PCIT v. KBCL

KRISHAK BHARTI COOPERATIVE LTD,NEW DELHI vs. ACIT, CENTRAL CIRCLE-30, NEW DELHI

In the result, assessee’s appeals for A

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharata.Y. 2017-18 & A.Y. 2018-19

…uarely covered in favour of the assessee in its own case for A.Y. 2010-11, wherein the Hon’ble Supreme Court in Civil Appeal No. 836/2018 dated 15.09.2023 dismissed the department’s appeal and upheld the order of Hon’ble Delhi High Court reported as (2017) 395 ITR 572 (Delhi). A copy of order of Hon’ble Supreme Court has also been placed on record. He also submitted that relying on the order of Hon’ble High Court the Coordinate Bench in assessee’s own case for A.Y. 2016-17, has decided the issue in favour of assessee. 16. Learned DR opposed the submissions. He, however, could not controvert the factual posit…

KRISHAK BHARATI COOPERATIVE LIMITED,NEW DELHI vs. ACIT CENTRAL CIRCLE 30, NEW DELHI

In the result, assessee’s appeals for A

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharata.Y. 2017-18 & A.Y. 2018-19

…uarely covered in favour of the assessee in its own case for A.Y. 2010-11, wherein the Hon’ble Supreme Court in Civil Appeal No. 836/2018 dated 15.09.2023 dismissed the department’s appeal and upheld the order of Hon’ble Delhi High Court reported as (2017) 395 ITR 572 (Delhi). A copy of order of Hon’ble Supreme Court has also been placed on record. He also submitted that relying on the order of Hon’ble High Court the Coordinate Bench in assessee’s own case for A.Y. 2016-17, has decided the issue in favour of assessee. 16. Learned DR opposed the submissions. He, however, could not controvert the factual posit…

DCIT, CENTRAL CIRCLE-30, NEW DELHI vs. KRISHAK BHARATI COOPERATIVE LTD, DELHI

In the result, assessee’s appeals for A

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharata.Y. 2017-18 & A.Y. 2018-19

…uarely covered in favour of the assessee in its own case for A.Y. 2010-11, wherein the Hon’ble Supreme Court in Civil Appeal No. 836/2018 dated 15.09.2023 dismissed the department’s appeal and upheld the order of Hon’ble Delhi High Court reported as (2017) 395 ITR 572 (Delhi). A copy of order of Hon’ble Supreme Court has also been placed on record. He also submitted that relying on the order of Hon’ble High Court the Coordinate Bench in assessee’s own case for A.Y. 2016-17, has decided the issue in favour of assessee. 16. Learned DR opposed the submissions. He, however, could not controvert the factual posit…

DCIT,CENTRAL CIRCLE-30, NEW DELHI vs. KRISHAK BHARATI COOPERATIVE LTD., DELHI

In the result, assessee’s appeals for A

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharata.Y. 2017-18 & A.Y. 2018-19

…uarely covered in favour of the assessee in its own case for A.Y. 2010-11, wherein the Hon’ble Supreme Court in Civil Appeal No. 836/2018 dated 15.09.2023 dismissed the department’s appeal and upheld the order of Hon’ble Delhi High Court reported as (2017) 395 ITR 572 (Delhi). A copy of order of Hon’ble Supreme Court has also been placed on record. He also submitted that relying on the order of Hon’ble High Court the Coordinate Bench in assessee’s own case for A.Y. 2016-17, has decided the issue in favour of assessee. 16. Learned DR opposed the submissions. He, however, could not controvert the factual posit…

DCIT CENTRAL CIRCLE-30, DELHI vs. KRISHAK BHARTI COOPERATIVE LTD. , DELHI

In the result the appeal of the Revenue is dismissed

Bench: Shri N.K. Billaiya & Shri Kul Bharat

…i, Ground Nos. 1 and 2 are dismissed. 13. Ground No. 3 relates to the deletion of disallowance of deemed tax credit of Rs. 18,06,24,855/- by the Assessing Officer. 14. This issue was also decided by the Hon'ble High Court of Delhi in assessee’s own case in 395 ITR 572. The relevant findings of the Hon'ble High Court read as under: “The second question: Did the ITAT err in deciding that dividend income was taxable but exempt under Omani law to entitle the assessee to the benefits of the Indo Oman DTAA. 24. The rival contentions on this aspect are whether dividend income is at all taxable or if it taxable, but…

