KLM Royal Dutch Airlines v. Additional Director of Income Tax

292 ITR 49High Court2007#1455 most cited

What is KLM Royal Dutch Airlines v. Additional Director of Income Tax authority for?

Reassessment proceedings under Section 147 cannot be initiated based on a mere change of opinion or reappraisal of existing facts, but require new or fresh tangible material or information indicating escapement of income.

78

judgments rely on this decision, according to BharatTax’s citation analysis of 367,181 Indian tax judgments — from 2010 to 2025.

Also referred to as

KLM Royal Dutch Airlines v. ADIT · Section 147 · Section 148 · initiation of reassessment · fresh tangible material · mere change of opinion · escapement of income · full and true disclosure · reappraisal of existing facts · Kelvinator principle · 292 ITR 49

Sections most often in play

Section 143(3)Section 147Section 148Section 143(2)Section 142(1)Section 139Section 139(4)Section 237
Read the full judgment

Issues it is cited on

section 237section 55(2)assistant directorsection 139(9)section 49section 44bbfresh tangible materialsection 44bsection 114kelvinatormere change of opinionfull and true disclosure

Judgments citing KLM Royal Dutch Airlines v. Additional Director of Income Tax

Sahara India Power Corporation Ltd., Pune vs. Assistant Commissioner of Income-Tax

In the result, the appeal filed by the revenue for the AY 2005-06 in I

ITA 109/PUN/2007[2003-04]Status: DisposedITAT Delhi28 Apr 2023AY 2003-04

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar Us

For Appellant: Shri Ajay VohraFor Respondent: Shri Kanv Bali

…tion 143(3)/148. of the Income Tax Act is invalid and, therefore, the entire assessment framed is void ab-initio and bad in law. 74. The ld. CIT(A) placing reliance on the judgment of jurisdictional High Court in the case of KLM Royal Dutch Airways Vs. ADIT (292 ITR 49) quashed the assessment order. Against this revenue is in appeal before us. 75. We have heard the rival submissions and perused the materials available on record. The main contention of the ld. A.R. is that the assessee has filed the return of income for assessment year 2005-06 on 31.10.2005. The said return was processed u/s 143(1) of the Act. N…

ACIT, New Delhi vs. Sh. Vinod Kumar Gupta, New Delhi

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

ITA 6473/DEL/2014[2010-11]Status: DisposedITAT Delhi27 Apr 2023AY 2010-11

Bench: Shri N.K. Billaiya & Shri Challa Nagendra Prasad[Assessment Year: 2009-10] [Assessment Year: 2010-11]

For Appellant: Shri Anil Jain, AdvFor Respondent: Shri H.K. Choudhary, CIT-DR
Section 132Section 148Section 292B

…y with regard to the issue involved in this case, we can take the shelter of the decisions, as relied upon by the learned DR, which have been pronounced in the cases of section 148 proceedings viz. KLM Royal Dutch Airlines v. Assistant Director of Income Tax: 292 ITR 49 and CIT vs. K.M. Ranchayappan; 304 ITR 264. The judgments relied upon by the learned AR are not applicable to the facts of the case. In these judgments only one notice was issued and the same also was not as per the procedure prescribed under the Act whereas in the present case there is no defect in the first notice and the assessment has been co…

Mr. Vinod Gupta, New Delhi vs. DCIT, New Delhi

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

ITA 6259/DEL/2014[2010-11]Status: DisposedITAT Delhi27 Apr 2023AY 2010-11

Bench: Shri N.K. Billaiya & Shri Challa Nagendra Prasad[Assessment Year: 2009-10] [Assessment Year: 2010-11]

For Appellant: Shri Anil Jain, AdvFor Respondent: Shri H.K. Choudhary, CIT-DR
Section 132Section 148Section 292B

…y with regard to the issue involved in this case, we can take the shelter of the decisions, as relied upon by the learned DR, which have been pronounced in the cases of section 148 proceedings viz. KLM Royal Dutch Airlines v. Assistant Director of Income Tax: 292 ITR 49 and CIT vs. K.M. Ranchayappan; 304 ITR 264. The judgments relied upon by the learned AR are not applicable to the facts of the case. In these judgments only one notice was issued and the same also was not as per the procedure prescribed under the Act whereas in the present case there is no defect in the first notice and the assessment has been co…

