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.

M/S Suraj Pulses Pvt.Ltd., Delhi vs. Pr. CIT-8, New Delhi

In the result, the appeals of the Assessees are allowed

ITA 3010/DEL/2017[2008-09]Status: DisposedITAT Delhi06 Jul 2021AY 2008-09

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: S/Shri Shantanu Jain, AdvFor Respondent: Shri H.K. Choudhary, CIT-D.R
Section 133(6)Section 147Section 148Section 263

…he Act wherein the addition is also made of Rs.90,00,000/-. Thus, the facts mentioned in the proforma for reasons for reopening of the assessment are incorrect and non-existent. The Hon’ble High Court of Delhi in the case of PCIT vs. RMG Polyvinyl reported in 396 ITR 5 (Delhi) has held as under : “9. However, in neither of the above cases are the facts similar to those in the present case. The two glaring errors in the reasons in the present case are, in fact, unusual. What the AO might have done if he was aware, even at the stage of consideration of reopening of the assessment that a return had in fact been file…

M/S Suraj Pulses Pvt.Ltd., Delhi vs. Pr. CIT-8, New Delhi

In the result, the appeals of the Assessees are allowed

ITA 3009/DEL/2017[2007-08]Status: DisposedITAT Delhi06 Jul 2021AY 2007-08

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: S/Shri Shantanu Jain, AdvFor Respondent: Shri H.K. Choudhary, CIT-D.R
Section 133(6)Section 147Section 148Section 263

…he Act wherein the addition is also made of Rs.90,00,000/-. Thus, the facts mentioned in the proforma for reasons for reopening of the assessment are incorrect and non-existent. The Hon’ble High Court of Delhi in the case of PCIT vs. RMG Polyvinyl reported in 396 ITR 5 (Delhi) has held as under : “9. However, in neither of the above cases are the facts similar to those in the present case. The two glaring errors in the reasons in the present case are, in fact, unusual. What the AO might have done if he was aware, even at the stage of consideration of reopening of the assessment that a return had in fact been file…

Jai Prakash Gupta, Kolkata vs. ITO, Ward-37(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2142/KOL/2019[2013-14]Status: DisposedITAT Kolkata18 Jun 2021AY 2013-14

Bench: Shri A. T. Varkey, Jm]

Section 143(1)Section 147Section 148

…case of Pr. CIT vs. Meenakshi Overseas Pvt. Ltd. 395 ITR 677. ii) Decision of Hon’ble Delhi High Court in the case of Pr. CIT vs. G & G Pharma India Ltd. 387 ITR 147. iii) Decision of Hon’ble Delhi High Court in the case of Pr. CIT vs. RMG Polyvinyl (I) Ltd. 396 ITR 5 iv) Decision of Hon’ble Delhi High Court in the case of Sab Infrastructure Ltd. vs. ACIT 2017-(9)-TMI-1589. ITA No. 366/Del/2016 M/s Key Components (P) Ltd., Delhi. v) Decision of Hon’ble Delhi High Court in the case of CIT vs. Atul Jain 299 ITR 383. vi) Decision of Hon’ble Delhi High Court in the case of Shiv Sai Infrastructure Pvt. Ltd. vs. DCIT…

M/S Shri Shyam Sunder Infrastructure (P) Ltd., Delhi vs. ITO, New Delhi

In the result, appeal of the Assessee allowed

ITA 2106/DEL/2013[2003-04]Status: DisposedITAT Delhi19 May 2021AY 2003-04

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

For Appellant: Shri Vinod Kumar Bindal, CAFor Respondent: Shri Prakash Dubey, Sr. DR
Section 131Section 144Section 147Section 148Section 68

…s in support of our conclusion. 26 ITA.No.2106/Del./2013 Shri Shyam Sunder Infrastructure (P) Ltd., [Formerly known as M/s. Shalom Exim (P) Ltd., and then as Mamram Developers P. Ltd.,] Delhi. 7.6. In the case of Pr. CIT vs., RMG Polyvinyl (I) Ltd., [2017] 396 ITR 5 (Del.) the Hon’ble Delhi High Court 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 be tangible material per se and, thus, reassessment on said basis was not justified.” 7.…

M/S vs. R Enterprises, New Delhi

In the result, appeal of the Assessee allowed

ITA 1855/DEL/2016[2007-08]Status: DisposedITAT Delhi18 May 2021AY 2007-08

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastavaassessment Year : 2007-08

For Appellant: Sh. P.C. Yadav, AdvFor Respondent: Sh. Prakash Dubey, Sr. DR
Section 147Section 148Section 68

