PCIT v. Best Infrastructure (India) (P.) Ltd.

ITA 1165/BANG/2023[2015-16]Status: DisposedITAT Bangalore10 Jun 2024AY 2015-16

…ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.1163 to 1165/Bang/2023 Assessment Years: 2013-14 to 2015-16 M/s. Ramachandra Setty & Sons ITO SRS Building Ward-1 BM Road Vs. Hassan Hassan 573 201 PAN NO : AAEFS4881R APPELLANT RESPONDENT ITA Nos.1166/Bang/2023 Assessment Year: 2017-18 M/s. Ramachandra Setty & Sons ITO SRS Building Ward-1 BM Road Vs. Hassan Hassan 573 201 PAN NO : AAEFS4881R APPELLANT RESPONDENT ITA Nos.…

Income Tax Officer, W-1, Vijayanagar vs. Ramachandra Setty and Sons, Hassan

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R

ITA 1164/BANG/2023[2014-15]Status: DisposedITAT Bangalore10 Jun 2024AY 2014-15

…ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.1163 to 1165/Bang/2023 Assessment Years: 2013-14 to 2015-16 M/s. Ramachandra Setty & Sons ITO SRS Building Ward-1 BM Road Vs. Hassan Hassan 573 201 PAN NO : AAEFS4881R APPELLANT RESPONDENT ITA Nos.1166/Bang/2023 Assessment Year: 2017-18 M/s. Ramachandra Setty & Sons ITO SRS Building Ward-1 BM Road Vs. Hassan Hassan 573 201 PAN NO : AAEFS4881R APPELLANT RESPONDENT ITA Nos.…

Income Tax Officer Ward-1 Hassan, Hassan vs. Ramachandra Setty and Songs, Hassan

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R

ITA 1163/BANG/2023[2013-14]Status: DisposedITAT Bangalore10 Jun 2024AY 2013-14

…ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.1163 to 1165/Bang/2023 Assessment Years: 2013-14 to 2015-16 M/s. Ramachandra Setty & Sons ITO SRS Building Ward-1 BM Road Vs. Hassan Hassan 573 201 PAN NO : AAEFS4881R APPELLANT RESPONDENT ITA Nos.1166/Bang/2023 Assessment Year: 2017-18 M/s. Ramachandra Setty & Sons ITO SRS Building Ward-1 BM Road Vs. Hassan Hassan 573 201 PAN NO : AAEFS4881R APPELLANT RESPONDENT ITA Nos.…

Income Tax Officer, W-1, Hassan vs. Ramachandra Setty & Sons, Hassan

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R

ITA 1156/BANG/2023[2017-18]Status: DisposedITAT Bangalore10 Jun 2024AY 2017-18

…ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.1163 to 1165/Bang/2023 Assessment Years: 2013-14 to 2015-16 M/s. Ramachandra Setty & Sons ITO SRS Building Ward-1 BM Road Vs. Hassan Hassan 573 201 PAN NO : AAEFS4881R APPELLANT RESPONDENT ITA Nos.1166/Bang/2023 Assessment Year: 2017-18 M/s. Ramachandra Setty & Sons ITO SRS Building Ward-1 BM Road Vs. Hassan Hassan 573 201 PAN NO : AAEFS4881R APPELLANT RESPONDENT ITA Nos.…

M/S. S. Ramashandra Setty & Sons, Hassan vs. Income Tax Officer, Ward-1, Hassan

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R

ITA 374/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh16 May 2024AY 2012-13

…ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.1163 to 1165/Bang/2023 Assessment Years: 2013-14 to 2015-16 M/s. Ramachandra Setty & Sons ITO SRS Building Ward-1 BM Road Vs. Hassan Hassan 573 201 PAN NO : AAEFS4881R APPELLANT RESPONDENT ITA Nos.1166/Bang/2023 Assessment Year: 2017-18 M/s. Ramachandra Setty & Sons ITO SRS Building Ward-1 BM Road Vs. Hassan Hassan 573 201 PAN NO : AAEFS4881R APPELLANT RESPONDENT ITA Nos.…

M/S Jain Amar Clothing Pvt. Ltd., Ludhiana vs. DCIT, CC-III, Ludhiana

In the result, the ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Rohit Sharma, CIT DR