Vinod Gupta, New Delhi vs. DCIT, New Delhi

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

ITA 4055/DEL/2014[2009-10]Status: DisposedITAT Delhi27 Apr 2023AY 2009-10

Bench: Shri N.K. Billaiya & Shri Challa Nagendra Prasad[Assessment Year: 2009-10] [Assessment Year: 2010-11]

For Appellant: Shri Anil Jain, AdvFor Respondent: Shri H.K. Choudhary, CIT-DR
Section 132Section 148Section 292B

…y with regard to the issue involved in this case, we can take the shelter of the decisions, as relied upon by the learned DR, which have been pronounced in the cases of section 148 proceedings viz. KLM Royal Dutch Airlines v. Assistant Director of Income Tax: 292 ITR 49 and CIT vs. K.M. Ranchayappan; 304 ITR 264. The judgments relied upon by the learned AR are not applicable to the facts of the case. In these judgments only one notice was issued and the same also was not as per the procedure prescribed under the Act whereas in the present case there is no defect in the first notice and the assessment has been co…

ACIT, New Delhi vs. Sh. S. K. Gupta, New Delhi

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

ITA 3991/DEL/2014[2010-11]Status: DisposedITAT Delhi27 Apr 2023AY 2010-11

Bench: Shri N.K. Billaiya & Shri Challa Nagendra Prasad[Assessment Year: 2009-10] [Assessment Year: 2010-11]

For Appellant: Shri Anil Jain, AdvFor Respondent: Shri H.K. Choudhary, CIT-DR
Section 132Section 148Section 292B

…y with regard to the issue involved in this case, we can take the shelter of the decisions, as relied upon by the learned DR, which have been pronounced in the cases of section 148 proceedings viz. KLM Royal Dutch Airlines v. Assistant Director of Income Tax: 292 ITR 49 and CIT vs. K.M. Ranchayappan; 304 ITR 264. The judgments relied upon by the learned AR are not applicable to the facts of the case. In these judgments only one notice was issued and the same also was not as per the procedure prescribed under the Act whereas in the present case there is no defect in the first notice and the assessment has been co…

ACIT, New Delhi vs. Sh. Vinod Kumar Gupta, Delhi

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

ITA 3989/DEL/2014[2009-10]Status: DisposedITAT Delhi27 Apr 2023AY 2009-10

Bench: Shri N.K. Billaiya & Shri Challa Nagendra Prasad[Assessment Year: 2009-10] [Assessment Year: 2010-11]

For Appellant: Shri Anil Jain, AdvFor Respondent: Shri H.K. Choudhary, CIT-DR
Section 132Section 148Section 292B

…y with regard to the issue involved in this case, we can take the shelter of the decisions, as relied upon by the learned DR, which have been pronounced in the cases of section 148 proceedings viz. KLM Royal Dutch Airlines v. Assistant Director of Income Tax: 292 ITR 49 and CIT vs. K.M. Ranchayappan; 304 ITR 264. The judgments relied upon by the learned AR are not applicable to the facts of the case. In these judgments only one notice was issued and the same also was not as per the procedure prescribed under the Act whereas in the present case there is no defect in the first notice and the assessment has been co…

S.K. Gupta, New Delhi vs. DCIT, New Delhi

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

ITA 3887/DEL/2014[2010-11]Status: DisposedITAT Delhi27 Apr 2023AY 2010-11

Bench: Shri N.K. Billaiya & Shri Challa Nagendra Prasad[Assessment Year: 2009-10] [Assessment Year: 2010-11]

For Appellant: Shri Anil Jain, AdvFor Respondent: Shri H.K. Choudhary, CIT-DR
Section 132Section 148Section 292B

…y with regard to the issue involved in this case, we can take the shelter of the decisions, as relied upon by the learned DR, which have been pronounced in the cases of section 148 proceedings viz. KLM Royal Dutch Airlines v. Assistant Director of Income Tax: 292 ITR 49 and CIT vs. K.M. Ranchayappan; 304 ITR 264. The judgments relied upon by the learned AR are not applicable to the facts of the case. In these judgments only one notice was issued and the same also was not as per the procedure prescribed under the Act whereas in the present case there is no defect in the first notice and the assessment has been co…

Sh. S.K. Gupta, New Delhi vs. DCIT, New Delhi

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

ITA 3107/DEL/2014[2009-10]Status: DisposedITAT Delhi27 Apr 2023AY 2009-10

Bench: Shri N.K. Billaiya & Shri Challa Nagendra Prasad[Assessment Year: 2009-10] [Assessment Year: 2010-11]

