 40A(2)(a)Section 40A(2)(b)

…. Ltd. Vs. ITO in ITA Nos. 8136, 8138 & 8137/Mum/2011. iii. Sanghi Brothers (India) P. Ltd. vs. Department of Income Tax in ITA No. 286/Ind/2011 iv. J. J. Enterprises vs. CIT, reported in 254 ITR 216 (SC) v. Friends Clearing Agency P. Ltd. v. CIT, reported in 332 ITR 269 16. Considering the entire aspect of the matter, the Ld. CIT(A) deleted the addition with the following observation: “4.2.1 I have considered the facts of the case, plea raised by the appellant and findings of the AO. On perusal of the profit and loss account filed by the appellant it is seen that the appellant has claimed cost of purchases only…

NAMTEL TECHNOLOGIES P LTD ,BHOPAL vs. ACIT(A) NFAC NEW DELHI, DELHI

In the result, this appeal of Assessee is partly allowed

ITA 162/IND/2021[2015-16]Status: DisposedITAT Indore16 Nov 2022AY 2015-16

Bench: Ms.Suchitra Kamble & Shrib.M. Biyani(Conducted Through Virtual Court) Assessment Year: 2015-16 Namtel Technologies (P) Dcit-3(1), Ltd., Bhopal बनाम/ Bhopal Vs. (Appellant / Assessee) (Respondent / Revenue) Pan: Aaccn6502F Assessee By Shri S.S.Solanki, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 24.08.2022 Date Of Pronouncement 16.11.2022

Section 143(3)Section 37(1)Section 40A(2)Section 40A(2)(b)

…आयकर अपील"य अ"धकरण, इंदौर "यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE MS.SUCHITRA KAMBLE, JUDICIAL MEMBER AND SHRIB.M. BIYANI, ACCOUNTANT MEMBER (Conducted through Virtual Court) Assessment Year: 2015-16 Namtel Technologies (P) DCIT-3(1), Ltd., Bhopal बनाम/ Bhopal Vs. (Appellant / Assessee) (Respondent / Revenue) PAN: AACCN6502F Assessee by Shri S.S.Solanki, AR Revenue by Shri Ashish Porwal, Sr. DR Date of Hearing 24.08.2022 Date of Pronouncement 16.11.2022 आदेश/ O R D E R Per B.M. Biyani, A.M.: Feeling aggrieved by appeal-order dated 15.07.2021 passed by Ld. Commissioner of…

ITO WARD-59(3), NEW DELHI vs. SARWAN JAIN, DELHI

In the result, the appeal of the Revenue is dismissed

ITA 9435/DEL/2019[2016-17]Status: DisposedITAT Delhi14 Oct 2022AY 2016-17

Bench: Sh. Anil Chaturvedi & Sh. Anubhav Sharmaito Vs. Sarwan Jain Ward – 59(3) B-92, Swasthya Vihar, New Delhi New Delhi – 110 092 Pan No. Aafpj 9540 H (Appellant) (Respondent) & Co No. 26/Del/2020 (Arising Out Of Ita No.9435/Del/2019) (Assessment Year : 2016-17) Sarwan Jain Vs. Ito B-92, Swasthya Vihar, Ward – 59(3) New Delhi – 110092 New Delhi Pan No. Aafpj 9540 H (Appellant) (Respondent)

Section 143(2)Section 144Section 41(1)

…or spelt out the expenses which were not vouched completely more so when the assessee’s account was duly audited. He, thereafter, by placing reliance on the decision rendered by Hon’ble Delhi High Court in the case of Friends Clearing Agency (P) Ltd. vs. CIT 332 ITR 269 deleted the ad-hoc disallowance of expenses. Aggrieved by the order of CIT(A), Revenue is now before us. 9. Before us, Learned DR supported the order of AO. 5 10. Learned AR on the other hand reiterated the submissions made before the AO and CIT(A) and further submitted that the CO filed by the assessee in his support of the order of CIT(A) and…