Section 143(3)Section 153ASection 263Section 68

…ot be said to be incriminating evidence by itself as found during the course of search as held in various decisions and in this regard, reliance was placed on the decisions of Hon’ble Delhi High Court in case of Pr. CIT Vs. Best Infrastructure India Pvt. Ltd. 397 ITR 82 (Del), CIT Vs. Harjeev Aggarwal 290 CTR 263 (Del), Jaipur Benches of the Tribunal in case of DCIT Vs. A M Exports 69 ITR (Trib)16 (Jaipur Trib), and Delhi Benches in case of Brahmaputra Finlease P. Ltd. Vs. DCIT 51 CCH 796(Del Trib) and Rathi Steel Ltd. Vs. ACIT 56 CCH 102 (Del Trib). 9.6 Regarding the findings of the Ld. CIT(A), point wise rebut…

DCIT, Central Circle, Noida vs. Pgp Charitable Trust, Delhi

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

ITA 471/DEL/2019[2011-12]Status: DisposedITAT Delhi01 May 2024AY 2011-12

Bench: Shri Amit Shukla & Shri M. Balaganesh

Section 12ASection 132Section 153C

…the statement recorded during the course of search cannot constitute incriminating material. Reliance in this regard is rightly placed on the decision of Hon’ble Jurisdictional High Court in the case of PCIT vs Best Infrastructure (India) (P) Ltd reported in 397 ITR 82 (Del). It is not in dispute that the Asst Years 2010-11 and 2011-12 fall under the category of unabated assessments even if construed as on the date of search in Maconns, Meenu and Yadav Singh group on 27.11.2014 or even if construed from the date of satisfaction note recorded, which would be the date of search qua the assessee herein. In either…

DCIT, Central Circle, Noida vs. Pgp Charitable Trust, Delhi

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

ITA 470/DEL/2019[2010-11]Status: DisposedITAT Delhi01 May 2024AY 2010-11

Bench: Shri Amit Shukla & Shri M. Balaganesh

Section 12ASection 132Section 153C

…the statement recorded during the course of search cannot constitute incriminating material. Reliance in this regard is rightly placed on the decision of Hon’ble Jurisdictional High Court in the case of PCIT vs Best Infrastructure (India) (P) Ltd reported in 397 ITR 82 (Del). It is not in dispute that the Asst Years 2010-11 and 2011-12 fall under the category of unabated assessments even if construed as on the date of search in Maconns, Meenu and Yadav Singh group on 27.11.2014 or even if construed from the date of satisfaction note recorded, which would be the date of search qua the assessee herein. In either…

Dy. Commissioner of Income Tax, Central Circle-3(3), Mumbai vs. Avaada Ventures Private Limited, Mumbai

In the result, all the appeals of the Revenue are dismissed as well as Cross Objections of the assessee are dismissed as infructuous

ITA 4342/MUM/2023[2017]Status: DisposedITAT Mumbai05 Apr 2024

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI S RIFAUR RAHMAN (Accountant Member)

Section 132Section 132(4)Section 139(1)Section 143(3)Section 153A

…ich are retracted subsequently to not form the sole basis for computing undisclosed income of an assessee. M/s. Avaada Ventures Pvt. Ltd 9.20.2 Similar decision has been rendered by Delhi High Court in the case of PCIT Vs Best Infrastructure Private Limited, 397 ITR 82 wherein it was held as under 38. Fifthly, statements recorded under Section 132 (4) of the Act of the Act do not by themselves constitute incriminating material as has been explained by this Court in Commissioner of Income Tax v. Hajeev Aggarwal (supra) Lastly, as already pointed out hereinbefore, the facts in the present case arm different from t…

DCIT, Central Circle- 3(3), Mumbai vs. Avaada Ventures Pvt. Ltd, Mumbai

In the result, all the appeals of the Revenue are

ITA 2749/MUM/2023[2013-14]Status: DisposedITAT Mumbai05 Apr 2024AY 2013-14

Section 132Section 132(4)Section 139(1)Section 143(3)Section 153A

…ensure that such statements, which are retracted subsequently to not form the sole basis for computing undisclosed income of an assessee. 9.20.2 Similar decision has been rendered by Delhi High Court in the case of PCIT Vs Best Infrastructure Private Limited, 397 ITR 82 wherein it was held as under 38. Fifthly, statements recorded under Section 132 (4) of the Act of the Act do not by themselves constitute incriminating material as has been explained by this Court in Commissioner of Income Tax v. Hajeev Aggarwal (supra) Lastly, as already pointed out hereinbefore, the facts in the present case arm different from t…

Sri Prakash Bhajandas Talreja, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bengaluru

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

ITA 1065/BANG/2023[2017-18]Status: DisposedITAT Bangalore22 Mar 2024AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri G. Manoj Kumar, D.R

