Parag Dalimia v. DCIT

386 ITR 466High Court2016#3916 most cited

What is Parag Dalimia v. DCIT authority for?

Incriminating material found during a search operation, which the assessee accepts, forms a valid basis for assessment.

30

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2020 to 2024.

Also referred to as

Parag Dalimia · DCIT · search operation · incriminating material · assessment · section 153A · section 132

Sections most often in play

Section 153ASection 1961Section 271(1)(c)Section 69Section 132Section 132(4)Section 143(3)Section 142(1)

Issues it is cited on

section 90(3)section 65(b)section 65b(4)section 163section 276cash found during searchjewellery found during searchsection 153b(1)section 65bsection 65azadi bachao andolanhouse property income

Judgments citing Parag Dalimia v. DCIT

Rajinder Kumar, New Delhi vs. ACIT, Central Circle- 30, New Delhi

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 6743/DEL/2017[2006-07]Status: DisposedITAT Delhi12 Jun 2024AY 2006-07

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…rch operation, the assessee had accepted the same. This is clearly an incriminating material. In this regard, he relied on the following decisions:- a. ITA No. 5499/Del/2017 for AY 2006-07 in the case of Parag Dalimia Vs. DCIT; b. Soignee R. Kothari Vs. DCIT 386 ITR 466 (Bombay) 17. Considered the rival submissions and materials available on record, we observe that the Ld AR now raised several issues relating to the income offered ITA Nos.6743 & 6744/Del/2017 & 3623 to 3627/DEL/2016 And ITA Nos. 6767 ,6769,7756 to 7759,7760/Del/2017 Rajinder Kumar by the assessee in revised return of income, the basis of offeri…

Rajinder Kumar, New Delhi vs. ACIT, New Delhi

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 3627/DEL/2016[2012-13]Status: DisposedITAT Delhi12 Jun 2024AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…rch operation, the assessee had accepted the same. This is clearly an incriminating material. In this regard, he relied on the following decisions:- a. ITA No. 5499/Del/2017 for AY 2006-07 in the case of Parag Dalimia Vs. DCIT; b. Soignee R. Kothari Vs. DCIT 386 ITR 466 (Bombay) 17. Considered the rival submissions and materials available on record, we observe that the Ld AR now raised several issues relating to the income offered ITA Nos.6743 & 6744/Del/2017 & 3623 to 3627/DEL/2016 And ITA Nos. 6767 ,6769,7756 to 7759,7760/Del/2017 Rajinder Kumar by the assessee in revised return of income, the basis of offeri…

Rajinder Kumar, New Delhi vs. ACIT, New Delhi

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 3626/DEL/2016[2011-12]Status: DisposedITAT Delhi12 Jun 2024AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…rch operation, the assessee had accepted the same. This is clearly an incriminating material. In this regard, he relied on the following decisions:- a. ITA No. 5499/Del/2017 for AY 2006-07 in the case of Parag Dalimia Vs. DCIT; b. Soignee R. Kothari Vs. DCIT 386 ITR 466 (Bombay) 17. Considered the rival submissions and materials available on record, we observe that the Ld AR now raised several issues relating to the income offered ITA Nos.6743 & 6744/Del/2017 & 3623 to 3627/DEL/2016 And ITA Nos. 6767 ,6769,7756 to 7759,7760/Del/2017 Rajinder Kumar by the assessee in revised return of income, the basis of offeri…

Rajinder Kumar, New Delhi vs. ACIT, New Delhi

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 3625/DEL/2016[2010-11]Status: DisposedITAT Delhi12 Jun 2024AY 2010-11

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…rch operation, the assessee had accepted the same. This is clearly an incriminating material. In this regard, he relied on the following decisions:- a. ITA No. 5499/Del/2017 for AY 2006-07 in the case of Parag Dalimia Vs. DCIT; b. Soignee R. Kothari Vs. DCIT 386 ITR 466 (Bombay) 17. Considered the rival submissions and materials available on record, we observe that the Ld AR now raised several issues relating to the income offered ITA Nos.6743 & 6744/Del/2017 & 3623 to 3627/DEL/2016 And ITA Nos. 6767 ,6769,7756 to 7759,7760/Del/2017 Rajinder Kumar by the assessee in revised return of income, the basis of offeri…

Rajinder Kumar, New Delhi vs. ACIT, New Delhi

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 3624/DEL/2016[2009-10]Status: DisposedITAT Delhi12 Jun 2024AY 2009-10

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…rch operation, the assessee had accepted the same. This is clearly an incriminating material. In this regard, he relied on the following decisions:- a. ITA No. 5499/Del/2017 for AY 2006-07 in the case of Parag Dalimia Vs. DCIT; b. Soignee R. Kothari Vs. DCIT 386 ITR 466 (Bombay) 17. Considered the rival submissions and materials available on record, we observe that the Ld AR now raised several issues relating to the income offered ITA Nos.6743 & 6744/Del/2017 & 3623 to 3627/DEL/2016 And ITA Nos. 6767 ,6769,7756 to 7759,7760/Del/2017 Rajinder Kumar by the assessee in revised return of income, the basis of offeri…

