PCIT v. RMG Polyvinyl (I) Ltd.

396 ITR 5High Court2017#293 most cited

What is PCIT v. RMG Polyvinyl (I) Ltd. authority for?

Reassessment based solely on information from the Investigation Wing, without the Assessing Officer conducting further inquiry or demonstrating an independent application of mind, is unjustified and invalid.

272

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2017 to 2026.

Also referred to as

PCIT v. RMG Polyvinyl (I) Ltd. · reassessment · section 148 · investigation wing · accommodation entries · tangible material · assessing officer · application of mind · live link · section 147

Also reported as

83 Taxmann.com 348249 Taxmann 610

Sections most often in play

Section 148Section 147Section 143(3)Section 151Section 1961Section 68Section 133(6)Section 142(1)

Issues it is cited on

sanction under section 151material facts necessary for assessmentlive linksection 151(1)borrowed satisfactionsanctioning authorityfirst proviso to section 147non application of mindsection 151(2)tangible materialshare capital and share premiumnon-application of mind

Judgments citing PCIT v. RMG Polyvinyl (I) Ltd.

Hanuman Prasad Aggarwal, Faridabad vs. ITO Ward - 1(3), Faridabad

In the result, ITA.No.7376/Del

ITA 7376/DEL/2019[2011-12]Status: DisposedITAT Delhi10 Sept 2020AY 2011-12

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

Section 142(1)Section 147Section 148

…supplied to the assessee. Therefore, there is a total non-application of mind on the part of the A.O. to reopen the assessment. In support of his contention, he has relied upon Judgments of the Hon’ble Delhi High court in the cases of RNG Polyvinyle (I) Ltd., 396 ITR 5 (Del.), Meenakshi Overseas Pvt. Ltd., 395 ITR 677 (Del.) and GNG Pharma India 384 ITR 147 (Del.). He has submitted that since A.O. has admittedly did not confront any material supplied by the Investigation Wing to assessee, despite assessee made a specific request and also requested to allow cross-examination of statement of Shri Pramod Kumar Jinda…

Narender Kumar Gupta, New Delhi vs. ITO Ward-2(1), Faridabad

In the result, ITA.No.7376/Del

ITA 7375/DEL/2019[2011-12]Status: DisposedITAT Delhi10 Sept 2020AY 2011-12

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

Section 142(1)Section 147Section 148

…supplied to the assessee. Therefore, there is a total non-application of mind on the part of the A.O. to reopen the assessment. In support of his contention, he has relied upon Judgments of the Hon’ble Delhi High court in the cases of RNG Polyvinyle (I) Ltd., 396 ITR 5 (Del.), Meenakshi Overseas Pvt. Ltd., 395 ITR 677 (Del.) and GNG Pharma India 384 ITR 147 (Del.). He has submitted that since A.O. has admittedly did not confront any material supplied by the Investigation Wing to assessee, despite assessee made a specific request and also requested to allow cross-examination of statement of Shri Pramod Kumar Jinda…

Garima Aggarwal, Faridabad vs. ITO Ward - 1(3), Faridabad

In the result, ITA.No.7376/Del

ITA 7374/DEL/2019[2011-12]Status: DisposedITAT Delhi10 Sept 2020AY 2011-12

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

Section 142(1)Section 147Section 148

…supplied to the assessee. Therefore, there is a total non-application of mind on the part of the A.O. to reopen the assessment. In support of his contention, he has relied upon Judgments of the Hon’ble Delhi High court in the cases of RNG Polyvinyle (I) Ltd., 396 ITR 5 (Del.), Meenakshi Overseas Pvt. Ltd., 395 ITR 677 (Del.) and GNG Pharma India 384 ITR 147 (Del.). He has submitted that since A.O. has admittedly did not confront any material supplied by the Investigation Wing to assessee, despite assessee made a specific request and also requested to allow cross-examination of statement of Shri Pramod Kumar Jinda…

