Kantilal and Bros. v. ACIT

52 ITD 412Income Tax Appellate Tribunal1995#2005 most cited

What is Kantilal and Bros. v. ACIT authority for?

Once the generation of income is offered to tax, particularly in post-search disclosures or cases involving intra-group fund flow, its subsequent application as expenditure, investment, or cash movement cannot be separately added to income, provided a clear link between the source and application of funds is established.

57

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2017 to 2025.

Also referred to as

Kantilal and Bros. v. ACIT · 52 ITD 412 · telescoping principle · post-search disclosures · application of funds · Section 132(4) statement · Section 68 cash credit · unexplained investment · seized material · block assessment · intra-group fund flow

Sections most often in play

Section 153ASection 132Section 143(3)Section 68Section 37(1)Section 69CSection 115BBESection 145

Issues it is cited on

section 76on money receiptsection 74eligible assesseestatement under section 132(4)on-moneyloose paperssection 44ablock periodunexplained expendituresection 44adshare capital and share premium

Judgments citing Kantilal and Bros. v. ACIT

ACIT, New Delhi vs. M/S. Majestic Properties Pvt. Ltd., New Delhi

In the result, all the appeals of the revenue are dismissed

ITA 5579/DEL/2011[2007-08]Status: DisposedITAT Delhi14 Oct 2022AY 2007-08

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 5231/Del/2011 : Asstt. Year 2005-06 Ita No. 5392/Del/2011 : Asstt. Year 2006-07 Ita No. 5579/Del/2011 : Asstt. Year 2007-08 Acit, Vs. M/S Majestic Properties (P) Ltd., Central Circle-2, 1/18B, Asaf Ali Road, New Delhi New Delhi (Appellant) (Respondent) Pan No. Aaacm7158E Assessee By : Dr. Rakesh Gupta, Adv. & Sh. Deepesh Garg, Adv. Revenue By : Ms. Shivani Singh, Cit Dr Date Of Hearing: 22.07.2022 Date Of Pronouncement: 14.10.2022

For Appellant: Dr. Rakesh Gupta, Adv. &For Respondent: Ms. Shivani Singh, CIT DR
Section 132

…R 775, 82 (SC). Further reliance is placed on following cases that no addition could be made merely on the basis of uncorroborated loose papers: Atul Kumar Jain Vs. DCIT TTJ 064 786 (Del) ACIT Vs. Kirori Lal Aggarwal 50 TTJ 393 (Jab) Kantilal & Bros Vs. ACIT 52 ITD 412 (Pune) ADDI ITO Vs. T. Mudduveerappa Sons 45 ITD 12 (Bang) M. V. Mathew Vs. ITO 46 TTJ 353 (Coch) ITO Vs. W.D. Estate Pvt. Ltd. 45 ITD 473 (Bom) CIT Vs. SMS Investments Corpn. P Ltd. 207 ITR 364fRaj) CIT (Central II) Vs. K.K. Gupta 308 ITR 230(Delhi) ACIT Vs. Shailesh S. Shah 63 ITD 153 (Bom). “the AO has not given any reasoning or finding or has…

ACIT, New Delhi vs. M/S. Majestic Properties Pvt. Ltd., New Delhi

In the result, all the appeals of the revenue are dismissed

ITA 5392/DEL/2011[2006-07]Status: DisposedITAT Delhi14 Oct 2022AY 2006-07

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 5231/Del/2011 : Asstt. Year 2005-06 Ita No. 5392/Del/2011 : Asstt. Year 2006-07 Ita No. 5579/Del/2011 : Asstt. Year 2007-08 Acit, Vs. M/S Majestic Properties (P) Ltd., Central Circle-2, 1/18B, Asaf Ali Road, New Delhi New Delhi (Appellant) (Respondent) Pan No. Aaacm7158E Assessee By : Dr. Rakesh Gupta, Adv. & Sh. Deepesh Garg, Adv. Revenue By : Ms. Shivani Singh, Cit Dr Date Of Hearing: 22.07.2022 Date Of Pronouncement: 14.10.2022