…taking to which section 10A applies could not be included in the total income of the assessee. Therefore, the petitioner was right in filing the return by excluding the income in terms of section 10A.” 6.6. 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" 6.7. In the case of Pr. CIT vs., Meenakshi Overseas (P) Ltd., 395 ITR 677 (Del.), the Hon’ble Delhi High…

Simranpal Singh Suri, New Delhi vs. ITO Ward 45(5), New Delhi

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

ITA 2821/DEL/2019[2010-11]Status: DisposedITAT Delhi12 May 2021AY 2010-11

Bench: Shri R.K. Pandaassessment Year: 2010-11 Simranpal Singh Suri, Vs Ito, Jg-1/77, Vikaspuri, Ward 45(5), New Delhi. New Delhi. Pan: Akzps3760Q (Appellant) (Respondent) Assessee By : Shri V.K. Sabharwal, Advocate Revenue By : Shri Farath Khan, Sr. Dr Date Of Hearing : 15.03.2021 Date Of Pronouncement : 12.05.2021 Order

For Appellant: Shri V.K. Sabharwal, AdvocateFor Respondent: Shri Farath Khan, Sr. DR
Section 133(6)Section 142(1)Section 144Section 147Section 148Section 151

…mind and had given approval in a mechanical manner. 9.1 It has been held in various decisions that reopening of the assessment on wrong set of facts makes such reopening a nullity. The Hon’ble Delhi High Court in the case of PCIT vs. RMG Polyvinyl (I) Ltd., 396 ITR 5, has held that reopening of the assessment on wrong set of facts makes the assessment a nullity. Similar view has been taken by the coordinate Benches of the Tribunal in the case of Shri Dheeraj Yadav vs. ITO vide ITA No.6701/Del/2019, order dated 01.01.2021, M/s Bull Riders Financial Services (P) Ltd. vs. ITO, vide ITA No.1891/Del/2017, order date…

Anand Pershad Jaiswal, New Delhi vs. DCIT (International Taxation), New Delhi

In the result, all appeals filed by the respective assesses are

ITA 3731/DEL/2016[2007-08]Status: DisposedITAT Delhi23 Apr 2021AY 2007-08

Bench: Shri R.K. Panda & Ms. Suchitra Kamble

For Appellant: Ms. R.S. Singhavi, CAFor Respondent: Dr. Prabha Kant CIT-DR
Section 147Section 148Section 149(1)(c)Section 151(2)

…on of jurisdiction u/s 148 is illegal and bad in law. 13.1. Referring to the following decisions, he submitted that reopening of the assessment u/s 148 of the Act is not in accordance with law and has to be quashed. i. PCIRT vs RMG Polyvinyl (I) Ltd. [2017] 396 ITR 5 (Delhi) ii. Gorika Investment and Exports Pvt. Ltd. vs ITO (ITA No.3396/Del/2018) He accordingly submitted that since the Assessing Officer has reopened the assessment in a mechanical manner, therefore such reopening of assessment has to be treated as null and void. 14. He submitted that the Assessing Officer in utter disregard of the provision…

Anand Pershad Jaiswal, New Delhi vs. DCIT (International Taxation), New Delhi

In the result, all appeals filed by the respective assesses are

ITA 3730/DEL/2016[2006-07]Status: DisposedITAT Delhi23 Apr 2021AY 2006-07

Bench: Shri R.K. Panda & Ms. Suchitra Kamble

For Appellant: Ms. R.S. Singhavi, CAFor Respondent: Dr. Prabha Kant CIT-DR
Section 147Section 148Section 149(1)(c)Section 151(2)

…on of jurisdiction u/s 148 is illegal and bad in law. 13.1. Referring to the following decisions, he submitted that reopening of the assessment u/s 148 of the Act is not in accordance with law and has to be quashed. i. PCIRT vs RMG Polyvinyl (I) Ltd. [2017] 396 ITR 5 (Delhi) ii. Gorika Investment and Exports Pvt. Ltd. vs ITO (ITA No.3396/Del/2018) He accordingly submitted that since the Assessing Officer has reopened the assessment in a mechanical manner, therefore such reopening of assessment has to be treated as null and void. 14. He submitted that the Assessing Officer in utter disregard of the provision…

Sh. Karamjit S. Jaiwswal, New Delhi vs. DCIT, New Delhi

In the result, all appeals filed by the respective assesses are

ITA 3248/DEL/2016[2007-08]Status: DisposedITAT Delhi23 Apr 2021AY 2007-08

Bench: Shri R.K. Panda & Ms. Suchitra Kamble

For Appellant: Ms. R.S. Singhavi, CAFor Respondent: Dr. Prabha Kant CIT-DR
Section 147Section 148Section 149(1)(c)Section 151(2)