KRISHAK BHARTI COOPERATIVE LIMITED ,DELHI vs. ACIT, CIRCLE 29(1), DELHI

In the result the appeal of the Revenue is dismissed

Bench: Shri N.K. Billaiya & Shri Kul Bharat

…i, Ground Nos. 1 and 2 are dismissed. 13. Ground No. 3 relates to the deletion of disallowance of deemed tax credit of Rs. 18,06,24,855/- by the Assessing Officer. 14. This issue was also decided by the Hon'ble High Court of Delhi in assessee’s own case in 395 ITR 572. The relevant findings of the Hon'ble High Court read as under: “The second question: Did the ITAT err in deciding that dividend income was taxable but exempt under Omani law to entitle the assessee to the benefits of the Indo Oman DTAA. 24. The rival contentions on this aspect are whether dividend income is at all taxable or if it taxable, but…

ACIT, CIRCLE- 29(1), NEW DELHI vs. KRISHAK BHARATI COOPERATIVE LTD.,, NEW DELHI

In the result, the appeals of the assessee are allowed and that of the Revenue are dismissed

Bench: Sh. N. K. Choudharydr. B. R. R. Kumarita No. 6364/Del/2018 : Asstt. Year : 2013-14 Ita No. 6365/Del/2018 : Asstt. Year : 2014-15 M/S Krishak Bharati Cooperative Ltd., Vs Acit, A-60, Kailash Colony, Circle-30(1), New Delhi-110048 New Delhi-110002 (Appellant) (Respondent) Pan No. Aaaak0203G Ita No. 7241/Del/2018 : Asstt. Year : 2013-14 Ita No. 7242/Del/2018 : Asstt. Year : 2014-15 Acit, Vs M/S Krishak Bharati Cooperative Ltd., Circle-29(1), A-60, Kailash Colony, New Delhi-110002 New Delhi-110048 (Appellant) (Respondent) Pan No. Aaaak0203G Assessee By : Sh. K.V.S.R. Krishna, Ca & Sh. Aman Goel, Ca Revenue By : Ms. Sapna Bhatia, Cit Dr & Sh. Ravi Kant Choudhary, Sr. Dr Date Of Hearing: 01.09.2022 Date Of Pronouncement: 14.11.2022

…Supreme Court against the order of Hon’ble High Court. Thus, we find that the decision of the Hon’ble High Court which confirmed the order of the ITAT is binding as of now. 13. The Hon’ble High Court vide order dated 21.04.2017 in the case of PCIT Vs. KBCL (395 ITR 572), after examining the facts and the DTAA between India and Oman held that the assessee is entitled for the tax credit. The ld. CIT(A) has prudently deleted the addition in deference to the order of the Hon’ble High Court. Hence, we decline to interfere with the order of the ld. CIT(A) on this issue. ITA Nos. 6364 & 6365/Del/2018 Krishak Bharat…

ACIT, CIRCLE- 29(1), NEW DELHI vs. KRISHAK BHARATI COOPERATIVE LTD.,, NEW DELHI

In the result, the appeals of the assessee are allowed and that of the Revenue are dismissed

Bench: Sh. N. K. Choudharydr. B. R. R. Kumarita No. 6364/Del/2018 : Asstt. Year : 2013-14 Ita No. 6365/Del/2018 : Asstt. Year : 2014-15 M/S Krishak Bharati Cooperative Ltd., Vs Acit, A-60, Kailash Colony, Circle-30(1), New Delhi-110048 New Delhi-110002 (Appellant) (Respondent) Pan No. Aaaak0203G Ita No. 7241/Del/2018 : Asstt. Year : 2013-14 Ita No. 7242/Del/2018 : Asstt. Year : 2014-15 Acit, Vs M/S Krishak Bharati Cooperative Ltd., Circle-29(1), A-60, Kailash Colony, New Delhi-110002 New Delhi-110048 (Appellant) (Respondent) Pan No. Aaaak0203G Assessee By : Sh. K.V.S.R. Krishna, Ca & Sh. Aman Goel, Ca Revenue By : Ms. Sapna Bhatia, Cit Dr & Sh. Ravi Kant Choudhary, Sr. Dr Date Of Hearing: 01.09.2022 Date Of Pronouncement: 14.11.2022