For Appellant: Dr. Rakesh Gupta, Adv. &For Respondent: Ms. Shivani Singh, CIT DR
Section 132

…R 775, 82 (SC). Further reliance is placed on following cases that no addition could be made merely on the basis of uncorroborated loose papers: Atul Kumar Jain Vs. DCIT TTJ 064 786 (Del) ACIT Vs. Kirori Lal Aggarwal 50 TTJ 393 (Jab) Kantilal & Bros Vs. ACIT 52 ITD 412 (Pune) ADDI ITO Vs. T. Mudduveerappa Sons 45 ITD 12 (Bang) M. V. Mathew Vs. ITO 46 TTJ 353 (Coch) ITO Vs. W.D. Estate Pvt. Ltd. 45 ITD 473 (Bom) CIT Vs. SMS Investments Corpn. P Ltd. 207 ITR 364fRaj) CIT (Central II) Vs. K.K. Gupta 308 ITR 230(Delhi) ACIT Vs. Shailesh S. Shah 63 ITD 153 (Bom). “the AO has not given any reasoning or finding or has…

DCIT, New Delhi vs. M/S. Majestic Properties (P) Ltd., New Delhi

In the result, all the appeals of the revenue are dismissed

ITA 5231/DEL/2011[2005-06]Status: DisposedITAT Delhi14 Oct 2022AY 2005-06

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 5231/Del/2011 : Asstt. Year 2005-06 Ita No. 5392/Del/2011 : Asstt. Year 2006-07 Ita No. 5579/Del/2011 : Asstt. Year 2007-08 Acit, Vs. M/S Majestic Properties (P) Ltd., Central Circle-2, 1/18B, Asaf Ali Road, New Delhi New Delhi (Appellant) (Respondent) Pan No. Aaacm7158E Assessee By : Dr. Rakesh Gupta, Adv. & Sh. Deepesh Garg, Adv. Revenue By : Ms. Shivani Singh, Cit Dr Date Of Hearing: 22.07.2022 Date Of Pronouncement: 14.10.2022

For Appellant: Dr. Rakesh Gupta, Adv. &For Respondent: Ms. Shivani Singh, CIT DR
Section 132

…R 775, 82 (SC). Further reliance is placed on following cases that no addition could be made merely on the basis of uncorroborated loose papers: Atul Kumar Jain Vs. DCIT TTJ 064 786 (Del) ACIT Vs. Kirori Lal Aggarwal 50 TTJ 393 (Jab) Kantilal & Bros Vs. ACIT 52 ITD 412 (Pune) ADDI ITO Vs. T. Mudduveerappa Sons 45 ITD 12 (Bang) M. V. Mathew Vs. ITO 46 TTJ 353 (Coch) ITO Vs. W.D. Estate Pvt. Ltd. 45 ITD 473 (Bom) CIT Vs. SMS Investments Corpn. P Ltd. 207 ITR 364fRaj) CIT (Central II) Vs. K.K. Gupta 308 ITR 230(Delhi) ACIT Vs. Shailesh S. Shah 63 ITD 153 (Bom). “the AO has not given any reasoning or finding or has…

Shri Naresh Jhanwar, Jaipur vs. DCIT, C.C.-3, Jaipur

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

ITA 260/JPR/2020[2017-18]Status: DisposedITAT Jaipur17 Aug 2022AY 2017-18
For Appellant: Sh. P. C. Parwal (CA)For Respondent: Shri Sanjay Dhariwal (CIT)
Section 139Section 143(3)Section 153ASection 199CSection 292CSection 68