Sheela Aggarwal, Faridabad vs. ITO Ward - 2(3), Faridabad

In the result, ITA.No.7376/Del

ITA 7373/DEL/2019[2011-12]Status: DisposedITAT Delhi10 Sept 2020AY 2011-12

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

Section 142(1)Section 147Section 148

…supplied to the assessee. Therefore, there is a total non-application of mind on the part of the A.O. to reopen the assessment. In support of his contention, he has relied upon Judgments of the Hon’ble Delhi High court in the cases of RNG Polyvinyle (I) Ltd., 396 ITR 5 (Del.), Meenakshi Overseas Pvt. Ltd., 395 ITR 677 (Del.) and GNG Pharma India 384 ITR 147 (Del.). He has submitted that since A.O. has admittedly did not confront any material supplied by the Investigation Wing to assessee, despite assessee made a specific request and also requested to allow cross-examination of statement of Shri Pramod Kumar Jinda…

Meena Gupta, Faridabad vs. ITO Ward - 1(5), Faridabad

In the result, ITA.No.7376/Del

ITA 7372/DEL/2019[2011-12]Status: DisposedITAT Delhi10 Sept 2020AY 2011-12

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

Section 142(1)Section 147Section 148

…supplied to the assessee. Therefore, there is a total non-application of mind on the part of the A.O. to reopen the assessment. In support of his contention, he has relied upon Judgments of the Hon’ble Delhi High court in the cases of RNG Polyvinyle (I) Ltd., 396 ITR 5 (Del.), Meenakshi Overseas Pvt. Ltd., 395 ITR 677 (Del.) and GNG Pharma India 384 ITR 147 (Del.). He has submitted that since A.O. has admittedly did not confront any material supplied by the Investigation Wing to assessee, despite assessee made a specific request and also requested to allow cross-examination of statement of Shri Pramod Kumar Jinda…

O.P.Yadav, New Delhi vs. DCIT, Central Circ Le-15, New Delhi

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

ITA 5523/DEL/2018[2000-01]Status: DisposedITAT Delhi10 Sept 2020AY 2000-01

Bench: Shri H.S. Sidhu & Shri O.P. Kant

Section 133(6)Section 143(3)Section 144Section 147Section 148Section 158B

…High Court in CIT Vs. Lalitkumar Bardia (2017) 84 taxmann.com 213 (Bom), Our plea that reopening is invalid is supported by following High Court/Apex court decisions considered in decisions enlisted below. i) Delhi high court decision in case of RMG Polyvinyl 396 ITR 5; ii) High Court of Delhi in the case of PCIT vs. Meenakshi Overseas P. Ltd. 395 ITR 677 (Del); iii) High Court of Delhi in the case of PCIT vs. G&G Pharma India Ltd. reported in 384 ITR 147 (Del); On basis of above discussion we make a humble prayer for i) admission of our legal and jurisdictional additional ground and ii) allowing our appeal by a…

Ak Lumber Limited, Delhi vs. ACIT, Circle-1(1), New Delhi

In the result, the appeal of the assessee in ITA No

ITA 8761/DEL/2019[2011-12]Status: DisposedITAT Delhi10 Jul 2020AY 2011-12

Bench: Shri N.K. Billaiya & Shri Kuldip Singh[Assessment Year: 2011-12]

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Jagdish Singh Dahiya, Sr. DR
Section 131Section 132Section 143(1)Section 143(3)

…and had he examined these documents/evidences or made necessary enquiries, he may not have issued notice u/s 148 of the Act but for non-application of mind, the assessment was reopened. 21. The Hon'ble High Court of Delhi in the case of RMG Polyvinyl Ltd 396 ITR 5 had the occasion to consider the issue whether notice issued by the Assessing Officer to reopen assessment on the basis of information received from INV Wing could be said to be tangible material, the Hon'ble High Court held that information received from INV Wing could not be said to be tangible material per se without a further enquiry being un…

Omvir Singh, Ghaziabad vs. ITO, Ward- 2(1), Ghaziabad

In the result, the appeal of the assessee in ITA No

ITA 7437/DEL/2018[2009-10]Status: DisposedITAT Delhi11 Jun 2020AY 2009-10

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble[Assessment Year: 2009-10]

For Appellant: Shri Rohit Tiwari, AdvFor Respondent: Shri R.K. Gupta, Sr. DR
Section 147Section 148

