How many judgments cite Ranbaxy Laboratories Ltd. v. CIT?

398 judgments on BharatTax cite Ranbaxy Laboratories Ltd. v. CIT (336 ITR 136), spanning 2012 to 2026.

Which sections of the Income Tax Act does Ranbaxy Laboratories Ltd. v. CIT come up under?

It is most often cited in judgments turning on Section 147, Section 148, Section 143(3), Section 68, Section 142(1), Section 151.

Ranbaxy Laboratories Ltd. v. CIT

336 ITR 136High Court2011#183 most cited

What is Ranbaxy Laboratories Ltd. v. CIT authority for?

In reassessment proceedings under Section 147/148, the Assessing Officer can assess other income not specified in the original notice if the initial ground for reopening assessment is found to be valid. However, if the income for which the assessment was initially reopened is found not to have escaped assessment, the Assessing Officer cannot proceed to assess any other income.

398

judgments rely on this decision, according to BharatTax’s citation analysis of 367,368 Indian tax judgments — from 2012 to 2026.

Also referred to as

Ranbaxy Laboratories Ltd. v. CIT · Section 147 · Section 148 · reopening of assessment · scope of reassessment · income escaping assessment · other income assessed · initial reason for reopening · quashing reassessment · Jet Airways principle · reassessment proceedings

Also reported as

12 Taxmann.com 74200 Taxmann 242242 CTR 11760 DTR 77

Sections most often in play

Section 147 Section 148 Section 143(3)Section 68 Section 142(1)Section 151 Section 139(1)Section 143(1)

Issues it is cited on

section 148(2)income escaping assessment reason to believe kelvinator escapement of income reopening of assessment change of opinion notice under section 148 tangible material reassessment proceedings regular assessment service of notice

Judgments citing Ranbaxy Laboratories Ltd. v. CIT

DCIT, Circle- 16(2), New Delhi vs. Meneta Automotive Components Pvt. Ltd., New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 1058/DEL/2018[2008-09]Status: DisposedITAT Delhi07 Feb 2023AY 2008-09

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. G. C. Srivastava, Adv. &For Respondent: Sh. Bhagwati Charan, Sr. DR

Section 92C

…THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘I’, NEW DELHI Before Dr. B. R. R. Kumar, Accountant Member Sh. Yogesh Kumar US, Judicial Member ITA No. 1058/Del/2018 : Asstt. Year : 2008-09 DCIT, Vs Meneta Automotive Components Circle-16(2), Pvt. Ltd., 111, Rishab Corporate New Delhi-110002 Tower, 16, Community Centre, Karkarduma, Delhi-110092 (APPELLANT) (RESPONDENT) PAN No. AAECM8250H Assessee by : Sh. G. C. Srivastava, Adv. & Sh. Mayank Patawari, CA Revenue by : Sh. Bhagwati Charan, Sr. DR Date of Hearing: 21.11.2022 Date of Pronouncement: 07.02.2023 ORDER Per Dr. B. R. R. Kumar, Accountant Member: The pres…

Pradeep Kumar, Jhujhunu vs. ITO Ward -2, Jhujhunu

In the result, appeal of the assessee is allowed

ITA 370/JPR/2022[2011-12]Status: DisposedITAT Jaipur11 Jan 2023AY 2011-12

Bench: HON’BLE SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Sharwan Kumar Gupta, AdvocateFor Respondent: Ms Monisha Choudhary (JCIT)

Section 142(1)Section 143(3)Section 147Section 148Section 234A

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”SMC” JAIPUR Jh lanhi xkslkbZ] U;kf;d lnL; ds le{k BEFORE: HON’BLE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER vk;dj vihy la-@ITA No. 370/JP/2022 fu/kZkj.k o"kZ@Assessment Year : 2011-12. cuke Shri Pradeep Kumar The Income Tax Officer, Vs. S/o Dhanraj, ACTO, Ward 2, Choudhary Colony, W. No. 18, Jhunjhunu. Chirawa, The. Chirawa, Jhunjhunu. LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No. AUSPK 0411 F vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Shri Sharwan Kumar Gupta, Advocate. jktLo dh vksj ls@ Reve…