…names of the borrowers is correct and not the names of lenders. Entire documents should read as a rejected as a whole— Navjivan Oil Mills vs. CIT (2001) 170 CTR (Guj) 224: (2001) 252 ITR 417 (Guj), Kantilal Bros. vs. Asstt. CIT (2995) 51 MI (Pune) 513: (1995) 52 ITD 412 (Pune), Glass Lines Equipment Co. Ltd. vs. CIT (2001) 170 CTR (Guj) 470 : (2002) 253 ITR 454 (Guj), Mehta Parikh & Co. vs. C1T (1956) 30 ITR 181 (SC) and Chander Mohan Mehta vs. Asstt. CIT (Inv.) (1999) 65 TTJ (Pune) 327: (1999) 71. ITD 245 (Pune) applied. First thing the AO has to prove is that it is the investment of the assessee. In other words…

Shri Naresh Jhanwar, Jaipur vs. DCIT, C.C.-3, Jaipur

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

ITA 259/JPR/2020[2016-17]Status: DisposedITAT Jaipur17 Aug 2022AY 2016-17
For Appellant: Sh. P. C. Parwal (CA)For Respondent: Shri Sanjay Dhariwal (CIT)
Section 139Section 143(3)Section 153ASection 199CSection 292CSection 68

…names of the borrowers is correct and not the names of lenders. Entire documents should read as a rejected as a whole— Navjivan Oil Mills vs. CIT (2001) 170 CTR (Guj) 224: (2001) 252 ITR 417 (Guj), Kantilal Bros. vs. Asstt. CIT (2995) 51 MI (Pune) 513: (1995) 52 ITD 412 (Pune), Glass Lines Equipment Co. Ltd. vs. CIT (2001) 170 CTR (Guj) 470 : (2002) 253 ITR 454 (Guj), Mehta Parikh & Co. vs. C1T (1956) 30 ITR 181 (SC) and Chander Mohan Mehta vs. Asstt. CIT (Inv.) (1999) 65 TTJ (Pune) 327: (1999) 71. ITD 245 (Pune) applied. First thing the AO has to prove is that it is the investment of the assessee. In other words…

ACIT, Central Circle, Alwar vs. Shri Babu Lal Data, 2015-16

In the result, appeal of the revenue is dismissed

ITA 1232/JPR/2019[2016-17]Status: DisposedITAT Jaipur05 May 2022AY 2016-17
For Appellant: Sh. P. C. Parwal, CAFor Respondent: S. Naiyer Ali Najmi, CIT
Section 127Section 132Section 139Section 153A

…o be a book. The term 'book' is to be construed as it is understood in the common parlance. No special meaning could be assigned to that term. Therefore, the assessee's case could not be put within the ken of section 68.- Kantilal & Bros. v. Asstt. CIT [1995] 52 ITD 412 (Pune) 8.2 In the back drop of the above it is clear that the predominant condition is to maintain the books of accounts & these conditions needs to be cumulatively fulfilled and in absence of anyone of the fulfilling criteria, the amount cannot be added under section 68 of the act. It is also settled law that the onus to prove the genuineness of…

ACIT, Central Circle, Alwar vs. Shri Babu Lal Data, 2015-16

In the result, appeal of the revenue is dismissed

ITA 1231/JPR/2019[2015-16]Status: DisposedITAT Jaipur05 May 2022AY 2015-16
For Appellant: Sh. P. C. Parwal, CAFor Respondent: S. Naiyer Ali Najmi, CIT
Section 127Section 132Section 139Section 153A

…o be a book. The term 'book' is to be construed as it is understood in the common parlance. No special meaning could be assigned to that term. Therefore, the assessee's case could not be put within the ken of section 68.- Kantilal & Bros. v. Asstt. CIT [1995] 52 ITD 412 (Pune) 8.2 In the back drop of the above it is clear that the predominant condition is to maintain the books of accounts & these conditions needs to be cumulatively fulfilled and in absence of anyone of the fulfilling criteria, the amount cannot be added under section 68 of the act. It is also settled law that the onus to prove the genuineness of…

