How many judgments cite PCIT v. M/s SNG Developers Limited?

71 judgments on BharatTax cite PCIT v. M/s SNG Developers Limited (404 ITR 312), spanning 2018 to 2025.

Which sections of the Income Tax Act does PCIT v. M/s SNG Developers Limited come up under?

It is most often cited in judgments turning on Section 147, Section 148, Section 143(3), Section 151, Section 143(1), Section 133(6).

PCIT v. M/s SNG Developers Limited

404 ITR 312High Court2018#1595 most cited

What is PCIT v. M/s SNG Developers Limited authority for?

Reasons for reopening assessment under Section 147 and issuing a Section 148 notice must meet statutory conditions. A flawed belief that income escaped assessment, based on incorrect facts like misidentified accommodation entries, vitiates reassessment jurisdiction.

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2018 to 2025.

Also referred to as

PCIT v. SNG Developers Limited · 404 ITR 312 · Section 147 · Section 148 · reopening assessment · reasons recorded · statutory conditions · escaped assessment · accommodation entries · jurisdiction · non-application of mind

Sections most often in play

Section 147 Section 148 Section 143(3)Section 151 Section 143(1)Section 133(6)Section 139 Section 142(1)

Issues it is cited on

sanction under section 151 section 147(b)processing under section 143(1)section 151(1)non application of mind live link material facts necessary for assessment shell company full and true disclosure share capital and share premium non-application of mind sanctioning authority

Judgments citing PCIT v. M/s SNG Developers Limited

GDR FINANCE AND LEASING P. LTD,DELHI vs. INCOME TAX OFFICER, DELHI

In the result, the appeal of the assessee is allowed

ITA 802/DEL/2025[2018-19]Status: DisposedITAT Delhi23 Dec 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarassessment Year : 2018-19 M/S Gdr Finance & Leasing Vs. Assessment Unit, Pvt. Ltd., Income Tax Officer, 323, Agrawal Plaza, Nfac. Dda Community Centre, Shalimar Bagh, New Delhi – 110 088. Pan: Aaacg2363D (Appellant) (Respondent) Assessee By : Shri C.S. Aggarwal, Sr. Advocate; Shri Rupinder Aggarwal, Shri R.P. Mall, Shri Uma Shankar, Ms Suman Verma & Ms Vidushi Aggarwal, Advocates Revenue By : Shri Om Parkash, Sr. Dr Date Of Hearing : 29.10.2025 Date Of Pronouncement : 23.12.2025 Order Per Vimal Kumar, Jm:

For Appellant: Shri C.S. Aggarwal, Sr. AdvocateFor Respondent: Shri Om Parkash, Sr. DR

Section 133(6)Section 142Section 143(2)Section 147Section 148Section 148ASection 151ASection 250

…. Asstt. CIT [2019] 411 ITR 602 (Bombay) iv. Ankita A. Choksey vs. ITO W.P. 3344 of 2018 dated 10.1.2019 HC (Bom) v. Mumtaz Hazi Mohmad Memon Vs. ITO 408 ITR 268 (Guj) vi. Pr. CIT v. RMG Ply vinyl (I) Ltd. 396 ITR 5 (Del) vii. PCIT vs. SNG Developers Limited 404 ITR 312 (Del) 6 viii. Shamshad Khan vs. ACIT 395 ITR 265 (Del) ix. Synfonia Tradelinks (P). Ltd. vs. ITO 435 ITR 642 (Del) x. Sunrise Education Trust vs. ITO (Exemption) 92 taxmann.com 74 (Guj) 6. Learned authorized representative for the Department submitted that the assessee, in response to notice u/s 148A(b), merely issued a blanket denial of having…

SH. ATAR SINGH,FARIDABAD vs. ITO WARD-1(1), FARIDABAD

In the result, Appeal of the Assessee is partly allowed

ITA 2732/DEL/2025[2012-13]Status: DisposedITAT Delhi19 Dec 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shuklai.T.A. No. 2732/Del/2025 (A.Y 2012-13) Sh. Atar Singh Vs Income Tax Officer House No. 5, Village, Gazipur, Ward 1(1) Gazipur Road, Faridabad, Faridabad, Haryana Haryana-121005 122001 Pan: Dmpps6598B Appellant Respondent Assessee By Sh. S.S. Nagar, Ca Revenue By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 29/10/2025 Date Of Pronouncement 19/12/2025 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals)/National Faceless Appeal

