PCIT v. Param Diary Limited

439 ITR 89Reported decision#9791 most cited

What is PCIT v. Param Diary Limited authority for?

Regular books of accounts maintained by an assessee in the normal course of business are not incriminating material and cannot form the basis for framing an assessment under Section 143(3) read with Section 153A of the Income Tax Act, 1961.

11

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2022 to 2022.

Also referred to as

PCIT v. Param Diary Limited · 439 ITR 89 · regular books of accounts · incriminating material · search assessment · section 143(3) · section 153A

Issues it is cited on

section 41(1)section 41section 40a(3)sundry creditorsloose paperssection 145(3)section 40asearch assessmentsection 69csection 40section 131genuineness of the transaction

Judgments citing PCIT v. Param Diary Limited

DCIT Cen Cir 2(2), Mumbai vs. Infinity Industries P. Ltd, Mumbai

In the result, appeal of the assessee for A

ITA 2933/MUM/2015[2010-11]Status: DisposedITAT Mumbai23 Dec 2022AY 2010-11
Section 144Section 145(3)

…see in its normal course of business cannot fall under the ambit of incriminating material found during the course of search. Our view is further fortified by the decision of the Hon’ble Delhi High Court in the case of PCIT vs. Param Diary Limited reported in 439 ITR 89 wherein it was held that regular books of accounts of the assessee, by no stretch of imagination, could be treated as incriminating material to form basis of framing assessment u/s.143(3) r.w.s. 153A of the Act. In any case, we find that the original M/s. Infinity Industries Pvt. Ltd. return of income for the A.Y.2007-08 was filed by the assessee…

DCIT Cen Cir 2(2), Mumbai vs. Infinity Industries P. Ltd, Mumbai

In the result, appeal of the assessee for A

ITA 2932/MUM/2015[2009-10]Status: DisposedITAT Mumbai23 Dec 2022AY 2009-10
Section 144Section 145(3)

…see in its normal course of business cannot fall under the ambit of incriminating material found during the course of search. Our view is further fortified by the decision of the Hon’ble Delhi High Court in the case of PCIT vs. Param Diary Limited reported in 439 ITR 89 wherein it was held that regular books of accounts of the assessee, by no stretch of imagination, could be treated as incriminating material to form basis of framing assessment u/s.143(3) r.w.s. 153A of the Act. In any case, we find that the original M/s. Infinity Industries Pvt. Ltd. return of income for the A.Y.2007-08 was filed by the assessee…

DCIT Cen Cir 2(2), Mumbai vs. Infinity Industries P. Ltd, Mumbai

In the result, appeal of the assessee for A

ITA 2931/MUM/2015[2008-09]Status: DisposedITAT Mumbai23 Dec 2022AY 2008-09
Section 144Section 145(3)

…see in its normal course of business cannot fall under the ambit of incriminating material found during the course of search. Our view is further fortified by the decision of the Hon’ble Delhi High Court in the case of PCIT vs. Param Diary Limited reported in 439 ITR 89 wherein it was held that regular books of accounts of the assessee, by no stretch of imagination, could be treated as incriminating material to form basis of framing assessment u/s.143(3) r.w.s. 153A of the Act. In any case, we find that the original M/s. Infinity Industries Pvt. Ltd. return of income for the A.Y.2007-08 was filed by the assessee…

DCIT Cen Cir 2(2), Mumbai vs. Infinity Industries P. Ltd, Mumbai

In the result, appeal of the assessee for A

ITA 2930/MUM/2015[2007-08]Status: DisposedITAT Mumbai23 Dec 2022AY 2007-08
Section 144Section 145(3)

…see in its normal course of business cannot fall under the ambit of incriminating material found during the course of search. Our view is further fortified by the decision of the Hon’ble Delhi High Court in the case of PCIT vs. Param Diary Limited reported in 439 ITR 89 wherein it was held that regular books of accounts of the assessee, by no stretch of imagination, could be treated as incriminating material to form basis of framing assessment u/s.143(3) r.w.s. 153A of the Act. In any case, we find that the original M/s. Infinity Industries Pvt. Ltd. return of income for the A.Y.2007-08 was filed by the assessee…

DCIT Cen Cir 2(2), Mumbai vs. Infinity Industries Ltd, Mumbai

In the result, appeal of the assessee for A

ITA 2929/MUM/2015[2006-07]Status: DisposedITAT Mumbai23 Dec 2022AY 2006-07
Section 144Section 145(3)

…see in its normal course of business cannot fall under the ambit of incriminating material found during the course of search. Our view is further fortified by the decision of the Hon’ble Delhi High Court in the case of PCIT vs. Param Diary Limited reported in 439 ITR 89 wherein it was held that regular books of accounts of the assessee, by no stretch of imagination, could be treated as incriminating material to form basis of framing assessment u/s.143(3) r.w.s. 153A of the Act. In any case, we find that the original M/s. Infinity Industries Pvt. Ltd. return of income for the A.Y.2007-08 was filed by the assessee…