For Appellant: Shri Anil Jain, AdvFor Respondent: Shri H.K. Choudhary, CIT-DR
Section 132Section 148Section 292B

…y with regard to the issue involved in this case, we can take the shelter of the decisions, as relied upon by the learned DR, which have been pronounced in the cases of section 148 proceedings viz. KLM Royal Dutch Airlines v. Assistant Director of Income Tax: 292 ITR 49 and CIT vs. K.M. Ranchayappan; 304 ITR 264. The judgments relied upon by the learned AR are not applicable to the facts of the case. In these judgments only one notice was issued and the same also was not as per the procedure prescribed under the Act whereas in the present case there is no defect in the first notice and the assessment has been co…

Venkateshwara Rao Poonuru, Hyderabad vs. ADIT, International Taxation-(2), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 71/HYD/2022[2017-18]Status: DisposedITAT Hyderabad10 Apr 2023AY 2017-18

Bench: Shri R.K. Panda & Shri Laliet Kumar

For Appellant: Shri Y.V. Bhanu Narayan Rao, CAFor Respondent: Shri Jeevan Lal Lavidiya, CIT (DR)
Section 143Section 143(1)Section 143(2)Section 147Section 148Section 153Section 69A

…ITA 71 of 2022 Venkateswara Rao Ponnuru आयकर अपील"य अ"धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B‘ Bench, Hyderabad Before Shri R.K. Panda, Accountant Member AND Shri Laliet Kumar, Judicial Member ITA-IT No.71/Hyd/2022 Assessment Year: 2017-18 Shri Venkateswara Rao Vs. Asstt. Director of Income Ponnuru, Hyderabad Tax (International PAN:AAWPP7203L Taxation)-2 Hyderabad (Appellant) (Respondent) Assessee by: Shri Y.V. Bhanu Narayan Rao, CA Revenue by: Shri Jeevan Lal Lavidiya, CIT (DR) Date of hearing: 16/03/2023 Date of pronouncement: 10/04/2023 ORDER Per R.K. Panda, A.M This appeal fil…

ACIT, Jammu vs. Sh Vikramaditya Singh, Jammu

In the result, all the fours appeals filed by the Revenue are dismissed and the three Cross Objections as well as the ground as per Rule 27 are allowed

ITA 269/ASR/2007[1998-99]Status: DisposedITAT Delhi24 Jan 2022AY 1998-99

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

For Appellant: Shri C.S. Aggarwal, SrFor Respondent: Shri S.D. Kapila, Spl
Section 139(9)Section 147Section 148

…ore vitiated in law. 41.2 Referring to the following decisions, he submitted that surfacing of fresh material is necessary even in a case, wherein the assessment was originally made u/s 143(1) of the Act: i) 319 ITR 221 (Del) Shipra Srivastava vs. ACIT ii) 292 ITR 49 (Del) KLM Royal Dutch Airlines vs. CIT A at page 63, placitum 19 iii) 289 ITR37 (Mad) Bapalal and Company Exports vs. JCIT. At page 45 Placitum 12 iv) 321 ITR526 (Del) CIT vs. Batra Bhatta Company. SLP dismissed in the case of CIT v Batra Bhatta Co. v) 220 CTR 369 (Raj) CIT vs. Bigbass Maheshwari Sewa Samiti vi) 218 CTR 264 (Raj) CIT vs. Smt. Jyot…

ACIT, Cir-II, Jammu vs. Smt. Yashorajya Laxmi, Jammu

In the result, all the fours appeals filed by the Revenue are dismissed and the three Cross Objections as well as the ground as per Rule 27 are allowed

ITA 268/ASR/2007[1998-99]Status: DisposedITAT Delhi24 Jan 2022AY 1998-99

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

For Appellant: Shri C.S. Aggarwal, SrFor Respondent: Shri S.D. Kapila, Spl
Section 139(9)Section 147Section 148