…dated 03.02.2016. 10. This clearly shows that the Assessing Officer issued notice mechanically without applying his mind. Such action of the Assessing Officer did not find any favour with the Hon'ble High Court of Delhi in the case of RMG Polyvinyl [I] Ltd 396 ITR 5. The relevant facts of that case are as under: “4. Notice under Section 147 of the Act was issued by the AO to the Assessee on 25th March, 2011. The following reasons for the re- opening were furnished to the Assessee for reopening the assessment: 11. Reasons for the belief Information has been received from the that Information has income has es…

Aero Dealcomm Pvt. Ltd., Kolkata vs. I.T.O., Ward-4(3), Kolkata

ITA 2484/KOL/2019[2009-10]Status: DisposedITAT Kolkata29 May 2020AY 2009-10

Bench: Sri J. Sudhakar Reddy, Hon’Ble) Assessment Years: 2009-10 Aereo Dealcomm Pvt. Ltd………….………...........................................................……………….…......Appellant C/O. S.N. Ghosh & Associates, Advocates 2, Garstin Place 2Nd Floor Suite No. 203 Off Hare Street Kolkata West Bengal – 700 001 [Pan : Aacca 5934 G] Vs. Income Tax Officer, Ward-4(3), Kolkata…………………..……………….............….……....…....Respondent Appearances By: Shri Somnath Ghosh, Advocate & Shri M. Jhawar, Fca, Appeared On Behalf Of The Assessee. Shri Jayanta Khanra, Jcit Sr. D/R, Appearing On Behalf Of The Revenue. Date Of Concluding The Hearing : February 26Th, 2020 Date Of Pronouncing The Order : May 29Th, 2020 Order Per J. Sudhakar Reddy, Am :-

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 68

…nt is bad in law circumstances, the reopening of assessment is bad in law :-  PCIT vs. Meenakshi Overseas P. Ltd. ( PCIT vs. Meenakshi Overseas P. Ltd. (2017) 395 ITR 677 (Del.) 2017) 395 ITR 677 (Del.)  PCIT vs. RMG P PCIT vs. RMG Polyvinyl (I) Ltd. (2017) 396 ITR 5 (Del.)  PCIT vs. G & G Pharma India Ltd. (2016) 384 ITR 147 (Del.) PCIT vs. G & G Pharma India Ltd. (2016) 384 ITR 147 (Del.) PCIT vs. G & G Pharma India Ltd. (2016) 384 ITR 147 (Del.) 4.1. He further argued that He further argued that, the letter of the DCIT, Hqs.-1, Kolkata, on behalf of on behalf of the ld. Pr. CIT-1, Kolkata addressed addresse…

Akg Securities & Consulting Ltd, New Delhi vs. ITO Ward - 1(1), New Delhi

In the result, the Appeal filed by the Assessee stands allowed

ITA 4395/DEL/2019[2010-11]Status: DisposedITAT Delhi27 Feb 2020AY 2010-11

Bench: Shri H.S. Sidhu & Shri N.K. Billaiyaassessment Year : 2010-11

For Appellant: Mr. Rohit Tiwari, Adv. & Sh. VinjayFor Respondent: Sh. S.N. Pandey, Sr. DR
Section 143(3)Section 147Section 148Section 250

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHE : A : NEW DELHI BEFORE SHRI H.S. SIDHU, JUDICIAL MEMBER AND SHRI N.K. BILLAIYA, ACCOUNTANT MEMBER Assessment Year : 2010-11 AKG SECURITIES & CONSULTING Vs. ITO, WARD-1(1), LTD., NEW DELHI 3776/309, NIRMAL MARKET, ROOM NO. 380-A, NETAJI SUBHASH MARG, C.R. BUILDING, IP ESTATE, DARYAGANJ, NEW DELHI – 110 001 NEW DELHI – 110 002 (PAN: AAACA7549K) (Appellant) (Respondent) Assessee by : Mr. Rohit Tiwari, Adv. & Sh. Vinjay Verma, Adv. Department by : Sh. S.N. Pandey, Sr. DR. ORDER PER H.S. SIDHU, JM This appeal filed by the assessee is directed against the order pa…