DCIT Cen Cir 2(2), Mumbai vs. Infinity Industries Ltd, Mumbai

In the result, appeal of the assessee for A

ITA 2928/MUM/2015[2005-06]Status: DisposedITAT Mumbai23 Dec 2022AY 2005-06
Section 144Section 145(3)

…see in its normal course of business cannot fall under the ambit of incriminating material found during the course of search. Our view is further fortified by the decision of the Hon’ble Delhi High Court in the case of PCIT vs. Param Diary Limited reported in 439 ITR 89 wherein it was held that regular books of accounts of the assessee, by no stretch of imagination, could be treated as incriminating material to form basis of framing assessment u/s.143(3) r.w.s. 153A of the Act. In any case, we find that the original M/s. Infinity Industries Pvt. Ltd. return of income for the A.Y.2007-08 was filed by the assessee…

DCIT Cen Cir 2(2), Mumbai vs. Infinity Industries Ltd, Mumbai

In the result, appeal of the assessee for A

ITA 2927/MUM/2015[2004-05]Status: DisposedITAT Mumbai23 Dec 2022AY 2004-05
Section 144Section 145(3)

…see in its normal course of business cannot fall under the ambit of incriminating material found during the course of search. Our view is further fortified by the decision of the Hon’ble Delhi High Court in the case of PCIT vs. Param Diary Limited reported in 439 ITR 89 wherein it was held that regular books of accounts of the assessee, by no stretch of imagination, could be treated as incriminating material to form basis of framing assessment u/s.143(3) r.w.s. 153A of the Act. In any case, we find that the original M/s. Infinity Industries Pvt. Ltd. return of income for the A.Y.2007-08 was filed by the assessee…

Infinity Industries P.Ltd, Mumbai vs. DCIT CC 2(2), Mumbai

In the result, appeal of the assessee for A

ITA 2399/MUM/2015[2009-10]Status: DisposedITAT Mumbai23 Dec 2022AY 2009-10
Section 144Section 145(3)

…see in its normal course of business cannot fall under the ambit of incriminating material found during the course of search. Our view is further fortified by the decision of the Hon’ble Delhi High Court in the case of PCIT vs. Param Diary Limited reported in 439 ITR 89 wherein it was held that regular books of accounts of the assessee, by no stretch of imagination, could be treated as incriminating material to form basis of framing assessment u/s.143(3) r.w.s. 153A of the Act. In any case, we find that the original M/s. Infinity Industries Pvt. Ltd. return of income for the A.Y.2007-08 was filed by the assessee…

Infinity Industries P.Ltd, Mumbai vs. DCIT CC 2(2), Mumbai

In the result, appeal of the assessee for A

ITA 2398/MUM/2015[2008-09]Status: DisposedITAT Mumbai23 Dec 2022AY 2008-09
Section 144Section 145(3)

…see in its normal course of business cannot fall under the ambit of incriminating material found during the course of search. Our view is further fortified by the decision of the Hon’ble Delhi High Court in the case of PCIT vs. Param Diary Limited reported in 439 ITR 89 wherein it was held that regular books of accounts of the assessee, by no stretch of imagination, could be treated as incriminating material to form basis of framing assessment u/s.143(3) r.w.s. 153A of the Act. In any case, we find that the original M/s. Infinity Industries Pvt. Ltd. return of income for the A.Y.2007-08 was filed by the assessee…

Infinity Industries P.Ltd, Mumbai vs. DCIT CC 2(2), Mumbai

In the result, appeal of the assessee for A

ITA 2397/MUM/2015[2007-08]Status: DisposedITAT Mumbai23 Dec 2022AY 2007-08
Section 144Section 145(3)

…see in its normal course of business cannot fall under the ambit of incriminating material found during the course of search. Our view is further fortified by the decision of the Hon’ble Delhi High Court in the case of PCIT vs. Param Diary Limited reported in 439 ITR 89 wherein it was held that regular books of accounts of the assessee, by no stretch of imagination, could be treated as incriminating material to form basis of framing assessment u/s.143(3) r.w.s. 153A of the Act. In any case, we find that the original M/s. Infinity Industries Pvt. Ltd. return of income for the A.Y.2007-08 was filed by the assessee…

Infinity Industries P.Ltd, Mumbai vs. DCIT CC 2(2), Mumbai

In the result, appeal of the assessee for A

ITA 2396/MUM/2015[2011-12]Status: DisposedITAT Mumbai23 Dec 2022AY 2011-12
Section 144Section 145(3)

…see in its normal course of business cannot fall under the ambit of incriminating material found during the course of search. Our view is further fortified by the decision of the Hon’ble Delhi High Court in the case of PCIT vs. Param Diary Limited reported in 439 ITR 89 wherein it was held that regular books of accounts of the assessee, by no stretch of imagination, could be treated as incriminating material to form basis of framing assessment u/s.143(3) r.w.s. 153A of the Act. In any case, we find that the original M/s. Infinity Industries Pvt. Ltd. return of income for the A.Y.2007-08 was filed by the assessee…

PCIT v. Param Diary Limited (439 ITR 89) — Cited in 11 Judgments | BharatTax