ITA 1064/BANG/2023[2016-17]Status: HeardITAT Bangalore22 Mar 2024AY 2016-17

…rovided an opportunity to cross-examine the person who has given statement. Reliance is placed on the Hon'ble Delhi High Court in Principal Commissioner of Income-tax, Delhi-2 v. Best Infrastructure (India) (P.) Ltd' [2017] 84 taxmann.com 287 (Delhi) / [2017] 397 ITR 82 (Delhi). 9.24 The Hon'ble Tribunal in M/S Fateh Chand Charitable Trust CIT (Exemptions) Lucknow 2016 (4) TMI 1119 - ITAT Lucknow / (20161 49 ITR Trib) 276 held that it is settled position of law that any evidence collected at the back of the assessee cannot be used adversely unless and until it is confronted to the assessee and the assessee is all…

Sri Prakash Bhajandas Talreja, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bengaluru

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri G. Manoj Kumar, D.R

ITA 1062/BANG/2023[2015-16]Status: DisposedITAT Bangalore22 Mar 2024AY 2015-16

…rovided an opportunity to cross-examine the person who has given statement. Reliance is placed on the Hon'ble Delhi High Court in Principal Commissioner of Income-tax, Delhi-2 v. Best Infrastructure (India) (P.) Ltd' [2017] 84 taxmann.com 287 (Delhi) / [2017] 397 ITR 82 (Delhi). 9.24 The Hon'ble Tribunal in M/S Fateh Chand Charitable Trust CIT (Exemptions) Lucknow 2016 (4) TMI 1119 - ITAT Lucknow / (20161 49 ITR Trib) 276 held that it is settled position of law that any evidence collected at the back of the assessee cannot be used adversely unless and until it is confronted to the assessee and the assessee is all…

Sri Prakash Bhajandas Talreja, Bengaluru vs. Deputy Commissioner of Income-Tax, Central Circle-1(3), Bengaluru

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri G. Manoj Kumar, D.R

ITA 1061/BANG/2023[2014-15]Status: DisposedITAT Bangalore22 Mar 2024AY 2014-15

…rovided an opportunity to cross-examine the person who has given statement. Reliance is placed on the Hon'ble Delhi High Court in Principal Commissioner of Income-tax, Delhi-2 v. Best Infrastructure (India) (P.) Ltd' [2017] 84 taxmann.com 287 (Delhi) / [2017] 397 ITR 82 (Delhi). 9.24 The Hon'ble Tribunal in M/S Fateh Chand Charitable Trust CIT (Exemptions) Lucknow 2016 (4) TMI 1119 - ITAT Lucknow / (20161 49 ITR Trib) 276 held that it is settled position of law that any evidence collected at the back of the assessee cannot be used adversely unless and until it is confronted to the assessee and the assessee is all…

Sri Prakash Bhajandas Talreja, Bengaluru vs. Deputy Commissioner of Income-Tax, Central Circle-1(3), Bengaluru

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri G. Manoj Kumar, D.R

ITA 1784/DEL/2022[2013-14]Status: DisposedITAT Delhi06 Mar 2024AY 2013-14

…rovided an opportunity to cross-examine the person who has given statement. Reliance is placed on the Hon'ble Delhi High Court in Principal Commissioner of Income-tax, Delhi-2 v. Best Infrastructure (India) (P.) Ltd' [2017] 84 taxmann.com 287 (Delhi) / [2017] 397 ITR 82 (Delhi). 9.24 The Hon'ble Tribunal in M/S Fateh Chand Charitable Trust CIT (Exemptions) Lucknow 2016 (4) TMI 1119 - ITAT Lucknow / (20161 49 ITR Trib) 276 held that it is settled position of law that any evidence collected at the back of the assessee cannot be used adversely unless and until it is confronted to the assessee and the assessee is all…

ACIT, Central Circle-28, New Delhi vs. Stonex India Pvt Ltd, Delhi

In the result, the appeal of the Revenue is dismissed

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia

For Appellant: Shri Gaurav Jain, AdvocateFor Respondent: Shri H.K. Choudhary, CIT-DR

Section 132Section 133(6)Section 139(1)Section 142(1)Section 143(3)Section 153ASection 68

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “G” DELHI BEFORE SHRI KUL BHARAT, JUDICIAL MEMBER & SHRI PRADIP KUMAR KEDIA, ACCOUNTANT MEMBER I.T.A. No.1784/DEL/2022 Assessment Year 2013-14 ACIT Stonex India Pvt. Ltd. Central Circle-28 Vs. D-176 West Delhi Mansarover Garden New Delhi S.O. Delhi Delh. TAN/PAN: AACCG9620R (Appellant) (Respondent) Appellant by: Shri Gaurav Jain, Advocate Ms. Sweta Bansal, CA Respondent by: Shri H.K. Choudhary, CIT-DR Date of hearing: 18 01 2024 Date of pronouncement: 06 03 2024 O R D E R PER PRADIP KUMAR KEDIA-A.M. : The captioned appeal is directed against the first appella…