The Peria Karamalai Tea & Produce Co.Ltd., Coimbatore vs. The DCIT, Corporate Circle-1, Coimbatore

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

ITA 189/CHNY/2021[2014-15]Status: DisposedITAT Chennai08 Dec 2022AY 2014-15

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri R. Vijayaraghavan, AdvocateFor Respondent: Shri S. Senthil Kumaran, CIT

Section 143(3)Section 147Section 148Section 263Section 263(2)Section 80I

…ore the Tribunal. 5. Before us, the ld.counsel for the assessee stated that the issue is squarely covered by decision of Hon’ble Bombay High Court in the cases of CIT vs. Jet Airways (I) Ltd., (2011) 331 ITR 236 and Ranbaxy Laboratories Ltd., vs. CIT, (2011) 336 ITR 136, wherein it is held that the AO had jurisdiction to reassess income other than the income in respect of which proceedings u/s.147 of the Act were initiated but he was not justified in doing so, when the very reason for initiation of those proceedings ceased to survive. The ld.counsel argued that legislature could not be presumed to have intended…

Deputy Commissioner of Income Tax 13(2)(2), Mumbai vs. Sun Metallics & Alloys Private Limited, Mumbai

In the result, ITA No. 2628/Mum/2018 for A

ITA 2629/MUM/2018[2013-14]Status: DisposedITAT Mumbai21 Nov 2022AY 2013-14

Bench: Shri Kuldip Singh & Shri Gagan Goyal

For Appellant: Sh. K.Shivaram, Sr. Adv. &For Respondent: Sh. Satyapal Kumar, Sr. DR

Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “G”, MUMBAI BEFORE SHRI KULDIP SINGH, JUDICIAL MEMBER AND SHRI GAGAN GOYAL, ACCOUNTANT MEMBER ITA No. 2629/Mum/2018 (A.Y. 2013-14) Dy.CIT-13(2) (2), Room No. 146, 1st Floor, Aayakar Bhavan, M.K. Road, Mumbai-400020. ...... Appellant Vs. M/s. Sun Metallics & Alloys Pvt. Ltd. 14, Neha Industrial (W), Mumbai- 400067. PAN: AAPCS2702P ...... Respondent C.O. No. 95/Mum/2019 (A.Y. 2012-13) M/s. Sun Metallics & Alloys Pvt. Ltd. 14, Neha Industrial (W), Mumbai- 400067. PAN: AAPCS2702P ...... Appellant Vs. Dy.CIT-13(2)(2), Room No. 146, 1st Floor, Aayakar Bhavan, M.K. Roa…

Deputy Commissioner of Income Tax 13(2)(2), Mumbai vs. Sun Metallics & Alloys Private Limited, Mumbai

In the result, ITA No. 2628/Mum/2018 for A

ITA 2628/MUM/2018[2012-13]Status: DisposedITAT Mumbai21 Nov 2022AY 2012-13

Bench: Shri Kuldip Singh & Shri Gagan Goyal

For Appellant: Sh. K.Shivaram, Sr. Adv. &For Respondent: Sh. Satyapal Kumar, Sr. DR

Section 68

Golden Century Food Products P.Ltd, New Delhi vs. ITO, Ward-10(2), New Delhi

In the result, this appeal filed by the assessee stands allowed

ITA 6137/DEL/2019[2011-12]Status: DisposedITAT Delhi17 Nov 2022AY 2011-12

For Appellant: NoneFor Respondent: Shri Om Prakash, Sr. DR

Section 133Section 147Section 148

…mounting to Rs.26,95,000/- being unexplained credit in the books of account despite the fact that the same were duly confirmed and accepted by Ld AO. The assessee relies on the judgement of Ld. High Court of Delhi in case of Ranbaxy Laboratories Ltd V/s CIT [ 60 DTR 77 (2011)], wherein it has been held that where reasons for initiation of proceedings cease to exist/survive, no assessment can be framed u/s 147/148. 6) That under the facts & circumstances of the case the Ld. A.O. has erred under the law while making addition amounting to Rs. 53,900/- being unexplained expenditure which were not subject matter of No…

