ACIT, New Delhi vs. Smt Urmila Chandulal Patel, New Delhi
Accordingly all the appeals of the revenue with respect to all these assesses are dismissed
ITA 1459/DEL/2015[2010-11]Status: DisposedITAT Delhi31 Dec 2018AY 2010-11
Bench: Shri Prashant Maharishi & Shri K.N.Charyacit, Vs. Rohan Patel, Central Circle-06, New Delhi 10, Executive Club Road, Chandanholla Mehrauli, New Delhi Pan: Asjpp8428L (Appellant) (Respondent) Acit, Vs. Himanshu Patel, Central Circle-06, New Delhi 10, Executive Club Road, Chandanholla Mehrauli, New Delhi Pan: Actpp8270C (Appellant) (Respondent) Acit, Vs. Praduman Patel, Central Circle-06, New Delhi 10, Executive Club Road, Chandanholla Mehrauli, New Delhi Pan: Ajhpp2206P (Appellant) (Respondent) Acit, Vs. Krish Patel, Central Circle-06, New Delhi 10, Executive Club Road, Chandanholla Mehrauli, New Delhi Pan: Aqvpp2875R (Appellant) (Respondent) Acit, Vs. Urmila Chandulal Patel, Central Circle-06, New Delhi 10, Executive Club Road, Chandanholla Mehrauli, New Delhi Pan: Aeipp1395R
For Appellant: Shri Raj Gupta, CAFor Respondent: Smt Sulekha Verma, CIT DR
Section 132Section 142Section 153Section 153C
…esent case, therefore, the failure of the AO to record a specific satisfaction as to how the recovered material belonged to the assessee in the note that preceded the notice issued under it, vitiates the assessments ‖ Pepsico India Holdings (P.) Ltd. Vs. ACIT 370 ITR 295 (DEL.) (9 - 16/RP 15) ―Para - 13. Having set out the position in law in the decision of this Court in the_ case of Pepsi Foods Pvt. Ltd. (supra), it must be seen as to whether the Assessing Officer of the searched person (the Jaipuria Group) could he said to have arrived at a satisfaction that the documents mentioned above belonged to the petitio…