Section 147Section 148Section 151Section 151(1)Section 69A

…th the grounds on which the reassessment notice was issued were not found to exist, and, therefore, the Income-tax Officer did not get jurisdiction to make the reassessment.” 17. Hon’ble Delhi High Court in the case of Pr. CIT Vs. SNG Developers Ltd., [2018] 404 ITR 312 (Del.) held as under: “Held, dismissing the appeal, that the reasons recorded by the Assessing Officer for reopening the assessment under section 147, issuing a notice under section 148 did not meet the statutory conditions. As already held by the Appellate Tribunal, there was a repetition of at least five accommodation entries and the total amo…

NARENDRA KACHRULAL ABAD,JALNA vs. INCOME-TAX OFFICER, WARD - 1,, JALNA

In the result, appeal of the assessee partly allowed

ITA 866/PUN/2019[2009-10]Status: DisposedITAT Pune06 Oct 2025AY 2009-10

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.866/Pun/2019 निर्धारण वषा / Assessment Year: 2009-10 Shri Narendra Kachrulal Abad, V The Income Tax Officer, Abad House, Nal Galli, S Ward-1, Jalna. Kadrabad, Jalna – 431203. Maharashtra. Pan: Acspa9531C Appellant/ Assessee Respondent / Revenue Assessee By Shri Hari Krishan – Ar Revenue By Shri Arvind Renge –Addl.Cit(Dr) Date Of Hearing 28/07/2025 Date Of Pronouncement 06/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)-1, Aurangabadpassed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2009-10 Dated 30.03.2019, Emanating From Order U/S.143(3) R.W.S 147Of The Income Tax Act, 1961, Dated 03.11.2017. The Assessee Has Raised The Following Concise Grounds Of Appeal :

Section 143(3)Section 148Section 250

…013) 357 ITR 300 (Del) (HC) Meenakshi Oversea's Pvt Ltd (2017) 395 ITR 677 CIT (Del) (HC) o CIT vs. Fair Invest Ltd. (2013) 357 ITR 146 (Del) (HC) Sarthank Securities Co. (P.) Ltd. Vs. ITO (2010) 329 ITR 110(Del.) (HC) o Pr. CIT vs. SNG Developers Ltd. (2018) 404 ITR 312 (Del.) (HC) o M/s.Coronation Agro Industries Ltd. Vs. Deputy Commissioner of Income-Tax Circle-6(2)(1). o Commissioner of Income Tax-13 Vs. Pat Commodity Services Pvt. Ltd. Income Tax Appeal No.1257 of 2016 o Akshar Builders and Developers Vs. ACIT-28(1), Mumbai & Anr Writ Petition No.14490 of 2018 (Bom HC) o PCIT-5 Vs. Manxil Dineshkumar Shah R/…

NARAYAN SUPPLIERS PVT. LTD.,KOLKATA vs. I.T.O., WARD - 6(3), KOLKATA, KOLKATA

In the result, appeal of the assessee is dismissed

ITA 1077/KOL/2024[2011-2012]Status: DisposedITAT Kolkata08 Sept 2025AY 2011-2012

Section 10(38)

….\nCIT v. Kamdhenu Steel & Alloys Ltd. (2012) 248 CTR 33\n(Del)(HC).\n13.\nCIT v. Multiplex Trading & Industrial Co Ltd (2015) 128 DTR\n217 (Del) (HC).\n14.\nCIT vs. Fair Invest Ltd. (2013) 357 ITR 146 (Del.) (HC).\n15.\nPr. CIT vs. SNG Developers Ltd. [2018] 404 ITR 312 (Del.)\n(HC).\n16.\nPCIT vs. Shodiman Investments Pvt. Ltd, (2018) 93\ntaxmann.com 153/167 DTR 290 (Bom.)(HC).\n17.\nIn the case of ACIT v. Dhariya Construction Co (2010) 328 ITR\n515 (SC) wherein it was held that the opinion of DVO per se is\nnot an information for the purpose of reopening assessment\nunder section 147 of the Act.\n18.\nWhether…

AMIT KUMAR,DELHI vs. INCOME TAX OFFICER, WARD 1(1), GUWAHATI, INCOME TAS OFFICER

ITA 33/GTY/2024[2021-22]Status: DisposedITAT Guwahati25 Jun 2025AY 2021-22

Bench: SHRI MANOMOHAN DAS, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 133(6)Section 250Section 69CSection 70

