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
…cases no unaccounted source could be established which might be correlated with these purely estimates hence this addition was made independently in the absence of any evidence, material or corroboration. In Sneh Enterprises Vs. Commissioner of Customs (2006) 7 SCC 714, 721, it was held ‘while dealing with a taxing provision, the principle of strict interpretation should be applied. The court shall not interpret the statutory provision in such a manner which would create an additional fiscal burden on a person. It would never be done by invoking the provisions of another act, which are not attracted. It is also t…