…Supreme Court against the order of Hon’ble High Court. Thus, we find that the decision of the Hon’ble High Court which confirmed the order of the ITAT is binding as of now. 13. The Hon’ble High Court vide order dated 21.04.2017 in the case of PCIT Vs. KBCL (395 ITR 572), after examining the facts and the DTAA between India and Oman held that the assessee is entitled for the tax credit. The ld. CIT(A) has prudently deleted the addition in deference to the order of the Hon’ble High Court. Hence, we decline to interfere with the order of the ld. CIT(A) on this issue. ITA Nos. 6364 & 6365/Del/2018 Krishak Bharat…

KRISHAK BHARATI COOPERATIVE LTD.,,NEW DELHI vs. ACIT, CIRCLE- 30(1), NEW DELHI

In the result, the appeals of the assessee are allowed and that of the Revenue are dismissed

Bench: Sh. N. K. Choudharydr. B. R. R. Kumarita No. 6364/Del/2018 : Asstt. Year : 2013-14 Ita No. 6365/Del/2018 : Asstt. Year : 2014-15 M/S Krishak Bharati Cooperative Ltd., Vs Acit, A-60, Kailash Colony, Circle-30(1), New Delhi-110048 New Delhi-110002 (Appellant) (Respondent) Pan No. Aaaak0203G Ita No. 7241/Del/2018 : Asstt. Year : 2013-14 Ita No. 7242/Del/2018 : Asstt. Year : 2014-15 Acit, Vs M/S Krishak Bharati Cooperative Ltd., Circle-29(1), A-60, Kailash Colony, New Delhi-110002 New Delhi-110048 (Appellant) (Respondent) Pan No. Aaaak0203G Assessee By : Sh. K.V.S.R. Krishna, Ca & Sh. Aman Goel, Ca Revenue By : Ms. Sapna Bhatia, Cit Dr & Sh. Ravi Kant Choudhary, Sr. Dr Date Of Hearing: 01.09.2022 Date Of Pronouncement: 14.11.2022

…Supreme Court against the order of Hon’ble High Court. Thus, we find that the decision of the Hon’ble High Court which confirmed the order of the ITAT is binding as of now. 13. The Hon’ble High Court vide order dated 21.04.2017 in the case of PCIT Vs. KBCL (395 ITR 572), after examining the facts and the DTAA between India and Oman held that the assessee is entitled for the tax credit. The ld. CIT(A) has prudently deleted the addition in deference to the order of the Hon’ble High Court. Hence, we decline to interfere with the order of the ld. CIT(A) on this issue. ITA Nos. 6364 & 6365/Del/2018 Krishak Bharat…

KRISHAK BHARATI COOPERATIVE LTD.,,NEW DELHI vs. ACIT, CIRCLE- 30(1), NEW DELHI

In the result, the appeals of the assessee are allowed and that of the Revenue are dismissed

Bench: Sh. N. K. Choudharydr. B. R. R. Kumarita No. 6364/Del/2018 : Asstt. Year : 2013-14 Ita No. 6365/Del/2018 : Asstt. Year : 2014-15 M/S Krishak Bharati Cooperative Ltd., Vs Acit, A-60, Kailash Colony, Circle-30(1), New Delhi-110048 New Delhi-110002 (Appellant) (Respondent) Pan No. Aaaak0203G Ita No. 7241/Del/2018 : Asstt. Year : 2013-14 Ita No. 7242/Del/2018 : Asstt. Year : 2014-15 Acit, Vs M/S Krishak Bharati Cooperative Ltd., Circle-29(1), A-60, Kailash Colony, New Delhi-110002 New Delhi-110048 (Appellant) (Respondent) Pan No. Aaaak0203G Assessee By : Sh. K.V.S.R. Krishna, Ca & Sh. Aman Goel, Ca Revenue By : Ms. Sapna Bhatia, Cit Dr & Sh. Ravi Kant Choudhary, Sr. Dr Date Of Hearing: 01.09.2022 Date Of Pronouncement: 14.11.2022

…Supreme Court against the order of Hon’ble High Court. Thus, we find that the decision of the Hon’ble High Court which confirmed the order of the ITAT is binding as of now. 13. The Hon’ble High Court vide order dated 21.04.2017 in the case of PCIT Vs. KBCL (395 ITR 572), after examining the facts and the DTAA between India and Oman held that the assessee is entitled for the tax credit. The ld. CIT(A) has prudently deleted the addition in deference to the order of the Hon’ble High Court. Hence, we decline to interfere with the order of the ld. CIT(A) on this issue. ITA Nos. 6364 & 6365/Del/2018 Krishak Bharat…