Shri Babu Lal Data, Alwar vs. DCIT, Central Circle, Alwar

In the result, appeal of the revenue is dismissed

ITA 1223/JPR/2019[2016-17]Status: DisposedITAT Jaipur05 May 2022AY 2016-17
For Appellant: Sh. P. C. Parwal, CAFor Respondent: S. Naiyer Ali Najmi, CIT
Section 127Section 132Section 139Section 153A

…o be a book. The term 'book' is to be construed as it is understood in the common parlance. No special meaning could be assigned to that term. Therefore, the assessee's case could not be put within the ken of section 68.- Kantilal & Bros. v. Asstt. CIT [1995] 52 ITD 412 (Pune) 8.2 In the back drop of the above it is clear that the predominant condition is to maintain the books of accounts & these conditions needs to be cumulatively fulfilled and in absence of anyone of the fulfilling criteria, the amount cannot be added under section 68 of the act. It is also settled law that the onus to prove the genuineness of…

Shri Babu Lal Data, Alwar vs. DCIT, Central Circle, Alwar

In the result, appeal of the revenue is dismissed

ITA 1222/JPR/2019[2015-16]Status: DisposedITAT Jaipur05 May 2022AY 2015-16
For Appellant: Sh. P. C. Parwal, CAFor Respondent: S. Naiyer Ali Najmi, CIT
Section 127Section 132Section 139Section 153A

…o be a book. The term 'book' is to be construed as it is understood in the common parlance. No special meaning could be assigned to that term. Therefore, the assessee's case could not be put within the ken of section 68.- Kantilal & Bros. v. Asstt. CIT [1995] 52 ITD 412 (Pune) 8.2 In the back drop of the above it is clear that the predominant condition is to maintain the books of accounts & these conditions needs to be cumulatively fulfilled and in absence of anyone of the fulfilling criteria, the amount cannot be added under section 68 of the act. It is also settled law that the onus to prove the genuineness of…

ITO, Ward- 27(4), New Dlehi vs. Zexus Air Services Pvt. Ltd., Gurgaon

In the result, the appeal filed by the Revenue as well as the CO filed by the assessee are dismissed

ITA 2608/DEL/2018[2014-15]Status: DisposedITAT Delhi23 Apr 2021AY 2014-15

Bench: Shri R.K. Panda & Ms. Suchitra Kambleassessment Year: 2014-15 Ito, Vs Zexus Air Services Pvt. Ltd., Ward-27(4), 148-149, Centrum Plaza, New Delhi. Sector-53, Dlf Phase-V, Gurgaon. Pan: Aaacz6541L Co No.121/Del/2018 (Ita No.2608/Del/2018) Assessment Year: 2014-15 Zexus Air Services Pvt. Ltd., Vs. Ito, 148-149, Centrum Plaza, Ward-27(4), Sector-53, Dlf Phase-V, New Delhi. Gurgaon. Pan: Aaacz6541L (Appellant) (Respondent) Assessee By : Shri Gaurav Bansal, Ca Revenue By : Smt. Sushma Singh, Cit-Dr Date Of Hearing : 31.03.2021 Date Of Pronouncement : 23.04.2021 Order Per R.K. Panda, Am: This Appeal Filed By The Revenue Is Directed Against The Order Dated 12Th January, 2018 Of The Cit(A)-9, New Delhi, Relating To Assessment Year 2014-15. Co No.121/Del/2018 The Assessee Has Filed The Co Against The Appeal Filed By The Revenue. For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Common Order.