…ore vitiated in law. 41.2 Referring to the following decisions, he submitted that surfacing of fresh material is necessary even in a case, wherein the assessment was originally made u/s 143(1) of the Act: i) 319 ITR 221 (Del) Shipra Srivastava vs. ACIT ii) 292 ITR 49 (Del) KLM Royal Dutch Airlines vs. CIT A at page 63, placitum 19 iii) 289 ITR37 (Mad) Bapalal and Company Exports vs. JCIT. At page 45 Placitum 12 iv) 321 ITR526 (Del) CIT vs. Batra Bhatta Company. SLP dismissed in the case of CIT v Batra Bhatta Co. v) 220 CTR 369 (Raj) CIT vs. Bigbass Maheshwari Sewa Samiti vi) 218 CTR 264 (Raj) CIT vs. Smt. Jyot…

ACIT, Jammu vs. Dr Karan Singh, Jammu

In the result, all the fours appeals filed by the Revenue are dismissed and the three Cross Objections as well as the ground as per Rule 27 are allowed

ITA 267/ASR/2007[1998-99\u005cu005cu005cu005cu005cu005cu005cu005c]Status: DisposedITAT Delhi24 Jan 2022

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

For Appellant: Shri C.S. Aggarwal, SrFor Respondent: Shri S.D. Kapila, Spl
Section 139(9)Section 147Section 148

…ore vitiated in law. 41.2 Referring to the following decisions, he submitted that surfacing of fresh material is necessary even in a case, wherein the assessment was originally made u/s 143(1) of the Act: i) 319 ITR 221 (Del) Shipra Srivastava vs. ACIT ii) 292 ITR 49 (Del) KLM Royal Dutch Airlines vs. CIT A at page 63, placitum 19 iii) 289 ITR37 (Mad) Bapalal and Company Exports vs. JCIT. At page 45 Placitum 12 iv) 321 ITR526 (Del) CIT vs. Batra Bhatta Company. SLP dismissed in the case of CIT v Batra Bhatta Co. v) 220 CTR 369 (Raj) CIT vs. Bigbass Maheshwari Sewa Samiti vi) 218 CTR 264 (Raj) CIT vs. Smt. Jyot…

ACIT, Jammu vs. Sh M.K. Ajat Shatru, Jammu

In the result, all the fours appeals filed by the Revenue are dismissed and the three Cross Objections as well as the ground as per Rule 27 are allowed

ITA 263/ASR/2003[1998-99]Status: DisposedITAT Delhi24 Jan 2022AY 1998-99

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

For Appellant: Shri C.S. Aggarwal, SrFor Respondent: Shri S.D. Kapila, Spl
Section 139(9)Section 147Section 148

…ore vitiated in law. 41.2 Referring to the following decisions, he submitted that surfacing of fresh material is necessary even in a case, wherein the assessment was originally made u/s 143(1) of the Act: i) 319 ITR 221 (Del) Shipra Srivastava vs. ACIT ii) 292 ITR 49 (Del) KLM Royal Dutch Airlines vs. CIT A at page 63, placitum 19 iii) 289 ITR37 (Mad) Bapalal and Company Exports vs. JCIT. At page 45 Placitum 12 iv) 321 ITR526 (Del) CIT vs. Batra Bhatta Company. SLP dismissed in the case of CIT v Batra Bhatta Co. v) 220 CTR 369 (Raj) CIT vs. Bigbass Maheshwari Sewa Samiti vi) 218 CTR 264 (Raj) CIT vs. Smt. Jyot…

ITO, Ward-17(1), New Delhi vs. Momentum Technologies P.Ltd, New Delhi

The appeal of the Revenue is dismissed

ITA 5803/DEL/2017[2012-13]Status: DisposedITAT Delhi15 Nov 2021AY 2012-13

Bench: Ms Suchitra Kamble & Sh. Prashant Maharishii.T.A. No. 5803/Del/2017 (A.Y 2012-13) (Through Video Conferencing) Vs Momentum Technologies P. Ito Ward-17(1) Ltd. B-21, Moti Nagar, Room No. 323A, C. R. Building, New Delhi New Delhi Aaccm6467C (Appellant) (Respondent)

Section 131Section 68

…Officer. The reasons given by the Tribunal are based on valid materials and evidence and we do not find any error or illegality in the order of the Tribunal so as to warrant interference.” 18. Same is also the mandate of Honourable Delhi High court in [2007] 292 ITR 49 KLM ROYAL DUTCH AIRLINES v. ASSISTANT DIRECTOR OF INCOME-TAX where in it has been held that Where an assessment has not been framed at all, it is not possible to posit that income has escaped assessment. 19. In view of this we also held that when the revised return is pending before ld AO, Time limit for picking that return for scrutiny is pending…