Arina Grover, New Delhi vs. ACIT, Circle-45(1), New Delhi

In the result, the Appeal filed by the Assessee stands partly allowed

ITA 9316/DEL/2019[2008-09]Status: DisposedITAT Delhi20 Feb 2020AY 2008-09

Bench: Shri H.S. Sidhuassessment Year : 2008-09 M/S Arina Grover, Vs. Acit, Circle 45(1), D-25, 2Nd Floor, New Delhi Ajay Enclave, New Delhi – 110 027 (Pan: Akepg0821F) (Appellant) (Respondent)

For Appellant: Sh. Rohit Tiwari, Advocate & Sh. VinayFor Respondent: Sh. Pradeep Singh Gautam, Sr.DR
Section 139Section 143(1)Section 143(3)Section 147Section 148

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES : SMC : NEW DELHI BEFORE SHRI H.S. SIDHU, JUDICIAL MEMBER Assessment Year : 2008-09 M/S ARINA GROVER, Vs. ACIT, CIRCLE 45(1), D-25, 2ND FLOOR, NEW DELHI AJAY ENCLAVE, NEW DELHI – 110 027 (PAN: AKEPG0821F) (Appellant) (Respondent) Assessee by : Sh. Rohit Tiwari, Advocate & Sh. Vinay Verma, Advocate Department by : Sh. Pradeep Singh Gautam, Sr.DR. ORDER This appeal filed by the assessee is directed against the order passed by the Ld. CIT(A)-15, New Delhi on 16.10.2019 in relation to the assessment year 2008-09. 2. The brief facts of the case are that assessee f…

M/S. Bull Riders Financial Services (P) Ltd., New Delhi vs. ITO, Ghaziabad

In the result, appeal of the Assessee allowed

ITA 1891/DEL/2017[2005-06]Status: DisposedITAT Delhi10 Feb 2020AY 2005-06

Bench: Shri Bhavnesh Saini & Shri R.K. Panda

For Appellant: Shri Somil AgarwalFor Respondent: Shri S.L. Anuragi, Sr. D.R
Section 143(3)Section 147Section 148Section 151Section 68

…circumstances, the A.O. has signed the fax recorded reasons. Thus, there is total non-application of mind on the part of the A.O. for reopening of the assessment. We rely upon Judgment in the case of Pr. Commissioner of Income Tax vs., RMG Polyvinyl (I) Ltd., 396 ITR 5 (Del.), Pr. Commissioner of Income Tax vs., Meenakshi Overseas (P) Ltd., 395 ITR 677 (Del.) and Pr. 20 ITA.No.1891/Del./2017 M/s. Bull Riders Financial Services (P) Ltd., Ghaziabad, Uttar Pradesh. CIT vs., G And G Pharma India Ltd., [2016] 384 ITR 147 (Del.) and Sarthak Securities Co. (P) Ltd., 329 ITR 110 (Del.). 5.7. The above discussion would…

S.N. Arora/Sapra, New Delhi vs. ITO, Ward- 23(2), New Delhi

In the result, appeal of the Assessee for the A

ITA 4252/DEL/2018[2007-08]Status: DisposedITAT Delhi30 Jan 2020AY 2007-08

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

For Appellant: Shri R.S. Singhvi, C.A. And Shri Satyajeet Goel, C.AFor Respondent: Ms. Rakhi Vimal, Sr. D.R
Section 143(1)Section 148Section 68

…lhi in ITA.No.5747/Del./ 2018 vide Order Dated 22.11.2019, in which, on identical facts, the reopening of the assessment have been quashed. He has also relied upon Judgment of Hon’ble Delhi High Court in the case of Pr. CIT vs., RMG Polyvinyl (I) Ltd., [2017] 396 ITR 5 (Del.) in which it was held as under : “Where information was received from investigation wing that assessee was beneficiary of accommodation entries but no further inquiry was undertaken by Assessing Officer, said information could not be said to 8 ITA.Nos.4251 & 4252/Del./2018 Shri S.N. Arora/Sapra, New Delhi. be tangible material per se and, th…