Rajinder Kumar, New Delhi vs. ACIT, New Delhi

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 3623/DEL/2016[2008-09]Status: DisposedITAT Delhi12 Jun 2024AY 2008-09

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…rch operation, the assessee had accepted the same. This is clearly an incriminating material. In this regard, he relied on the following decisions:- a. ITA No. 5499/Del/2017 for AY 2006-07 in the case of Parag Dalimia Vs. DCIT; b. Soignee R. Kothari Vs. DCIT 386 ITR 466 (Bombay) 17. Considered the rival submissions and materials available on record, we observe that the Ld AR now raised several issues relating to the income offered ITA Nos.6743 & 6744/Del/2017 & 3623 to 3627/DEL/2016 And ITA Nos. 6767 ,6769,7756 to 7759,7760/Del/2017 Rajinder Kumar by the assessee in revised return of income, the basis of offeri…

ACIT, New Delhi vs. Sh. Rajinder Kumar, New Delhi

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 3368/DEL/2016[2010-11]Status: DisposedITAT Delhi12 Jun 2024AY 2010-11

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…rch operation, the assessee had accepted the same. This is clearly an incriminating material. In this regard, he relied on the following decisions:- a. ITA No. 5499/Del/2017 for AY 2006-07 in the case of Parag Dalimia Vs. DCIT; b. Soignee R. Kothari Vs. DCIT 386 ITR 466 (Bombay) 17. Considered the rival submissions and materials available on record, we observe that the Ld AR now raised several issues relating to the income offered ITA Nos.6743 & 6744/Del/2017 & 3623 to 3627/DEL/2016 And ITA Nos. 6767 ,6769,7756 to 7759,7760/Del/2017 Rajinder Kumar by the assessee in revised return of income, the basis of offeri…

Devinder Singh Sahney, Mumbai vs. ITO (It) 4(2)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 1585/MUM/2017[2006-07]Status: DisposedITAT Mumbai02 Apr 2024AY 2006-07

Bench: SHRI VIKAS AWASTHY, JUDICIAL MEMBER & SHRIGAGAN GOYAL (Accountant Member)

For Appellant: Shri P.J.Pardiwal, Sr. Advocate with S/Shri Madhur Agrawal, Fenil Bhatt &For Respondent: S/Shri Miland Chavan & Anil Sant, Sr. DRs
Section 142(1)Section 147Section 148

…rnished Consent Waiver Form, thereafter, it was for the bank to deny that the assessee is not having bank account. The ld. Departmental Representative placed reliance on the following decisions in support of his arguments. 10 (i) Soignee R. Kothari vs. DCIT, 386 ITR 466(Bom); (ii) Renu T. Tharani vs. DCIT, 117 taxmann.com, 804 (Mum-Trib); & (iii) Mohan Manaj Dhupelia vs. DCIT, ITA No.3544/Mum/2011 A.Y.2002-03 decided on 31/10/2014. 4. Controverting the submissions made on behalf of the Department, the ld.Counsel for the assessee submitted that the case laws own which reliance has been placed by the Department a…

Mrs. Renu Tikamdas Tharani, Mumbai vs. DCIT (It)-4(2)(1), Mumbai

ITA 2334/MUM/2018[2007-08]Status: DisposedITAT Mumbai30 Oct 2023AY 2007-08
For Appellant: Shri Mukesh AdvaniFor Respondent: Shri Anil Sant
Section 143(3)Section 147Section 148

…IN THE INCOME TAX APPELLATE TRIBUNAL "I" BENCH, MUMBAI SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER Mrs. Renu Tikamdas Tharani, 1 Prabhat Building, 28 B Road, Churchagate, Mumbai - 400020 [PAN: AAXPT4838Q] …………… Appellant Vs Deputy Commissioner of Income Tax, (International Taxation) 4(2)(1), Room No. 1708, Air India Building, Respondent ……………. Mumbai - 400021 Appearance For the Appellant/Assessee : Shri Mukesh Advani For the Respondent/Department : Shri Anil Sant Date Conclusion of hearing : 17.08.2023 Pronouncement of order : 30.10.2023 O R D E R Per Rahul Chaudhary, Judici…

Mrs. Renu Tikamdas Tharani, Mumbai vs. DCIT (It)-4(2)(1), Mumbai

ITA 2333/MUM/2018[2006-07]Status: DisposedITAT Mumbai16 Jul 2020AY 2006-07
Section 127Section 143(3)Section 147Section 148

…judgment of Hon‟ble jurisdictional High Court on materially similar facts, wherein Their Lordships has disapproved and deprecated the conduct of the assessee in not signing the consent waiver form, in the judgment reported as Soignee R Kothari Vs DCIT [(2016) 386 ITR 466 (Bom)]. That was also a case in which the assessee, originally a resident in India, had migrated to the USA. The information by way of a „base note‟ was received from the French Government, under the DTAA mechanism- as in this case, about existence of her bank account with the same bank, i.e. HSBC Private Bank (Suisse) SA, Geneva. In this case, a…