ACIT, CIRCLE-31(1), NEW DELHI vs. INDIAN FARMERS FERTILISER COOPERATIVE LTD.,, NEW DELHI

The appeal of the revenue is dismissed

Bench: Sh. N.K.Billaiya & Sh. Anubhav Sharmaasstt. Commissioner Of Income Vs. M/S. Indian Farmer Fertilizer Tax, Co-Operative Ltd. Circle -31(1), Iffco Sadan, C-1, New Delhi District Centre, Saket Place, New Delhi Pan- Aaaai0050M (Appellant) (Respondent)

…indings of CIT(A) have become final as the assessee’s appeal ITA No. 7322/Del/2017 has been settled under VSVS and withdrawn 20.11.2020 but in regard to the claim of credit the case of assessee is covered by the judgment of Hon’ble Delhi High Court in Kribhco 395 ITR 572 (Del) and ITAT Delhi order dated 19.09.2016 in ITA No. 2487/Del/2016 for assessment year 2010-11. 4.1.1 In regard to the remaining grounds of appeal no. 4 and 5 it was submitted that the Ld. F.A.A. has rightly concluded that assessee had sufficient own fund to finance its investment and otherwise also it is now well-settled that in a situation wh…

ACIT, CIRCLE- 30(1), NEW DELHI vs. KRISHAK BHARATI COOPERATIVE LTD.,, NEW DELHI

In the result, both the appeals are allowed in part and for statistical purpose

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘F’ NEW DELHI SHRI K.NARASIMHA CHARY, JUDICIAL MEMBER AND SHRI B.R.R. KUMAR, ACCOUNTANT MEMBER ITA No.5711/Del./2017 Assessment Year: 2012-13 M/s. Krishak Bharati Cooperaive ACIT, Circle -30(1), Room No.1302, 13th Floor, Ltd., A-60, Kailash Colony, vs New Delhi – 110 048. Civic Centre, PAN AAAAK0203G New Delhi. ITA No.5754/Del./2017 Assessment Year: 2012-13 ACIT, Circle -30(1), M/s. Krishak Bharati Room No.1302, 13th Floor, Civic vs Cooperaive Ltd., A-60, Kailash Centre, Colony, New Delhi. New Delhi – 110 048. PAN AAAAK0203G Assessee by : Shri KVSR Krishna, Advo…

KRISHAK BHARATI COOPERATIVE LTD.,,NEW DELHI vs. ACIT, CIRCLE- 30(1), NEW DELHI

In the result, both the appeals are allowed in part and for statistical purpose

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘F’ NEW DELHI SHRI K.NARASIMHA CHARY, JUDICIAL MEMBER AND SHRI B.R.R. KUMAR, ACCOUNTANT MEMBER ITA No.5711/Del./2017 Assessment Year: 2012-13 M/s. Krishak Bharati Cooperaive ACIT, Circle -30(1), Room No.1302, 13th Floor, Ltd., A-60, Kailash Colony, vs New Delhi – 110 048. Civic Centre, PAN AAAAK0203G New Delhi. ITA No.5754/Del./2017 Assessment Year: 2012-13 ACIT, Circle -30(1), M/s. Krishak Bharati Room No.1302, 13th Floor, Civic vs Cooperaive Ltd., A-60, Kailash Centre, Colony, New Delhi. New Delhi – 110 048. PAN AAAAK0203G Assessee by : Shri KVSR Krishna, Advo…

ROOP KUMAR BANSAL,GURGAON vs. PR,CIT (CENTRAL), GURGAON

In the result, ITA.No.383/Del

Bench: Shri Bhavnesh Saini & Shri O.P.Kant

…//FIT FOR PUBLICATION// OP Kant BS A.M. J.M. IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES “A” : DELHI [THROUGH VIDEO CONFERENCING] BEFORE SHRI BHAVNESH SAINI, JUDICIAL MEMBER AND SHRI O.P.KANT, ACCOUNTANT MEMBER ITA.No.383/Del./2021 Assessment Year 2017-2018 Smt. Abha Bansal, The Pr. CIT (Central), 103B, The Aralias, DLF Gurgaon. Golf Link City Phase-V, vs. Gurgaon, Haryana. Haryana. PIN – 122 001 PIN – 122 001. PAN AANPB8695H (Appellant) (Respondent) ITA.No.384/Del./2021 Assessment Year 2017-2018 Shri Pankaj Bansal, The Pr. CIT (Central), C-13, Sushant Lok, Gurgaon. Phase-1, Gurgaon, vs. Haryana. Haryana.…