S.N. Arora/Sapra, New Delhi vs. ITO, Ward- 23(2), New Delhi

In the result, appeal of the Assessee for the A

ITA 4251/DEL/2018[2006-07]Status: DisposedITAT Delhi30 Jan 2020AY 2006-07

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

For Appellant: Shri R.S. Singhvi, C.A. And Shri Satyajeet Goel, C.AFor Respondent: Ms. Rakhi Vimal, Sr. D.R
Section 143(1)Section 148Section 68

…lhi in ITA.No.5747/Del./ 2018 vide Order Dated 22.11.2019, in which, on identical facts, the reopening of the assessment have been quashed. He has also relied upon Judgment of Hon’ble Delhi High Court in the case of Pr. CIT vs., RMG Polyvinyl (I) Ltd., [2017] 396 ITR 5 (Del.) in which it was held as under : “Where information was received from investigation wing that assessee was beneficiary of accommodation entries but no further inquiry was undertaken by Assessing Officer, said information could not be said to 8 ITA.Nos.4251 & 4252/Del./2018 Shri S.N. Arora/Sapra, New Delhi. be tangible material per se and, th…

Behat Holdings Ltd., New Delhi vs. ITO Ward-4(3), New Delhi

In the result, appeal of Assessee allowed

ITA 8066/DEL/2019[2010-11]Status: DisposedITAT Delhi15 Jan 2020AY 2010-11

Bench: Shri Bhavnesh Saini & Shri N.K. Billaiya

For Appellant: Shri Deepesh Jain, C.A. And Shri Arpit Goel, C.AFor Respondent: Shri Ved Prakash Mishra, Sr. DR
Section 133(6)Section 147Section 148Section 151Section 68

…report without applying the mind. No right of cross-examination have been provided to the assessee to the statement of Shri Himanshu Verma and others. The assessee relied upon the following decisions. 3.1. In the case of Pr. CIT vs., RMG Polyvinyl (I) Ltd., 396 ITR 5 (Del.) the Hon’ble Delhi High Court held as under: "In the present case too, the information received from the Inv. Wing cannot be said to be tangible material per se without a further enquiry being undertaken by the learned assessing officer" 3.2. In the case of Pr. CIT vs., Meenakshi Overseas (P) Ltd., 395 ITR 677 (Del.), the Hon’ble Delhi High…

Goel Wax (P) Ltd., New Delhi vs. ITO, Ward-11(4), New Delhi

In the result, the Appeal filed by the Assessee stands partly allowed

ITA 2075/DEL/2018[2008-809]Status: DisposedITAT Delhi07 Jan 2020AY 2008-809

Bench: Shri H.S. Sidhuassessment Year : 2008-09

For Appellant: Sh. Raj Kumar, CAFor Respondent: Sh. Manoj Kumar Chopra, Sr. DR
Section 132Section 139(1)Section 143(2)Section 147Section 148Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES : SMC : NEW DELHI BEFORE SHRI H.S. SIDHU, JUDICIAL MEMBER Assessment Year : 2008-09 M/S GOEL WAX (P) LTD., Vs. ITO, WARD 11(4), C/O RAJ KUMAR & ASSOCIATES, NEW DELHI CAs, L-7A, SOUTH EXTENSION, PART-2, NEW DELHI – 49 (PAN: AAACG0121F) (Appellant) (Respondent) Assessee by : Sh. Raj Kumar, CA Department by : Sh. Manoj Kumar Chopra, Sr. DR. ORDER This appeal filed by the assessee is directed against the order passed by the Ld. CIT(A)-35, New Delhi on 01.12.2017 in relation to the assessment year 2008-09 on the following grounds:- 1. That under the facts and c…