For Appellant: Shri Gaurav Bansal, CAFor Respondent: Smt. Sushma Singh, CIT-DR
Section 68

…ssessee company. There is no dispute raised by the ld. AO with regard to number of shares; value thereon invested by the assessee company. We also find that the Co-ordinate Bench decision of Pune Tribunal in the case of Kantilal and Bros. vs. ACIT reported in 52 ITD 412 (Pune Trib.) also supports the case of the assessee. 4.3. In view of the aforesaid observations, in the facts and circumstances of the case and respectfully following the aforesaid judicial precedents relied upon hereinabove, we hold that the ld. AO had erroneously invoked the provisions of section 68 of the Act to the facts of the instant case, w…

M/S.Frohar Trading Private Limited, Mumbai vs. Income Tax Officer 6(3)1, Mumbai

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

ITA 543/MUM/2018[2012-13]Status: DisposedITAT Mumbai06 Apr 2021AY 2012-13

Bench: Shri Rajesh Kumar & Shri Amarjit Singhassessment Year: 2012-13

For Appellant: Shri Vishnu Aggarwal, A.RFor Respondent: Shri Leena Srivastav, D.R
Section 143(1)Section 68

…affa Investment Co. in 206ITR 718 at page 725, it is held that in case no cash has been received by the assessee, then no addition can be made u/s 68 of the Act. Similarly, the Pune Bench of the Tribunal also held so in the case of KantiLal& Bros. vs. ACIT in 52 ITD 412” 8. Thus, it is clear from the above that section 68 is not to be invoked where consideration is discharged by way of barter system and not by paying any sum of money. We, therefore, respectfully following the aforesaid decisions, set aside the order of Ld. CIT(A) and direct the AO to delete the disallowance. 9. Appeal of the assessee allowed. 1…

ITO, New Delhi vs. M/S. Elative Building Solutions Pvt. Ltd., New Delhi

In the result, appeal of assessee is allowed

ITA 2498/DEL/2017[2012-13]Status: DisposedITAT Delhi24 Mar 2021AY 2012-13
For Appellant: Shri Sudesh Garg, AdvocateFor Respondent: Shri Jagdish Singh, Sr. DR

…ssessee company. There is no dispute raised by the ld. AO with regard to number of shares; value thereon invested by the assessee company. We also find that the Co-ordinate Bench decision of Pune Tribunal in the case of Kantilal and Bros. vs. ACIT reported in 52 ITD 412 (Pune Trib.) also supports the case of the assessee. 4.3. In view of the aforesaid observations, in the facts and circumstances of the case and respectfully following the aforesaid judicial precedents relied upon hereinabove, we hold that the ld. AO had erroneously invoked the provisions of section 68 of the Act to the facts of the instant case, w…

I.T.O., Ward-1(3), Kolkata vs. M/S Trilokpati Exim Pvt. Ltd., Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 477/KOL/2019[2012-13]Status: DisposedITAT Kolkata16 Sept 2020AY 2012-13

Bench: Shri A. T. Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.477/Kol/2019 ("नधा"रणवष" / Assessment Year:2012-13)

For Appellant: Shri Ram Bilash Meena, CITFor Respondent: ShriVinod Kr. Jain, FCA
Section 143(3)Section 68

…ssessee company. There is no dispute raised by the ld. AO with regard to number of shares; value thereon invested by the assessee company. We also find that the Co-ordinate Bench decision of Pune Tribunal in the case of Kantilal and Bros. vs. ACIT reported in 52 ITD 412 (Pune Trib.) also supports the case of the assessee. 4.3. In view of the aforesaid observations, in the facts and circumstances of the case and respectfully following the aforesaid judicial precedents relied upon hereinabove, we hold that the ld. AO had erroneously invoked the provisions of section 68 of the Act to the facts of the instant case,…

ITO, Ward - 6(1), Kolkata vs. M/S. Dhankamal Commosaes Pvt. Ltd., Kolkata

In the result, appeal of the revenue is dismissed

ITA 2089/KOL/2017[2012-13]Status: DisposedITAT Kolkata17 Jun 2020AY 2012-13

Bench: Sri J. Sudhakar Reddy & Sri Aby T. Varkey) Assessment Year: 2012-13

Section 143(3)Section 250Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘A’ BENCH, KOLKATA (Before Sri J. Sudhakar Reddy, Accountant Member & Sri Aby T. Varkey, Judicial Member) Assessment Year: 2012-13 Income Tax Officer, Ward-6(1), Kolkata…..................................................................…........... Appellant Vs. M/s. Dhankamal Commonsales Pvt. Ltd...........................................................…………….....Respondent 10, Clive Row Kolkata – 700 001 [PAN : AAECD 1957 A] Appearances by: Shri Ram Bilash Meena, CIT, D/R, appearing on behalf of the Revenue. Shri V.K. Jain, FCA, appeared on behalf of the assessee.…