SARR FREIGHTS CORPORATION,NEW DELHI vs. DCIT CIRCLE 62(1), NEW DELHI

The appeal is allowed and the Impugned additions are set aside

ITA 3222/DEL/2019[2015-16]Status: DisposedITAT Delhi19 May 2022AY 2015-16

Bench: Shri B.R.R. Kumar & Shri Anubhav Sharmasarr Freights Corporation, Vs. Dcit, 1E, Sewak House, Jhandewalan Circle-62(1), Extn, New Delhi New Delhi Pan: Aacfs9569A (Appellant) (Respondent)

For Appellant: Shri Ashok Khandelwal, CAFor Respondent: Ms. Yagya Saini Kakkar, CIT DR
Section 142(1)Section 143(2)Section 143(3)Section 234B

…ercise of the statutory powers. In a quite reasonable manner the ld CIT(A) in Assessee‟s own case for Assessment Year 2014-15 has not sustained such dis- allowance by relying the judgemnt of Hon'ble Delhi High Court in Friends Clearing Agency (P) Ltd. Vs. CIT 332 ITR 269, where ithas held that there is no basis for an ad hoc dis- allowances. Either it was the case that the evidence was produced or the evidence was not produced. 8. Thus, grounds raised in present appeal are sustained and the appeal is allowed and the Impugned additions are set aside. Order pronounced in the open court on 19/05/2022. - - (B.R.R. KU…

ADDL. CIT, SPECIAL RANGE- 9, NEW DELHI vs. VIMAL MOULDERS INDIA PVT. LTD., NEW DELHI

In the result, the appeal filed by the Revenue is dismissed and the CO filed by the assessee is partly allowed

ITA 3122/DEL/2018[2012-13]Status: DisposedITAT Delhi18 Nov 2021AY 2012-13
For Appellant: Shri Ajay Wadhva, AdvocateFor Respondent: Shri Munesh Kumar, CIT, DR
Section 115JSection 143(1)Section 143(2)Section 269SSection 68

…or discrepancies. Therefore, in view of the following decisions of the Hon’ble Delhi High Court such ad hoc disallowances of expenses is not permissible:- 1) National Industrial Corpn. Ltd. vs. CIT, 258 ITR 575; & 2) Friends Cleaning Agency (P) Ltd. vs. CIT, 332 ITR 269. 5. We have considered the rival arguments made by both the sides, perused the orders of the Assessing Officer and CIT(A) and the paper book filed on behalf of the assessee. We have also considered the various decisions cited before us. So far as the ground raised by the Revenue is concerned, we find the AO made addition of Rs.15,88,50,872/- u/s…

HIMACHAL FUTURISTIC COMMUNICATIONS LTD.,NEW DELHI vs. DCIT, NEW DELHI

Appeals are disposed of by this common order

ITA 817/DEL/2014[2006-07]Status: DisposedITAT Delhi26 Oct 2021AY 2006-07

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Rakesh Joshi, C. AFor Respondent: Shri Najani [CIT] – D.R
Section 133ASection 143(3)Section 153ASection 80I

…y the learned assessing officer merely on conjectures and surmises. There is nothing like personal expenditure incurred by the company, as it is a case of the limited company. The assessee placed reliance on the case of Friends Clearing Agency Private Limited 332 ITR 269 and Widex India Private Limited versus DCIT 66 DTR. It was further stated that there is no instances available with the assessing officer that any expenditure is incurred by the assessee, which is not wholly and exclusively incurred for the purposes of the business. He therefore submitted that the disallowance made by the learned assessing office…

HIMACHAL FUTURISTIC COMMUNICATIONS LTD.,NEW DELHI vs. DCIT, NEW DELHI

Appeals are disposed of by this common order

ITA 816/DEL/2014[2005-06]Status: DisposedITAT Delhi26 Oct 2021AY 2005-06

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Rakesh Joshi, C. AFor Respondent: Shri Najani [CIT] – D.R
Section 133ASection 143(3)Section 153ASection 80I

…y the learned assessing officer merely on conjectures and surmises. There is nothing like personal expenditure incurred by the company, as it is a case of the limited company. The assessee placed reliance on the case of Friends Clearing Agency Private Limited 332 ITR 269 and Widex India Private Limited versus DCIT 66 DTR. It was further stated that there is no instances available with the assessing officer that any expenditure is incurred by the assessee, which is not wholly and exclusively incurred for the purposes of the business. He therefore submitted that the disallowance made by the learned assessing office…