ITO, Ward-17(1), New Delhi vs. Momentum Technologies P.Ltd, New Delhi

In the result ground number 1, 2 of the appeal are dismissed

ITA 5802/DEL/2017[2011-12]Status: DisposedITAT Delhi31 Mar 2021AY 2011-12

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

For Appellant: Shri Kapil Goel, AdvocateFor Respondent: Ms. Aman Preet, Sr. D.R
Section 68

…g Officer. The reasons given by the Tribunal are based on valid materials and evidence and we do not find any error or illegality in the order of the Tribunal so as to warrant interference.” 18 Same is also the mandate of Honourable Delhi High court in [2007] 292 ITR 49 KLM ROYAL DUTCH AIRLINES v. ASSISTANT DIRECTOR OF INCOME-TAX where in it has been held that Where an assessment has not been framed at all, it is not possible to posit that income has escaped assessment. 19 In view of this we also held that when the revised return is pending before ld AO, Time limit for picking that return for scrutiny is pending…

Kamlesh Shantilal Jain, Chennai vs. ACIT, Chennai

In the result, appeal filed by assessee is allowed

ITA 3335/CHNY/2018[2015-16]Status: DisposedITAT Chennai23 Feb 2021AY 2015-16

Bench: Shri V.Durga Rao & Shri G.Manjunatha

For Respondent: 10.02.2021
Section 147

…tion 237 of the Act, action could not have been taken under section 147/148 of the Act. Our answer to the question, therefore, is in the negative, i.e., against the Revenue." In the case of KLM Royal Dutch Airlines Vs. Assistant Director of Income-tax [2007] 292 ITR 49 (Delhi), the Delhi High Court, following the above Supreme Court judgment, considered the scope of provision of Sections 139 and 147 of the Act and held as follows: 16 "Applying this line of decisions to the facts of the present case, the inescapable conclusion that would have to be reached is that while assessment proceedings remain inchoate, no…

M/S. Bose Corporation India Pvt. Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeal filed by the assessee is allowed

ITA 5705/DEL/2016[2008-09]Status: DisposedITAT Delhi03 Sept 2020AY 2008-09

Bench: Shri N.K. Billaiya & Shri Kuldip Singh[Assessment Year: 2008-09] Bose Corporation India Pvt. Ltd., Vs. Dcit 3Rd Floor, Plot No.4, Circle – 5(1), Salcon Aurum, Jasola District New Delhi Centre, New Delhi – 110 025 Pan No. Aaacb 3260 A [Appellant] [Respondent]

For Appellant: Shri K. M. Gupta, AdvFor Respondent: Ms Rakhi Vimal, Sr. DR
Section 143(3)Section 147Section 148Section 37(1)

…l Bench of this Court in CIT v. Usha International Ltd.(supra), specifically overruled the decision of the DB in Consolidated Photo and Finvest Ltd. v. Assistant Commissioner of Income-Tax(supra). Even prior thereto, in KLM Royal Dutch Airlines v. ADIT [2007] 292 ITR 49, another DB of this Court noticed the anomaly that had resulted from the decision in Consolidated Photo and Finvest Ltd. v. Assistant Commissioner of Income-Tax (supra), which was contrary to other decisions, including the decision of the FB in CIT v. Kelvinator of India Ltd.(supra). This was noticed by the DB in KLM Royal Dutch Airlines v. ADIT (…

DCIT (Ltu), New Delhi vs. M/S. Gail (India) Ltd., New Delhi

Accordingly, we dismiss the appeal filed by the ld AO on the limited issue that order passed by the ld AO is barred by limitation. Ground No. 1 is dismissed

ITA 6079/DEL/2016[2006-07]Status: DisposedITAT Delhi21 Jul 2020AY 2006-07

Bench: Shri Amit Shukla & Shri Prashant Maharishidcit(Ltu), Vs. M/S. Gail (India) Ltd, Circle-1, 16, Bhikaji Cama Place, Nbcc Plaza Pusp Vihar, Rk Puram, New Delhi New Delhi (Appellant) (Respondent)

For Appellant: Shri Rohit Jain, AdvFor Respondent: Ms. Sunita Singh, CIT DR
Section 143(3)Section 147Section 148Section 14ASection 263