ITO, Ward- 6(1), Kolkata vs. M/S. Dsr Impex Pvt. Ltd., Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 2087/KOL/2017[2012-13]Status: DisposedITAT Kolkata05 Feb 2020AY 2012-13

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.2087/Kol/2017 ("नधा"रणवष" / Assessment Year:2012-13)

For Appellant: Shri Baij Nath Singh, JCITFor Respondent: None
Section 143(3)Section 68

…ssessee company. There is no dispute raised by the ld. AO with regard to number of shares; value thereon invested by the assessee company. We also find that the Co-ordinate Bench decision of Pune Tribunal in the case of Kantilal and Bros. vs. ACIT reported in 52 ITD 412 (Pune Trib.) also supports the case of the assessee. 4.3. In view of the aforesaid observations, in the facts and circumstances of the case and respectfully following the aforesaid judicial precedents relied upon hereinabove, we hold that the ld. AO had erroneously invoked the provisions of section 68 of the Act to the facts of the instant case, w…

Jypore Manufaturing Jewellers Pvt. Ltd., Jaipur vs. JCIT(OSD), Jaipur

In the result appeals filed by assessee are allowed and that of revenue are dismissed

ITA 304/JPR/2014[2009-10]Status: DisposedITAT Jaipur23 Jan 2020AY 2009-10
For Appellant: Shri S.L. Poddar, AdvocateFor Respondent: Shri B.K. Gupta, CIT -DR
Section 153ASection 153C

…and tails you lose is alien to the principles of income tax law. (i) CIT vs. Indio Airways Pvt Ltd (2012) 79 DTR 289 (Del) (ii) Vivek Kumar Kathotia vs. DCIT (2013) 142 ITD 394 (Kol. Trib) (iii) Kanti Lal & Brothers vs. Assistant Commissioner of Income Tax 52 ITD 412 (Pune) 2.10 Apropos the estimation of GP declared in regular books, ld. Counsel further contends that the book results have been examined in past making some additions, which on appeals have become final. No incriminating material is found as there was no search on assessee. However ld. AO again reviewed concluded book results and made GP add…

ITO, Ward - 13(2), Kolkata vs. M/S. Gouri Nandan Real Estate Pvt. Ltd., Howrah

In the result, we uphold the same and dismiss the appeal of the Revenue

ITA 2102/KOL/2017[2012-13]Status: DisposedITAT Kolkata29 Nov 2019AY 2012-13

Bench: Shri J. Sudhakar Reddy & Shri S.S. Godara]

Section 144Section 250Section 56(2)(vii)Section 68Section 80G

…ssessee company. There is no dispute raised by the Id. AO with regard to number of shares; value thereon invested by the assessee company. We also find that the Co-ordinate Bench decision of Pune Tribunal in the case of Kantilal and Bros. vs. ACIT reported in 52 ITD 412 (Pune Trib.) also supports the case of the assessee. 4.3. In view of the aforesaid observations, in the facts and circumstances of the case and respectfully following the aforesaid judicial precedents relied upon hereinabove, we hold that the Id. AO had erroneously invoked the provisions of section 68 of the Act to the facts of the instant case, w…

M/S. Sms Smelters Limited, Naharlagun vs. Deputy Commissioner of Income Tax, Circle - 3, Guwahati