…tain case laws and most importantly on the case of Meenakshi Overseas Pvt. Ltd. reported in 395 ITR 677 (Delhi). During the course of discussion, while several cases were relied on but emphasise was also laid on the case of M/s SNG Developers Ltd. reported in 404 ITR 312 (Delhi). Through these cases it was argued that the Ld. AO could not have merely worked with “borrowed satisfaction” and hence the assumption of jurisdiction was illegal at best. (vi) The Ld. AR also argued that the approval u/s 151 of the Act was given in a mechanical manner which would not be permitted in the face of several case laws relied u…

AMIT KUMAR,DELHI vs. INCOME TAX OFFICER, WARD 1(1), GUWAHATI, INCOME TAX OFFICER

ITA 32/GTY/2024[2017-18]Status: DisposedITAT Guwahati25 Jun 2025AY 2017-18

Bench: SHRI MANOMOHAN DAS, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 133(6)Section 250Section 69CSection 70

WINSOME TEXTILE INDUSTRIES LIMITED,CHANDIGARH vs. ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4(1), CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

ITA 528/CHANDI/2024[2011-12]Status: DisposedITAT Chandigarh27 Feb 2025AY 2011-12

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Shri Ved Parkash Kalia Sr. DR

Section 115JSection 143(1)Section 143(3)Section 147Section 148

…tion and independent application of mind, the reopening was held to be bad in law and in this regard, reliance was placed on the following decisions:  PCIT v. Shodiman Investments Pvt. Ltd. (2020) 422 ITR 337 (Bom.)(HC)  PCIT v. SNG Developers Ltd. [2018] 404 ITR 312 (Delhi)(HC)  PCIT v. Meenakshi Overseas Pvt. Ltd. (2017) 395 ITR 677 (Delhi) (HC)  PCIT vs RMG Polyvinyl Ltd ITA 29/2017 & CM 1009/2017 DATED 07/07/2017  PCIT v. G & G Pharma India Ltd. [2017] 384 ITR 147 (Delhi)(HC)  CIT v. Multiplex Trading & Industrial Co. Ltd. (2016) 378 ITR 351 (Delhi) (HC)  SABH Infrastructure vs ACIT WP(C) No. 1357/2…

PR. COMMISSIONER OF INCOME TAX-7, DELHI vs. SHREE BALKISHAN AGARWAL GLASS INDUSTRIES LTD

In the result, the appeal filed by the assessee is

ITA - 401 / 2024HC Delhi30 Jul 2024

Section 143(1)Section 147Section 148Section 68

…essment is that reason to believe that income has escaped assessment must be based on correct facts. Notice based on wrong facts is without jurisdiction and is to be quashed. The Hon’ble Delhi High Court in the case of PCIT vs. M/s SNG Developers Limited, 404 ITR 312, has held that condition precedent for issue of notice for reassessment is that the reason to believe that income has escaped assessment must be based on correct facts. Notice based on wrong facts is without jurisdiction and has to be quashed. The above decision of the Hon’ble High Court was challenged by the Revenue before the apex court a…

NISHA GOEL,DELHI vs. INCOME TAX OFFICER, WARD 52(3), WARD

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

ITA 2767/DEL/2023[2012-13]Status: DisposedITAT Delhi04 Jun 2024AY 2012-13

Bench: Shri Shamim Yahya & Shri Challa Nagendra Prasadिनधा"रणवष"/Assessment Year: 2012-13

Section 144Section 147Section 151

…its that the AO computation of escaped income is apparently based on incorrect 4 ITAA.No.2767/Del/2023 facts and, therefore, such factual errors show the non-application of mind. Reliance was placed on the decision of Pr. CIT Vs. M/s SNG Developers Ltd. (404 ITR 312) (Del.). Ld. Counsel submits that the SLP filed by the Revenue has also been dismissed by the Apex Court. Ld. Counsel also placed reliance on the decision of the Delhi High Court in the case of CIT Vs. Suren International Pvt. Ltd. (357 ITR 24), where proceedings were quashed as the AO wrongly quantified the escaped income. Further he also pl…