DCIT, NEW DELHI vs. M/S. HIMACHAL FUTURISTIC COMMUNICATIONS LTD., NEW DELHI

Appeals are disposed of by this common order

ITA 766/DEL/2014[2006-07]Status: DisposedITAT Delhi26 Oct 2021AY 2006-07

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Rakesh Joshi, C. AFor Respondent: Shri Najani [CIT] – D.R
Section 133ASection 143(3)Section 153ASection 80I

…y the learned assessing officer merely on conjectures and surmises. There is nothing like personal expenditure incurred by the company, as it is a case of the limited company. The assessee placed reliance on the case of Friends Clearing Agency Private Limited 332 ITR 269 and Widex India Private Limited versus DCIT 66 DTR. It was further stated that there is no instances available with the assessing officer that any expenditure is incurred by the assessee, which is not wholly and exclusively incurred for the purposes of the business. He therefore submitted that the disallowance made by the learned assessing office…

DCIT, NEW DELHI vs. M/S. HIMACHAL FUTURISTIC COMMUNICATIONS LTD., NEW DELHI

Appeals are disposed of by this common order

ITA 765/DEL/2014[2005-06]Status: DisposedITAT Delhi26 Oct 2021AY 2005-06

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Rakesh Joshi, C. AFor Respondent: Shri Najani [CIT] – D.R
Section 133ASection 143(3)Section 153ASection 80I

…y the learned assessing officer merely on conjectures and surmises. There is nothing like personal expenditure incurred by the company, as it is a case of the limited company. The assessee placed reliance on the case of Friends Clearing Agency Private Limited 332 ITR 269 and Widex India Private Limited versus DCIT 66 DTR. It was further stated that there is no instances available with the assessing officer that any expenditure is incurred by the assessee, which is not wholly and exclusively incurred for the purposes of the business. He therefore submitted that the disallowance made by the learned assessing office…

DCIT, NEW DELHI vs. M/S. HIMACHAL FUTURISTIC COMMUNICATIONS LTD., NEW DELHI

Appeals are disposed of by this common order

ITA 6226/DEL/2013[2004-05]Status: DisposedITAT Delhi26 Oct 2021AY 2004-05

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Rakesh Joshi, C. AFor Respondent: Shri Najani [CIT] – D.R
Section 133ASection 143(3)Section 153ASection 80I

…y the learned assessing officer merely on conjectures and surmises. There is nothing like personal expenditure incurred by the company, as it is a case of the limited company. The assessee placed reliance on the case of Friends Clearing Agency Private Limited 332 ITR 269 and Widex India Private Limited versus DCIT 66 DTR. It was further stated that there is no instances available with the assessing officer that any expenditure is incurred by the assessee, which is not wholly and exclusively incurred for the purposes of the business. He therefore submitted that the disallowance made by the learned assessing office…

DCIT, NEW DELHI vs. M/S. HIMACHAL FUTURISTIC COMMUNICATIONS LTD., NEW DELHI

Appeals are disposed of by this common order

ITA 6225/DEL/2013[2003-04]Status: DisposedITAT Delhi26 Oct 2021AY 2003-04

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Rakesh Joshi, C. AFor Respondent: Shri Najani [CIT] – D.R
Section 133ASection 143(3)Section 153ASection 80I

…y the learned assessing officer merely on conjectures and surmises. There is nothing like personal expenditure incurred by the company, as it is a case of the limited company. The assessee placed reliance on the case of Friends Clearing Agency Private Limited 332 ITR 269 and Widex India Private Limited versus DCIT 66 DTR. It was further stated that there is no instances available with the assessing officer that any expenditure is incurred by the assessee, which is not wholly and exclusively incurred for the purposes of the business. He therefore submitted that the disallowance made by the learned assessing office…