…on of jurisdiction u/s 148 is illegal and bad in law. 13.1. Referring to the following decisions, he submitted that reopening of the assessment u/s 148 of the Act is not in accordance with law and has to be quashed. i. PCIRT vs RMG Polyvinyl (I) Ltd. [2017] 396 ITR 5 (Delhi) ii. Gorika Investment and Exports Pvt. Ltd. vs ITO (ITA No.3396/Del/2018) He accordingly submitted that since the Assessing Officer has reopened the assessment in a mechanical manner, therefore such reopening of assessment has to be treated as null and void. 14. He submitted that the Assessing Officer in utter disregard of the provision…

Sh. Karamjit S. Jaiwswal, New Delhi vs. DCIT, New Delhi

In the result, all appeals filed by the respective assesses are

ITA 3247/DEL/2016[2006-07]Status: DisposedITAT Delhi23 Apr 2021AY 2006-07

Bench: Shri R.K. Panda & Ms. Suchitra Kamble

For Appellant: Ms. R.S. Singhavi, CAFor Respondent: Dr. Prabha Kant CIT-DR
Section 147Section 148Section 149(1)(c)Section 151(2)

…on of jurisdiction u/s 148 is illegal and bad in law. 13.1. Referring to the following decisions, he submitted that reopening of the assessment u/s 148 of the Act is not in accordance with law and has to be quashed. i. PCIRT vs RMG Polyvinyl (I) Ltd. [2017] 396 ITR 5 (Delhi) ii. Gorika Investment and Exports Pvt. Ltd. vs ITO (ITA No.3396/Del/2018) He accordingly submitted that since the Assessing Officer has reopened the assessment in a mechanical manner, therefore such reopening of assessment has to be treated as null and void. 14. He submitted that the Assessing Officer in utter disregard of the provision…

Rajesh Gupta (HUF), New Delhi vs. ITO Ward - 31(4), New Delhi

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

ITA 5712/DEL/2019[2011-12]Status: DisposedITAT Delhi19 Apr 2021AY 2011-12

Bench: Shri R.K. Pandaassessment Year : 2011-12 Rajesh Gupta Huf, Vs. Ito, C/O-Raj Kumar & Associates, Ward-31(4), Chartered Accountants, R. No.1209, Civic Centre, L-7A (Lgf), South Extension New Delhi-110002 Part-Ii, New Delhi-110049 Pan-Aaghr9262M

For Appellant: Sh. Raj Kumar, CAFor Respondent: Sh. Farat Khan, Sr. DR
Section 143(1)Section 147Section 148

…sion of the Hon’ble Delhi High Court in the case of CIT vs Kamdhenu Steel & Alloys reported in 248 CTR 33(Del.), in the case of CIT vs Sh. Atul Jain and Vinit Jain reported in 292 ITR 383(Del.) and in the case of Pr. CIT vs Rmg Polyvinyl (I) Ltd. reported in 396 ITR 5(Del.). 7. The learned counsel for the assessee submitted that as per notice u/s 148, the case of the assessee was reopened after getting approval from the Pr.CIT-11, New Delhi. The assessee vide letters dated 02.05.2018 and 13.08.2018 requested the Assessing Officer to provide the copy of the approval taken u/s 151(1) of the Act. However, no su…

DCIT 8(2)(1), Mumbai vs. Shradha Tradelinks P. Ltd, Mumbai

ITA 656/MUM/2016[2008-09]Status: DisposedITAT Mumbai08 Apr 2021AY 2008-09

Bench: Shri Shamim Yahya () & Shri Ravish Sood () Deputy Commissioner Of M/S Shradha Tradelinks Income Tax-8(2)(1), Vs. Pvt. Ltd., 1108, Dalamal Aayakar Bhavan, Room Tower, Free Press No. 624, M.K. Road, Journal Marg, Mumbai – 400 020 Nariman Point, Mumbai – 400 021 Pan No. Aafcs1489R (Assessee) (Revenue) C.O No.323/Mum/2017 (Arising Out Of Ita No. 656/Mum/2016) (Assessment Year: 2008-09) M/S Shradha Tradelinks Deputy Commissioner Of Pvt. Ltd. Vs. Income Tax, Circle 7(2), 1108, Dalamal Tower, Aayakar Bhavan, Free Press Journal Marg, Mumbai – 400 020 Nariman Point, Mumbai – 400 021 Pan No. Aafcs1489R (Assessee) (Revenue) Assessee By : Shri Paresh Shaparia, A.R Revenue By : Shri R. Manjunatha Swamy, Cit D.R Date Of Hearing : 13/01/2021 Date Of Pronouncement : 08/04/2021