RPG NIRMAN P.LTD,MEERUT vs. DCIT, CENTRAL CIRCLE, MEERUT

In the result all the captioned appeals of the assessee in ITA Nos

ITA 3026/DEL/2022[2017-18]Status: DisposedITAT Delhi06 Oct 2023AY 2017-18

Bench: Shri N.K. Billaiya & Ms Astha Chandra

For Appellant: Shri Gautam Jain, AdvFor Respondent: Shri Vivek Vardhan, Sr. DR

Section 143(3)Section 147

…him. There is not even a whisper about his accepting that he is providing accommodation entries through shell companies. The reasons recorded are factually incorrect on this count also. 11. The Hon'ble Delhi High Court in the case SNG Developers Limited 404 ITR 312 had an occasion to consider a case where there was factual error while recording reasons for reopening the assessment The Hon'ble High Court held as under: “11. In the considered view of the Court, neither of the above two cases come to the aid of the Revenue in the present case where the facts speak for themselves. The reasons for reopening th…

RPG NIRMAN (P) LTD.,MEERUT vs. DCIT, CENTRAL CIRCLE, MEERUT

In the result all the captioned appeals of the assessee in ITA Nos

ITA 3025/DEL/2022[2016-17]Status: DisposedITAT Delhi06 Oct 2023AY 2016-17

Bench: Shri N.K. Billaiya & Ms Astha Chandra

For Appellant: Shri Gautam Jain, AdvFor Respondent: Shri Vivek Vardhan, Sr. DR

Section 143(3)Section 147

RPG NIRMAN (P) LTD.,MEERUT vs. DCIT, CENTRAL CIRCLE, MEERUT

In the result all the captioned appeals of the assessee in ITA Nos

ITA 3024/DEL/2022[2015-16]Status: DisposedITAT Delhi06 Oct 2023AY 2015-16

Bench: Shri N.K. Billaiya & Ms Astha Chandra

For Appellant: Shri Gautam Jain, AdvFor Respondent: Shri Vivek Vardhan, Sr. DR

Section 143(3)Section 147

RPG NIRMAN (P) LTD.,MEERUT vs. DCIT, CENTRAL CIRCLE, MEERUT

In the result all the captioned appeals of the assessee in ITA Nos

ITA 3023/DEL/2022[2014-15]Status: DisposedITAT Delhi06 Oct 2023AY 2014-15

Bench: Shri N.K. Billaiya & Ms Astha Chandra

For Appellant: Shri Gautam Jain, AdvFor Respondent: Shri Vivek Vardhan, Sr. DR

Section 143(3)Section 147

NAMAH SHIVAYA TRADING PVT LTD,NEW DELHI vs. ITO WARD WARD - 17(3), NEW DELHI

In the result, appeal of the assessee is allowed in the manner

ITA 4739/DEL/2019[2008-09]Status: DisposedITAT Delhi29 Sept 2023AY 2008-09

Bench: supply of reasons thereby debarring appellant to file objection to the assumption of jurisdiction for initiation of reassessment proceedings. 4. The Ld. AR raising above legal contentions submitted that since the AO did not assume valid jurisdiction to initiate the reassessment proceedings and to issue notice u/s 148 of the Act, therefore, initiation of reassessment proceedings and all constant

Section 132Section 143(2)Section 143(3)Section 147Section 148

…s. 7. To support first legal contention, the Ld. AR has relied on the various judgments and orders including recent judgment of Hon’ble Jurisdictional High Court of Delhi in the case of Shamshad Khan Vs. ACIT (395 ITR 265) and PCIT Vs. SNG Developers Ltd. (404 ITR 312) (Del.) approved by the Hon’ble Supreme Court by dismissing SLP of Revenue No.42379/2017 dated 09.02.2018. 8. Regarding second legal contention of Ld. AR that the AO has not made any enquiry on the factual information received by Investigation Wing is concerned. From the copy of reasons recorded placed at pages 19-20 of the assessee’s paper boo…

MILKY WAY CONSULTANTS LLP,NEW DELHI vs. ITO WARD - 37(1), NEW DELHI

In the result, the appeal of the assessee is partly allowed on legal grounds

ITA 1946/DEL/2020[2011-12]Status: DisposedITAT Delhi16 Jun 2023AY 2011-12

For Appellant: Ms. Rano Jain, Adv. & Ms. Mansi Jain, AdvFor Respondent: Shri Sumit Kumar Verma, Sr. DR

Section 148

…ry about the actual nature of transaction therefore it is a clear case of non- application mind by the Assessing Officer therefore she submitted that in view of judgment of Hon’ble jurisdictional High Court of Delhi in the case of PCIT vs. SNG Developers Ltd. 404 ITR 312 (Del.) that the reopening of assessment has to be held as bad in law. 4. Replying to the above, the ld. Senior DR strongly supported the orders of the authorities below and submitted that at the time of recording reasons the Assessing Officer is not required to make a details inquiry on the entire material gathered by the investigation team hence…