Appeals are allowed in view of our foregoing detailed discussions

ITA 96/GTY/2017[2013-14]Status: DisposedITAT Guwahati06 Sept 2019AY 2013-14

Bench: Shri S.S.Godara & Dr. A.L. Saini

Section 143(3)Section 147Section 68Section 80l

…आयकर अपील"य अधीकरण, खंङपीठ गुवाहाट" , IN THE INCOME TAX APPELLATE TRIBUNAL GUWAHATI BENCH, GUWAHATI Before Shri S.S.Godara, Judicial Member and Dr. A.L. Saini, Accountant Member ITA No.91, 69, 76 & 77/Gau/2017 Assessment Years :2006-07, 207-08, 2012-13 & 2013-14 DCIT, Circle-3, V/s. M/s SMS Smelters Ltd. 7th Floor, Aayakar NH 52A, Lekhi Village, Bhawan, G.S. Road, Naharlagun, Dist. Christian Basti, Papumpare, Arunachal Guwahati-781005 Pradesh [PAN No.AABCN 7147 D] .. अपीलाथ" /Appellant ""यथ"/Respondent ITA No.93-96/Gau/2017 Assessment Years :2009-10, 2010- 11, 2012-13 & 2013-14 M/s SMS Smelters Ltd. V/s. DCIT,…

M/S. Sms Smelters Limited, Naharlagun vs. Deputy Commissioner of Income Tax, Circle - 3, Guwahati

Appeals are allowed in view of our foregoing detailed discussions

ITA 95/GTY/2017[2012-13]Status: DisposedITAT Guwahati06 Sept 2019AY 2012-13

Bench: Shri S.S.Godara & Dr. A.L. Saini

Section 143(3)Section 147Section 68Section 80l

…आयकर अपील"य अधीकरण, खंङपीठ गुवाहाट" , IN THE INCOME TAX APPELLATE TRIBUNAL GUWAHATI BENCH, GUWAHATI Before Shri S.S.Godara, Judicial Member and Dr. A.L. Saini, Accountant Member ITA No.91, 69, 76 & 77/Gau/2017 Assessment Years :2006-07, 207-08, 2012-13 & 2013-14 DCIT, Circle-3, V/s. M/s SMS Smelters Ltd. 7th Floor, Aayakar NH 52A, Lekhi Village, Bhawan, G.S. Road, Naharlagun, Dist. Christian Basti, Papumpare, Arunachal Guwahati-781005 Pradesh [PAN No.AABCN 7147 D] .. अपीलाथ" /Appellant ""यथ"/Respondent ITA No.93-96/Gau/2017 Assessment Years :2009-10, 2010- 11, 2012-13 & 2013-14 M/s SMS Smelters Ltd. V/s. DCIT,…

M/S. Sms Smelters Limited, Naharlagun vs. Deputy Commissioner of Income Tax, Circle - 3, Guwahati

Appeals are allowed in view of our foregoing detailed discussions

ITA 94/GTY/2017[2010-11]Status: DisposedITAT Guwahati06 Sept 2019AY 2010-11

Bench: Shri S.S.Godara & Dr. A.L. Saini

Section 143(3)Section 147Section 68Section 80l

…आयकर अपील"य अधीकरण, खंङपीठ गुवाहाट" , IN THE INCOME TAX APPELLATE TRIBUNAL GUWAHATI BENCH, GUWAHATI Before Shri S.S.Godara, Judicial Member and Dr. A.L. Saini, Accountant Member ITA No.91, 69, 76 & 77/Gau/2017 Assessment Years :2006-07, 207-08, 2012-13 & 2013-14 DCIT, Circle-3, V/s. M/s SMS Smelters Ltd. 7th Floor, Aayakar NH 52A, Lekhi Village, Bhawan, G.S. Road, Naharlagun, Dist. Christian Basti, Papumpare, Arunachal Guwahati-781005 Pradesh [PAN No.AABCN 7147 D] .. अपीलाथ" /Appellant ""यथ"/Respondent ITA No.93-96/Gau/2017 Assessment Years :2009-10, 2010- 11, 2012-13 & 2013-14 M/s SMS Smelters Ltd. V/s. DCIT,…