For Appellant: Shri Paresh Shaparia, A.RFor Respondent: Shri R. Manjunatha Swamy, CIT D.R
Section 132Section 143(3)Section 147

…order to have reasons to believe that the income of the assessee had escaped assessment was missing, the reopening of the assessment was not justified. Further, we find that the Hon’ble High Court of Delhi in the case of PCIT Vs. RMG Polyvinyl (I) Ltd. (2017) 396 ITR 5 (Del), relying on its earlier order in the case of Meenakshi Overseas Pvt. Ltd. (supra) had observed, that as the A.O in the case before them had merely acted upon the information received from the Investigation Wing without undertaking any further enquiry on his part thus, the link between the tangible material and the formation of the reasons to…

Sungrow Impex Private Limited, New Delhi vs. ITO Ward-24(3), New Delhi

In the result appeal of assessee allowed

ITA 4183/DEL/2019[2010-11]Status: DisposedITAT Delhi19 Mar 2021AY 2010-11

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

For Appellant: Shri P.C. Yadav, AdvocateFor Respondent: Shri Prakash Dubey, Sr. D.R
Section 143(1)Section 147Section 148Section 68

…plied his mind for forming the belief that income chargeable to tax has escaped assessment. In support of his contention he has relied upon following decisions:  Pr. CIT vs. Meenakshi Overseas Pvt. Ltd. 395 ITR 677 (Del.)  Pr. CIT vs. RMG Polyvinyl (I) Ltd. 396 ITR 5 (Del.) 23 ITA.No.4183/Del./2019 M/s. Sungrow Impex Private Limited, New Delhi.  Pr. CIT vs. G&G Pharma India Ltd. 384 ITR 147 (Del.)  Signature Hotels P. Ltd. Vs. ITO 338 ITR 51 (Del.) 13. Ld. Counsel for assessee submitted that it is, therefore, clear that reopening is based on incorrect facts. It is well settled law that if wrong facts and wr…

Savita Holdings Pvt. Ltd., Delhi vs. ITO, Ward- 22(4), New Delhi

ITA 1389/DEL/2019[2010-11]Status: DisposedITAT Delhi19 Mar 2021AY 2010-11

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

For Appellant: Shri Suresh Kumar Gupta, C.AFor Respondent: Shri Prakash Dubey, Sr. D.R
Section 143(1)Section 147Section 148Section 68Section 69A

…Ld. Counsel for the assessee in 9 ITA.No.1389/Del./2019 support of the proposition of law regarding non-application of the mind by the AO on the reasons recorded relied upon the judgment of Delhi High Court in the cases of M/s RMG Polyvinyl (I) Ltd. (2017) 396 ITR 5 (Del.), M/s G & G Pharma India Ltd., 384 ITR 147 (Del.), M/s Signature Hotels P. Ltd., 338 ITR 0051 (Del.) and M/s SFIL Stock Broking Ltd., 325 ITR 285. 6.1 Ld. Counsel for assessee submitted that it is settled position of law that the reasons for reopening of the assessment must be complete and a self explanatory demonstration the application…

Karan Khurana, Delhi vs. ITO, Ward- 48(2), New Delhi

In the result, the appeal of assessee is allowed

ITA 1783/DEL/2019[2010-11]Status: DisposedITAT Delhi17 Mar 2021AY 2010-11

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

For Appellant: Shri Suresh Gupta, C.AFor Respondent: Shri N.K. Bansal, Sr. D.R
Section 147Section 148Section 149(1)(b)Section 151

…ed his mind for forming the belief that income chargeable to tax has escaped assessment. In support of his contention he has relied upon following decisions: • Pr. CIT vs. Meenakshi Overseas Pvt. Ltd. 395 ITR 677 (Del.) • Pr. CIT vs. RMG Polyvinyl (I) Ltd. 396 ITR 5 (Del.) 22 ITA.No.1783/Del./2019 Shri Karan Khurana, Delhi. • Pr. CIT vs. G&G Pharma India Ltd. 384 ITR 147 (Del.) • Signature Hotels P. Ltd. Vs. ITO 338 ITR 51 (Del.) 13. Ld. Counsel for assessee submitted that it is, therefore, clear that reopening is based on incorrect facts. It is well settled law that if wrong facts and wrong reasons are re…