DCIT, NEW DELHI vs. M/S HIMACHAL FUTURISTIC COMMUNICATION LTD.,, NEW DELHI

Appeals are disposed of by this common order

ITA 5741/DEL/2013[2002-03]Status: DisposedITAT Delhi26 Oct 2021AY 2002-03

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Rakesh Joshi, C. AFor Respondent: Shri Najani [CIT] – D.R
Section 133ASection 143(3)Section 153ASection 80I

…y the learned assessing officer merely on conjectures and surmises. There is nothing like personal expenditure incurred by the company, as it is a case of the limited company. The assessee placed reliance on the case of Friends Clearing Agency Private Limited 332 ITR 269 and Widex India Private Limited versus DCIT 66 DTR. It was further stated that there is no instances available with the assessing officer that any expenditure is incurred by the assessee, which is not wholly and exclusively incurred for the purposes of the business. He therefore submitted that the disallowance made by the learned assessing office…

DCIT, NEW DELHI vs. M/S. DEE DEVELOPMENT ENGINEERS LTD., FARIDABAD

The appeal of the Revenue is dismissed

ITA 4959/DEL/2016[2011-12]Status: DisposedITAT Delhi08 Apr 2021AY 2011-12

Bench: Shri R. K. Panda & Ms Suchitra Kamble(Through Video Conferencing)

Section 143(2)Section 14A

…sing Officer has not at all pointed out that expenditure was incurred for personal purpose. The Ld. AR relied upon the Delhi High Court decision in case of DCIT Vs. Haryana Oxygen Ltd. (1999) 76 ITD (Del) 32 and Friends Clearing Agency Pvt. Ltd. Vs. CIT(2011) 332 ITR 269 (Del). The Ld. AR also relied upon the decision of the Delhi High Court in case of CIT Vs. Monto Motors Ltd. And ITA No. 978/2011 dated 12/12/2011 and CIT Vs. Jubilant Food Works Pvt. Ltd. , ITA No. 310/2014 dated 1/8/2014. As regards Ground No. 3 of the Revenue’s appeal, the Ld. AR submitted that the expenditure of Rs. 87,82,889/- was incurred f…

MANOJ KUMAR,GURGAON vs. ACIT, CIRCLE-62(1), NEW DELHI

In the result, the appeal of the assessee is partly allowed

ITA 978/DEL/2018[2014-15]Status: DisposedITAT Delhi02 Mar 2021AY 2014-15

Bench: Shri Bhavnesh Saini & Shri O.P. Kant[Through Video Conferencing]

Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘C’ NEW DELHI BEFORE SHRI BHAVNESH SAINI, JUDICIAL MEMBER AND SHRI O.P. KANT, ACCOUNTANT MEMBER [Through Video Conferencing] ITA No.978/Del./2018 Assessment Year: 2014-15 Shri Manoj Kumar, Vs. ACIT, Prop. Balaji Engineers & Circle-62(1), Consultants, House No. 9, New Delhi Sector-9, Gurgaon PAN :AGQPK1786P (Appellant) (Respondent) Appellant by Shri G.S. Kochar, CA Respondent by Shri Bhopal Singh, Sr.DR Date of hearing 17.02.2021 Date of pronouncement 02.03.2021 ORDER PER O.P. KANT: This appeal by the assessee is directed against order dated 30/11/2017 pass…

DEPUTY COMMISSIONER OF INCOME TAX 1(1) , BHOPAL vs. M/S. SOM DISTILLERIES & BREWERIES LTD., BHOPAL

In the result Ground No.2 of the revenue is allowed for

ITA 516/IND/2018[2012-13]Status: DisposedITAT Indore24 Oct 2019AY 2012-13

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradassessment Year 2012-13 Pan : Aabcs3374B