Giggle Infotech Pvt. Ltd., New Delhi vs. ITO, Ward- 10(1), New Delhi

In the result, the Appeal filed by the Assessee stands partly allowed

ITA 1284/DEL/2018[2008-09]Status: DisposedITAT Delhi01 Jan 2020AY 2008-09

Bench: Shri H.S. Sidhuassessment Year : 2008-09

For Appellant: Sh. Deepak Ostwal, FCAFor Respondent: Sh. Pradeep Singh Gautam, Sr.DR
Section 132Section 139Section 143(2)Section 143(3)Section 147Section 148Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES : SMC : NEW DELHI BEFORE SHRI H.S. SIDHU, JUDICIAL MEMBER Assessment Year : 2008-09 M/S GIGGLE INFOTECH PVT. Vs. ITO, WARD 10(1), LTD., NEW DELHI C/O D. OSTWAL & ASSOCIATES, 310, COMPETENT HOUSE, F-14, MIDDLE CIRCLE, CONNAUGHT PLACE, NEW DELHI – 110 001 (PAN: AACCG6898F) (Appellant) (Respondent) Assessee by : Sh. Deepak Ostwal, FCA Department by : Sh. Pradeep Singh Gautam, Sr.DR.. ORDER This appeal filed by the assessee is directed against the order passed by the Ld. CIT(A)-35, New Delhi on 09.11.2017 in relation to the assessment year 2008-09 on the follo…

Charbuja Marmo (India) Pvt. Ltd., Delhi vs. Pr.CIT- 2, New Delhi

In the result, appeal of Assessee allowed

ITA 4749/DEL/2019[2010-11]Status: DisposedITAT Delhi31 Dec 2019AY 2010-11

Bench: Shri Bhavnesh Saini & Shri B.R.R. Kumar

For Appellant: Shri Kapil Goel, AdvocateFor Respondent: Ms. Nidhi Srivastava, CIT-DR
Section 143(1)Section 147Section 148Section 151Section 263

…sment order. In support of this contention, he has relied upon the Judgments of Hon’ble Delhi High Court in the case of CIT vs. Suren International (2013) 357 ITR 24 (Del.), Judgment of Delhi High Court in the case of PCIT vs. RMG Polyvinyl (I) Ltd., (2017) 396 ITR 5 (Del.) and Judgment of Delhi High Court in the case of SNG Developers Ltd., (2018) 404 ITR 312 (Del.). He has submitted that since re- assessment order was invalid and bad in law, therefore, same cannot be revised under section 263 of the I.T. Act. No cross-examination have been allowed to the statement of Shri 43 ITA.No.4749/Del./2019 M/s. Cha…

Integrated Global Solutions Pvt. Ltd, New Delhi vs. ACIT, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 4993/DEL/2012[2006-07]Status: DisposedITAT Delhi31 Dec 2019AY 2006-07

Bench: Ms. Sushma Chowlashri N.K. Billaiya[A.Y 2006-07]

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Shri S.N. Meena, Sr. DR
Section 127Section 132Section 143(3)Section 147Section 148

…stion 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.” 17. In another case of RMG Polyvinyl India Ltd the Hon'ble Jurisdictional High Court in 396 ITR 5 has held as under: “Information received from Investigation Wing could not be said to be tangible material per se without a further inquiry being undertaken by the Assessing Officer to establish link between tangible material and formation of reason to believe that income had escaped assessment and consequently, re assessment was unjustified.” 1…

Devki Nandan Bindal, New Delhi vs. ITO, Ward- 46(3), New Delhi

In the result, appeal of the Assessee allowed

ITA 4271/DEL/2019[2010-11]Status: DisposedITAT Delhi18 Dec 2019AY 2010-11

Bench: Shri Bhavnesh Saini & Shri B.R.R. Kumar

For Appellant: Shri Kapil Goel, AdvocateFor Respondent: Ms. Nidhi Srivastava, CIT-DR
Section 131Section 144Section 147Section 148

…ent is invalid. In support of this proposition, he has relied upon the decisions of the Delhi High Court in the case of G & G Pharma India Limited 384 ITR 147 (Del.) and PCIT vs., Meenakshi Overseas (P) Ltd., 395 ITR 677 (Del.) and PCIT vs., RMG Poly vinyl 396 ITR 5 (Del.). 23 ITA.No.4271/Del./2019 Shri Devki Nandan Bindal, Delhi. He has submitted that the reasons recorded are vague and no particulars of credit have been mentioned in the reasons. The reasons also did not say if assessment have already been framed under section 143(3). Even the nature of the credit is not mentioned in the reasons. No partic…