SHRI BASANT BANSAL,GURGAON vs. PR,CIT (CENTRAL), GURGAON

In the result, ITA.No.383/Del

Bench: Shri Bhavnesh Saini & Shri O.P.Kant

…//FIT FOR PUBLICATION// OP Kant BS A.M. J.M. IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES “A” : DELHI [THROUGH VIDEO CONFERENCING] BEFORE SHRI BHAVNESH SAINI, JUDICIAL MEMBER AND SHRI O.P.KANT, ACCOUNTANT MEMBER ITA.No.383/Del./2021 Assessment Year 2017-2018 Smt. Abha Bansal, The Pr. CIT (Central), 103B, The Aralias, DLF Gurgaon. Golf Link City Phase-V, vs. Gurgaon, Haryana. Haryana. PIN – 122 001 PIN – 122 001. PAN AANPB8695H (Appellant) (Respondent) ITA.No.384/Del./2021 Assessment Year 2017-2018 Shri Pankaj Bansal, The Pr. CIT (Central), C-13, Sushant Lok, Gurgaon. Phase-1, Gurgaon, vs. Haryana. Haryana.…

PANKAJ BANSAL,GURGAON vs. PR,CIT (CENTRAL), GURGAON

In the result, ITA.No.383/Del

Bench: Shri Bhavnesh Saini & Shri O.P.Kant

…//FIT FOR PUBLICATION// OP Kant BS A.M. J.M. IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES “A” : DELHI [THROUGH VIDEO CONFERENCING] BEFORE SHRI BHAVNESH SAINI, JUDICIAL MEMBER AND SHRI O.P.KANT, ACCOUNTANT MEMBER ITA.No.383/Del./2021 Assessment Year 2017-2018 Smt. Abha Bansal, The Pr. CIT (Central), 103B, The Aralias, DLF Gurgaon. Golf Link City Phase-V, vs. Gurgaon, Haryana. Haryana. PIN – 122 001 PIN – 122 001. PAN AANPB8695H (Appellant) (Respondent) ITA.No.384/Del./2021 Assessment Year 2017-2018 Shri Pankaj Bansal, The Pr. CIT (Central), C-13, Sushant Lok, Gurgaon. Phase-1, Gurgaon, vs. Haryana. Haryana.…

ABHA BANSAL,GURGAON vs. PCIT, CENTRAL, GURGAON

In the result, ITA.No.383/Del

Bench: Shri Bhavnesh Saini & Shri O.P.Kant

…//FIT FOR PUBLICATION// OP Kant BS A.M. J.M. IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES “A” : DELHI [THROUGH VIDEO CONFERENCING] BEFORE SHRI BHAVNESH SAINI, JUDICIAL MEMBER AND SHRI O.P.KANT, ACCOUNTANT MEMBER ITA.No.383/Del./2021 Assessment Year 2017-2018 Smt. Abha Bansal, The Pr. CIT (Central), 103B, The Aralias, DLF Gurgaon. Golf Link City Phase-V, vs. Gurgaon, Haryana. Haryana. PIN – 122 001 PIN – 122 001. PAN AANPB8695H (Appellant) (Respondent) ITA.No.384/Del./2021 Assessment Year 2017-2018 Shri Pankaj Bansal, The Pr. CIT (Central), C-13, Sushant Lok, Gurgaon. Phase-1, Gurgaon, vs. Haryana. Haryana.…