DCIT, CC-15, NEW DELHI vs. BDR BUILDERS & DEVELOPERS P. LTD., NEW DELHI

In the result, the appeal of the Revenue is dismissed

ITA 1177/DEL/2021[2012-13]Status: DisposedITAT Delhi16 Mar 2023AY 2012-13

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usasstt. Year: 2012-13 Dcit, Vs. Bdr Builders & Developers P. Ltd,B- Central Circle-15, 393, Zakir Nagar So, South East Delhi, New Delhi New Delhi-1100025 (Appellant) (Respondent) Pan No. Assessee By : Dr. Rakesh Gupta, Adv. Revenue By : Sh. Kanv Bali, Sr. Dr Date Of Hearing: 28.02.2023 Date Of Pronouncement: 16.03.2023

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Sh. Kanv Bali, Sr. DR

Section 139(1)Section 143(3)Section 147Section 148Section 153ASection 68

…e requirement of law. 38. The question framed is answered in the negative, i.e., in favour of the Assessee and against the Revenue. The appeal is, accordingly, dismissed but with no orders as to costs." (ii) In the case of Pr. CIT v SNG Developers Ltd. (2018) 404 ITR 312 (Del) assessment was reopened u/s 147 of the Act. The A.O. recorded the reasons that as per information received from investigation wing, the assessee had taken accommodation entries to the tune of Rs. 95,65,510/-. The assessee filed the objections against the reopening. One of the objections was that figure of Rs. 95,65,510/- itself was wrong. T…

JVR RETAILS PRIVATE LIMITED ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX ,CIRCLE -2(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed

ITA 175/HYD/2021[2012-13]Status: DisposedITAT Hyderabad31 Jan 2023AY 2012-13

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Charyassessment Year: 2012-13 Jvr Retails Private Limited Vs Dcit, Circle-2(1) C/O. Murali & Co. . Hyderabad Chartered Accountants 6-3-655/2/3, Somajiguda Hyderabad-500 082 Pan : Aaccv9428J (Appellant) (Respondent) Assessee By: Shri M.V.Joshi Appeared For P.Murali Mohan Rao, Ca Revenue By: Shri Jeevan Lal Lavidiya, Cit-Dr Date Of Hearing: 14.01.2023 Date Of Pronouncement: 31.01.2023 O R D E R Per Shri Rama Kanta Panda (A.M.): This Appeal Filed By The Assessee Is Directed Against The Order Dated 16.03.2021 Passed U/S. 263 By The Learned Principal Commissioner Of Income Tax -2, Hyderabad Relating To A Y 2012-13. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Domestic Company Engaged In The Business Of Retails & Manufacturing Of Jewelry. It Filed Its Return Of Income Declaring Total Income Of Rs. 49,97,390/- On 08.09.2012 Which Was Processed U/S 143(1) On 21.02.2013. Subsequently, The Ao Reopened The Assessment By Recording Reasons As Per Provisions Of Section 147. The Reasons To Believe Which Was Put Up Before The Ld.Pcit-2 For Approval & Which Has Been Reproduced By The Ao In The Body Of The Assessment Order Read As Under:-

For Appellant: Shri M.V.Joshi appeared for P.Murali Mohan Rao, CAFor Respondent: Shri Jeevan Lal

Section 143(1)Section 143(3)Section 147Section 148Section 263Section 68

…ision of Delhi High Court in the case of Atul Kumar Swamy 362 ITR 693, Consulting Engineers Services India Pvt. Ltd., 378 ITR 318, Nestle India Ltd., 384 ITR 334 and Priyadesh Gupta 385 ITR 452. The Hon'ble Delhi High Court in the case of SNG Developers Ltd., 404 ITR 312 held that when A.O. initiated the re- assessment proceedings without application of mind, such proceedings would be invalid. A.O. in the present case has failed to verify the information received from Investigation Wing. Therefore, it is non-application of mind on the part of the A. O. to record correct facts in the reasons for reopening of the a…