Chetan Rajnikant Shah, Mumbai vs. Income Tax Officer-24(1)(4), Mumbai

The appeal of the assessee is allowed in terms of our aforesaid observations

ITA 1948/MUM/2018[2007-08]Status: DisposedITAT Mumbai22 Feb 2021AY 2007-08

Bench: Shri Shamim Yahya & Shri Ravish Soodchetan Rajnikant Shah Income Tax Officer-24(1)-4, 703, Jamuna Vihar, Piramal Chambers, Parel, Vs. Juhu Lane, Andheri West, Mumbai – 400 012 Mumbai – 400058 Pan – Amqps6037D (Appellant) (Respondent)

For Appellant: Shri Mehul Shah, A.RFor Respondent: Ms. Shreekala Pardeshi, D.R
Section 131Section 132(4)Section 143(3)Section 147Section 148Section 68

…order to have reasons to believe that the income of the assessee had escaped assessment was missing, the reopening of the assessment was not justified. Further, we find that the Hon’ble High Court of Delhi in the case of PCIT Vs. RMG Polyvinyl (I) Ltd. (2017) 396 ITR 5 (Del), relying on its aforesaid order in the case of Meenakshi Overseas Pvt. Ltd. (supra) had observed, that as the A.O in the case before them had merely acted upon the information received from the Investigation Wing without undertaking any further enquiry on his part thus, the link between the tangible material and the formation of the reasons t…

Bishan Sharup Gupta, Delhi vs. ITO, Ward- 45(4), New Delhi

In the result, appeal of the Assessee allowed

ITA 8083/DEL/2019[2010-11]Status: DisposedITAT Delhi19 Feb 2021AY 2010-11

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

For Appellant: Shri Kapil Goel, AdvocateFor Respondent: Shri Ved Prakash Mishra, Sr. D.R
Section 131Section 147Section 148

…taking to which section 10A applies could not be included in the total income of the assessee. Therefore, the petitioner was right in filing the return by excluding the income in terms of section 10A.” 6.6. In the case of Pr. CIT vs., RMG Polyvinyl (I) Ltd., 396 ITR 5 (Del.) the Hon’ble Delhi High Court held as under: 23 ITA.No.8083/Del./2019 Shri Bishan Sharup Gupta, New Delhi. "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" 6.7. In the case of Pr. CIT vs., Meenakshi…

M/S vs. R Enterprises, New Delhi

In the result, appeal of the Assessee allowed

ITA 1856/DEL/2016[2008-09]Status: DisposedITAT Delhi17 Feb 2021AY 2008-09

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

For Appellant: Shri P.C. Yadav, AdvocateFor Respondent: Shri Prakash Dubey, Sr. D.R
Section 147Section 148Section 68

…taking to which section 10A applies could not be included in the total income of the assessee. Therefore, the petitioner was right in filing the return by excluding the income in terms of section 10A.” 6.6. 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" 6.7. In the case of Pr. CIT vs., Meenakshi Overseas (P) Ltd., 395 ITR 677 (Del.), the Hon’ble Delhi High…

Anita Chaudhary, Muzaffarnagar vs. ITO, Ward-2(5), Khatuli

In the result, appeal of assessee is allowed

ITA 1095/DEL/2018[2012-13]Status: DisposedITAT Delhi05 Feb 2021AY 2012-13

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Appellant: Shri Gaurav Bansal, C.AFor Respondent: Shri Rajesh Kumar, Sr. D.R
Section 147Section 148Section 151(2)Section 69A

…non-application of mind. Therefore, the reopening of the assessment may be quashed. He has relied upon the Judgments of Hon’ble Delhi High Court in the case of Pr. CIT vs., G & G Pharma India Ltd., [2016] 384 ITR 147 (Del.), Pr. CIT vs., RMG Polyvinyl [2017] 396 ITR 5 (Del.). 5. On the other hand, Ld. D.R. relied upon the Orders of the authorities below and submitted that A.O. has correctly recorded reasons for reopening of the assessment because there was a cash deposit in the ICICI Bank Account of the assessee, therefore, reopening of the assessment is justified in the matter. 6. We have considered the rival s…

Madhu Apartment Pvt. Ltd., Delhi vs. ITO, Ward- 16(1), New Delhi

In the result, appeal of the Assessee allowed

ITA 3870/DEL/2018[2010-11]Status: DisposedITAT Delhi02 Feb 2021AY 2010-11

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

For Appellant: Shri Suresh K. Gupta, C.AFor Respondent: Shri Prakash Dubey , Sr. DR
Section 147Section 151Section 68

…ided to the assessee to 36 ITA.Nos.3869 & 3870/Del./2018 M/s. Madhu Apartment Private Limited, Delhi. 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 Hi…