Section 143(2)Section 143(3)Section 194Section 234ASection 40

…Som Distilleries & Breweries Ltd ITA No.495/Ind/2018 & ITA No.516/Ind/2018 आयकर अपील"य अ"धकरण, इंदौर "यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL, INDORE BENCH, INDORE BEFORE HON'BLE KUL BHARAT, JUDICIAL MEMBER AND HON'BLE MANISH BORAD, ACCOUNTANT MEMBER Assessment Year 2012-13 PAN : AABCS3374B M/s. Som Distilleries & V/s CIT(Appeals)-1, Breweries Ltd, Bhopal 23, Zone-23, M.P.Nagar, Bhopal (Appellant) (Respondent) Assessment Year 2012-13 DCIT-1(1), V/s M/s. Som Distilleries & Bhopal Breweries Ltd, 23, Zone-23, M.P.Nagar, Bhopal (Revenue) (Respondent) Revenue by Shri S.S. Mantri, CIT Assessee by S…

M/S. SOM DISTILLERIES & BREWERIES LTD.,BHOPAL vs. THE ACIT, 1(2), BHOPAL

In the result Ground No.2 of the revenue is allowed for

ITA 495/IND/2018[12-13]Status: DisposedITAT Indore24 Oct 2019

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradassessment Year 2012-13 Pan : Aabcs3374B

Section 143(2)Section 143(3)Section 194Section 234ASection 40

…Som Distilleries & Breweries Ltd ITA No.495/Ind/2018 & ITA No.516/Ind/2018 आयकर अपील"य अ"धकरण, इंदौर "यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL, INDORE BENCH, INDORE BEFORE HON'BLE KUL BHARAT, JUDICIAL MEMBER AND HON'BLE MANISH BORAD, ACCOUNTANT MEMBER Assessment Year 2012-13 PAN : AABCS3374B M/s. Som Distilleries & V/s CIT(Appeals)-1, Breweries Ltd, Bhopal 23, Zone-23, M.P.Nagar, Bhopal (Appellant) (Respondent) Assessment Year 2012-13 DCIT-1(1), V/s M/s. Som Distilleries & Bhopal Breweries Ltd, 23, Zone-23, M.P.Nagar, Bhopal (Revenue) (Respondent) Revenue by Shri S.S. Mantri, CIT Assessee by S…

M/S. VICHITRA CONSTRUCTIONS PVT. LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

ITA 5048/DEL/2015[2011-12]Status: DisposedITAT Delhi27 May 2019AY 2011-12

Bench: Shri N. K. Billaiya & Ms Suchitra Kamble

…India) Ltd. vs. Addl. CIT (2006) 102 TTJ (Pune) 882 " DCIT VS Haryana Oxygen Ltd. (1999) 76 ITD (Del) 32 " Dinesh Mills Ltd. v. CIT (2002) 254 ITR 673 (Guj) " CIT vs. S.S.P. (P) Ltd. (2011) 202 Taxman 386 (P&H) " Friends Clearing Agency (P) Ld. Vs. CIT (2011) 332 ITR 269 (Del) ) 37. The Ld. DR relied upon Assessment Order and the order of the CIT(A). 38. We have heard both the parties and perused the material available on record. The basis for this addition made by the Assessing Officer was in respect of addition made in A.Y. 2009-10. But the Assessing Officer failed to appreciate the changing scenario in prese…

M/S. VICHITRA CONSTRUCTIONS PVT. LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

ITA 5047/DEL/2015[2010-11]Status: DisposedITAT Delhi27 May 2019AY 2010-11

Bench: Shri N. K. Billaiya & Ms Suchitra Kamble

…India) Ltd. vs. Addl. CIT (2006) 102 TTJ (Pune) 882 " DCIT VS Haryana Oxygen Ltd. (1999) 76 ITD (Del) 32 " Dinesh Mills Ltd. v. CIT (2002) 254 ITR 673 (Guj) " CIT vs. S.S.P. (P) Ltd. (2011) 202 Taxman 386 (P&H) " Friends Clearing Agency (P) Ld. Vs. CIT (2011) 332 ITR 269 (Del) ) 37. The Ld. DR relied upon Assessment Order and the order of the CIT(A). 38. We have heard both the parties and perused the material available on record. The basis for this addition made by the Assessing Officer was in respect of addition made in A.Y. 2009-10. But the Assessing Officer failed to appreciate the changing scenario in prese…

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Friends Clearing Agency (P.) Ltd. v. Commissioner of Income (332 ITR 269) — Cited in 41 Judgments | BharatTax