SUCCESS INTERNATIONAL,NEW DELHI vs. ITO WARD- 51(4), NEW DELHI

The appeal is allowed

ITA 7301/DEL/2019[2009-10]Status: DisposedITAT Delhi16 Nov 2022AY 2009-10

Bench: Shri Anil Chaturvedi & Shri Anubhav Sharmasuccess International, Vs. Ito, C/O. Raj Kumar & Associates, Ward-51(4), Ca L-7A, )Lgf), South Extn, New Delhi Part-Ii, New Delhi (Appellant) (Respondent) Pan: Aaxfs3915K

For Appellant: Shri Raj Kumar, CAFor Respondent: Shri Abhishek Kumar, Sr. DR

Section 147Section 148Section 151Section 69C

…so been included. In regard to effect of factually wrong information in the reasons reliance was placed on the judgment of CIT Vs. Kamdhenu Steel & alloys Ltd (2012) 248 CTR (Del) 33, Ganesh Ganga Investments Pvt. Ltd ITa NO. 1579/Del/2019, SNG Developers Ltd 404 ITR 312 (Del), Ankita A. Choksey Vs. ITO & Ors 411 ITR 207, M/s. KLA Foods (India) Ltd & Ors ITA No. 2846/Del/2015, PCIT Vs. RMG Polyvinyal (I) Ltd 396 ITR 5 (Del), Vijay Haishchandra Patel Vs. ITO 400 ITR 167, Shree Balkishan Agarwal Glass Industries Ltd ITA No. 5798/Del/2016 Success International Vs. ITO, 7. Referring to the copy of approval u/s 151 av…

GANESH CHHGANLAL JAIN,MUMBAI vs. CIT (A), NFAC, DELHI

In the result, the appeal filed by the assessee is allowed for In the result, the appeal filed by the assessee is allowed for In the result, the appeal filed by the assessee is allowed for statisti...

ITA 2101/MUM/2022[2012-13]Status: DisposedITAT Mumbai18 Oct 2022AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2012-13 Ganesh Chhganlal Jain, Cit (A) Nfac, Plot No. 899 Jassawala Wadi, Delhi. Juhu Tara Road, Juju, Vs. Andheri West, Mumbai-400049. Pan No. Aanpj 1550 D Appellant Respondent Assessee By : Mr. Pramod Kumar Parida, Ar Revenue By : Mr. Sanyam Suresh Joshi, Dr Date Of Hearing : 12/10/2022 Date Of Pronouncement : 18/10/2022

For Appellant: Mr. Pramod Kumar Parida, ARFor Respondent: Mr. Sanyam Suresh Joshi, DR

Section 143(1)Section 148

…Siemens Information System Ltd. Vs ACIT 293 ITR 548 (Bombay H.C.) (Bombay H.C.) b) Shamshad Khan Vs ACIT 395 ITR 265 (Delhi HC) b) Shamshad Khan Vs ACIT 395 ITR 265 (Delhi HC) b) Shamshad Khan Vs ACIT 395 ITR 265 (Delhi HC) c) Pr. CCIT Vs SNG Developers Ltd 404 ITR 312 (Delhi HC) CCIT Vs SNG Developers Ltd 404 ITR 312 (Delhi HC) CCIT Vs SNG Developers Ltd 404 ITR 312 (Delhi HC) 6.3 In this case of Pr CIT Vs Manzil Dinesh Kumar Shah, Hon'ble In this case of Pr CIT Vs Manzil Dinesh Kumar Shah, Hon'ble In this case of Pr CIT Vs Manzil Dinesh Kumar Shah, Hon'ble Gujarat High Court has held that where the original…

HARISH CHANDER ,FARIDABAD vs. ITO, WARD-1(3), FARIDABAD

In the result assessee’s appeal is partly allowed for statistical purposes

ITA 1910/DEL/2021[2012-13]Status: DisposedITAT Delhi10 Jun 2022AY 2012-13

Bench: Shri Kul Bharat[Assessment Year: 2012-13

Section 142(1)Section 144Section 147Section 148Section 56(2)(v)

…et jurisdiction to reopen the assessment on such wrong facts recorded for reopening assessment. Reliance is also placed on the judgements of 4 Harish Chander Vs. ITO CIT v. Atlas Cycle Industries [1989] 180 ITR 319 [P&H] Pr. CIT v. SNG Developers Ltd [2018] 404 ITR 312 (Del.) Shamshad Khan v. ACIT [2017] 395 ITR 265 (Del.)” 4. On the contrary, learned DR opposed the submissions and supported the orders of the authorities below. 5. I have heard the rival contentions of the parties. There is no dispute with regard to the fact that cash was deposited in the bank account of the assessee. Before the Assessing Of…

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