M/S. GLOBUS PROJECTS PVT. LTD.,NEW DELHI vs. DCIT, FARIDABAD

In the result all the three appeals filed by the assesses are allowed

Bench: Shri H.S.Sidhu & Shri Prashant Maharishim/S. Globus Projects Private Ltd, Vs. Dcit, Unit No. 5D, 5Th Floor, Assets Aria Central Circle-1, Signature Offices, Jw Marriott Hotel, Faridabad Asset Area-4, Delhi Aerocity Hospitality District, New Delhi Pan:Aaccg5308E (Appellant) (Respondent) Bestech Hospitalities Pvt. Ltd, Vs. Dcit, Unit No. 5D, 5Th Floor, Assets Aria Central Circle-1, Signature Offices, Jw Marriott Hotel, Faridabad Asset Area-4, Delhi Aerocity Hospitality District, New Delhi Pan:Aaccg5308E (Appellant) (Respondent) Bestech India Pvt. Ltd, Vs. Dcit, Unit No. 5D, 5Th Floor, Assets Aria Central Circle-1, Signature Offices, Jw Marriott Hotel, Faridabad Asset Area-4, Delhi Aerocity Hospitality District, New Delhi Pan:Aaccg5308E (Appellant) (Respondent)

…Hence the directions of denovo asstt. are beyond jurisdiction. AUTHORITIES  CIT VS. CONTIMETERS ELECTRICALS (P) LTD. (2009) 22 DTR (DEL.) 158  Revision on issue not mentioned in show cause notice is not permissible.  PR. CIT V. KRISHAK BHARATI COOPE. LTD. 395 ITR 572 (Del.)  Revision scope of provisions natural justice order covering issues not mentioned in show cause notice not permissible. Six  The findings in sec.263 order are self contradictory  The CIT, has given a finding that it is a case of bogus share capital wherein cash has been paid against receipt of share capital (CIT Pg.8, Para - e)  Thus t…

M/S. BESTECH INDIA PVT. LTD.,NEW DELHI vs. DCIT, FARIDABAD

In the result all the three appeals filed by the assesses are allowed

Bench: Shri H.S.Sidhu & Shri Prashant Maharishim/S. Globus Projects Private Ltd, Vs. Dcit, Unit No. 5D, 5Th Floor, Assets Aria Central Circle-1, Signature Offices, Jw Marriott Hotel, Faridabad Asset Area-4, Delhi Aerocity Hospitality District, New Delhi Pan:Aaccg5308E (Appellant) (Respondent) Bestech Hospitalities Pvt. Ltd, Vs. Dcit, Unit No. 5D, 5Th Floor, Assets Aria Central Circle-1, Signature Offices, Jw Marriott Hotel, Faridabad Asset Area-4, Delhi Aerocity Hospitality District, New Delhi Pan: Aaccb2540F (Appellant) (Respondent) Bestech India Pvt. Ltd, Vs. Dcit, Unit No. 5D, 5Th Floor, Assets Aria Central Circle-1, Signature Offices, Jw Marriott Hotel, Faridabad Asset Area-4, Delhi Aerocity Hospitality District, New Delhi Pan: Aabcb6551B (Appellant) (Respondent)

…Hence the directions of denovo asstt. are beyond jurisdiction. AUTHORITIES  CIT VS. CONTIMETERS ELECTRICALS (P) LTD. (2009) 22 DTR (DEL.) 158  Revision on issue not mentioned in show cause notice is not permissible.  PR. CIT V. KRISHAK BHARATI COOPE. LTD. 395 ITR 572 (Del.)  Revision scope of provisions natural justice order covering issues not mentioned in show cause notice not permissible. Six  The findings in sec.263 order are self contradictory  The CIT, has given a finding that it is a case of bogus share capital wherein cash has been paid against receipt of share capital (CIT Pg.8, Para - e)  Thus t…

M/S. DAYANAND CONTRACTOR,ROHTAK vs. PR.CIT, ROHTAK

In the result, original

Bench: Shri Bhavnesh Saini & Shri L.P. Sahu

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES “B” : DELHI BEFORE SHRI BHAVNESH SAINI, JUDICIAL MEMBER AND SHRI L.P. SAHU, ACCOUNTANT MEMBER ITA.No.2806 & 2807/Del./2016 Assessment Years 2009-2010 & 2010-2011 M/s. Dayanand Contractor The Pr. CIT V & PO Kharainti, Aayakar Bhavan, Delhi Road, Dist. Rohtak. vs. Rohtak – 124 001 PAN AADFD4239K Haryana. (Appellant) (Respondent) S/Shri Gautam Jain, Piyush For Assessee : Kumar Kamal & Lalit Mohan, Advocates For Revenue : Ms. Rachna Singh, CIT-D.R. Date of Hearing : 22.11.2017 Date of Pronouncement : 30.11.2017 ORDER PER BHAVNESH SAINI, J.M. Both the appeals b…