Sh. Vibhav Jain, Ludhiana vs. DCIT, CC-III, Ludhiana

In the result, the ground no

ITA 355/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh16 Feb 2024AY 2013-14

Bench: SHRI. SANJAY GARG (Judicial Member), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Kusum Bansal, CIT DR

Section 10(36)Section 10(38)Section 143(1)Section 143(2)Section 153A

…ot be said to be incriminating evidence by itself as found during the course of search as held in various decisions and in this regard, reliance was placed on the decisions of Hon’ble Delhi High Court in case of Pr. CIT Vs. Best Infrastructure India Pvt. Ltd. 397 ITR 82 (Del), CIT Vs. Harjeev Aggarwal 290 CTR 263 (Del), Jaipur Benches of the Tribunal in case of DCIT Vs. A M Exports 69 ITR (Trib)16 (Jaipur Trib), and Delhi Benches in case of Brahmaputra Finlease P. Ltd. Vs. DCIT 51 CCH 796(Del Trib) and Rathi Steel Ltd. Vs. ACIT 56 CCH 102 (Del Trib). 9.5 Regarding the findings of the Ld. CIT(A), it was submitted…

Sh. Bipan Jain, Ludhiana vs. DCIT, CC-III, Ludhiana

In the result, the ground no

ITA 354/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh23 Jan 2024AY 2013-14

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Rohit Sharma, CIT DR

ITA 353/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh23 Jan 2024AY 2013-14

…ot be said to be incriminating evidence by itself as found during the course of search as held in various decisions and in this regard, reliance was placed on the decisions of Hon’ble Delhi High Court in case of Pr. CIT Vs. Best Infrastructure India Pvt. Ltd. 397 ITR 82 (Del), CIT Vs. Harjeev Aggarwal 290 CTR 263 (Del), Jaipur Benches of the Tribunal in case of DCIT Vs. A M Exports 69 ITR (Trib)16 (Jaipur Trib), and Delhi Benches in case of Brahmaputra Finlease P. Ltd. Vs. DCIT 51 CCH 796(Del Trib) and Rathi Steel Ltd. Vs. ACIT 56 CCH 102 (Del Trib). 10.5 Regarding the findings of the Ld. CIT(A), it was submitted…

Sh. Ashish Jain, Ludhiana vs. DCIT, CC-III, Ludhiana

In the result, the ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Rohit Sharma, CIT DR

ITA 352/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh23 Jan 2024AY 2012-13

…ot be said to be incriminating evidence by itself as found during the course of search as held in various decisions and in this regard, reliance was placed on the decisions of Hon’ble Delhi High Court in case of Pr. CIT Vs. Best Infrastructure India Pvt. Ltd. 397 ITR 82 (Del), CIT Vs. Harjeev Aggarwal 290 CTR 263 (Del), Jaipur Benches of the Tribunal in case of DCIT Vs. A M Exports 69 ITR (Trib)16 (Jaipur Trib), and Delhi Benches in case of Brahmaputra Finlease P. Ltd. Vs. DCIT 51 CCH 796(Del Trib) and Rathi Steel Ltd. Vs. ACIT 56 CCH 102 (Del Trib). 10.5 Regarding the findings of the Ld. CIT(A), it was submitted…

Sh. Ashish Jain, Ludhiana vs. DCIT, CC-III, Ludhiana

In the result, the ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Rohit Sharma, CIT DR

ITA 351/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh23 Jan 2024AY 2013-14

…ot be said to be incriminating evidence by itself as found during the course of search as held in various decisions and in this regard, reliance was placed on the decisions of Hon’ble Delhi High Court in case of Pr. CIT Vs. Best Infrastructure India Pvt. Ltd. 397 ITR 82 (Del), CIT Vs. Harjeev Aggarwal 290 CTR 263 (Del), Jaipur Benches of the Tribunal in case of DCIT Vs. A M Exports 69 ITR (Trib)16 (Jaipur Trib), and Delhi Benches in case of Brahmaputra Finlease P. Ltd. Vs. DCIT 51 CCH 796(Del Trib) and Rathi Steel Ltd. Vs. ACIT 56 CCH 102 (Del Trib). 10.5 Regarding the findings of the Ld. CIT(A), it was submitted…

Sh. Akhil Jain, Ludhiana vs. DCIT, CC-III, Ludhiana

In the result, the ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Rohit Sharma, CIT DR