…IT: 245 ITR 645 (Cal) 19. Mercury Travels Ltd.. Vs. DCIT: 258 ITR 533 (Cal.) 20. Berger Paints India Ltd., Vs. ACIT: 322 ITR 369 (Cal) 21. Aventis Pharma Limited, 323 ITR 570(Bom) 23. Usha International Limited, 348 ITR 485 (Del) 24. KLM Royal Dutch Airlines, 292 ITR 49 (Del) 25. Vipan Khanna, 255 ITR 220 (P&H) 26. NYK Line (India) Ltd. 68 DTR 90(Bom) 27. Bhor Industries Ltd, 267 ITR 161 (Bom) 28. Hindustan Lever Ltd, 268 ITR 332 (Bom ) 29. Bhogwati Sahakari Sakhar Karkhana Ltd, 269 ITR 186(Bom) 30. Ajanta Pharma Ltd. 267 ITR 200 (Bom ) 31. Grindwell Norton , 267 ITR 673 (Bom) 32. Feather Foam Ent.(P) Ltd. 296 IT…

The Pr. Commissioner of Income Tax -Central -1 vs. Virender Kumar Bhatia

In the result, the appeal filed by the revenue is dismissed

ITA/732/2019HC Delhi01 Nov 2019

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

Section 132Section 142Section 143(2)Section 158BSection 260A

…f the Act dated22/7/2007 was without jurisdiction held by Hon'ble Apex Court inc case of Trustees HHH, the Nizam Supplemental Family Trust Vs. CIT 242 ITR 381 and the decision of Hon'ble Delhi High Court in case of CIT Vs. KLM Royal Touch Airlines Vs. CIT 292 ITR 49. The Ld. AR contended that notice u/s 15880 of the Act was without jurisdiction since, the notice u/s 158BD dated 27/7/2007did not record any satisfaction as has been held by the Honble Delhi High Court in case of New Delhi Auto Finance Pvt. Ltd. Vs. JCIT 300 ITR 83following the judgment of the Hon'ble Apex ITA 732/2019…

Vinod Gupta, New Delhi vs. DCIT, New Delhi

In the result, both the appeal of the assessee and revenue are hereby dismissed

ITA 2378/DEL/2014[2008-09]Status: DisposedITAT Delhi28 Aug 2019AY 2008-09

Bench: Sh. H. S. Sidhudr. B. R. R. Kumarita No. 2378/Del/2014 : Asstt. Year : 2008-09 Vinod Gupta, Vs Dcit, C/O Raj Kumar & Associates, Central Circle-7, Cas, 4435/7, Ansari Road, Jhandewalan, Daryaganj, New Delhi-110002 New Delhi (Appellant) (Respondent) Pan No. Aaopg8867H Ita No. 3200/Del/2014 : Asstt. Year : 2008-09 Acit, Vs V.K. Gupta Central Circle-7, 119, Fie Indl. Area, Patparganj, Jhandewalan, Delhi-110092 New Delhi (Appellant) (Respondent) Pan No. Aaopg8867H Assessee By : Sh. Raj Kumar Gupta, Ca Revenue By : Sh. S. S. Rana, Cit Dr Date Of Hearing: 04.07.2019 Date Of Pronouncement: 28.08.2019 Order Per Dr. B. R. R. Kumar:

For Appellant: Sh. Raj Kumar Gupta, CAFor Respondent: Sh. S. S. Rana, CIT DR
Section 127Section 153Section 153ASection 153CSection 153C(1)Section 251Section 292B

…THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES ‘G’, NEW DELHI Before Sh. H. S. Sidhu, Judicial Member Dr. B. R. R. Kumar, Accountant Member ITA No. 2378/Del/2014 : Asstt. Year : 2008-09 Vinod Gupta, Vs DCIT, C/o Raj Kumar & Associates, Central Circle-7, CAs, 4435/7, Ansari Road, Jhandewalan, Daryaganj, New Delhi-110002 New Delhi (APPELLANT) (RESPONDENT) PAN No. AAOPG8867H ITA No. 3200/Del/2014 : Asstt. Year : 2008-09 ACIT, Vs V.K. Gupta Central Circle-7, 119, FIE Indl. Area, Patparganj, Jhandewalan, Delhi-110092 New Delhi (APPELLANT) (RESPONDENT) PAN No. AAOPG8867H Assessee by : Sh. Raj Kumar Gupta, CA Revenue…