National Fertilizers Ltd., New Delhi vs. Addl. CIT, Range- 18, New Delhi

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

ITA 1148/DEL/2018[2011-12]Status: DisposedITAT Delhi02 Nov 2022AY 2011-12

Bench: Shri Anil Chaturvedia N D Shri Challa Nagendra Prasad

For Appellant: Shri Aman Garg, C. AFor Respondent: [CIT] – D. R

Section 43B

…and the decision of this Court in CIT vs. Bharat Heavy Electrical Ltd. [2013] 352 ITR 88 (Del) and upheld the order of the CIT (A). 7. The Court's attention is drawn by learned counsel for the Assessee to the decision in CIT v Ranbaxy Laboratories Ltd. (2011) 334 ITR 341 (Del). The ratio of the above decision is that where there are actuarial reports supporting the provision to meet a contingent liability, it cannot be gone behind by the Assessing Officer (AO) unless it is shown to be not basec jn any scientific or know financial principles. 8. It is sought to be urged by learned counsel for the Revenue that only…

ACIT, Circle- 17(2), New Delhi vs. National Fertilizers Ltd., New Delhi

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

ITA 1041/DEL/2018[2011-12]Status: DisposedITAT Delhi02 Nov 2022AY 2011-12

Bench: Shri Anil Chaturvedia N D Shri Challa Nagendra Prasad

For Appellant: Shri Aman Garg, C. AFor Respondent: [CIT] – D. R

Section 43B

Solvex Interchem Pvt. Ltd., Mumbai vs. ACIT- 2 (3)(2), Mumbai

ITA 6973/MUM/2018[2010-11]Status: DisposedITAT Mumbai31 Oct 2022AY 2010-11

Bench: Shri Kuldip Singhassessment Year: 2010-11

For Appellant: Shri Himanshu Gandhi, A.RFor Respondent: Shri Azhar Zain Vayal Parambath, D.R

Section 143(3)Section 147Section 147BSection 147CSection 148Section 151(2)Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “SMC”, MUMBAI BEFORE SHRI KULDIP SINGH, JUDICIAL MEMBER Assessment Year: 2010-11 M/s. Solvex Interchem Pvt. ACIT-2(3)(2), Ltd., Room No.552, 5th Floor, Office No.22, Vs. 43/45Rajbahadur Building, Aayakar Bhavan, Tamrind Lane, Fort, M.K. Road, Mumbai – 400 023 New Marine Lines, PAN: AAFCS4957A Mumbai - 400020 (Appellant) (Respondent) Present for: Assessee by : Shri Himanshu Gandhi, A.R. Revenue by : Shri Azhar Zain Vayal Parambath, D.R. Date of Hearing : 14 . 09 . 2022 Date of Pronouncement : 31 . 10 . 2022 O R D E R Per : Kuldip Singh, Judicial Member: The…

Pgs Premiere Conferencing Private Limited, Bangalore vs. Principal Commissioner of Income Tax-5, Bangalore

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

ITA 622/BANG/2020[2015-16]Status: DisposedITAT Bangalore21 Oct 2022AY 2015-16

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: --- None ---For Respondent: Sri.K.Sankar Ganesh, JCIT-DR

Section 143(3)Section 263

…ransactions and ld. PCIT is right in treating the order passed under Section 143(3) of the Act as erroneous insofar as it is prejudicial to the interests of the Revenue. 27. Similarly, the Hon'ble Delhi High Court had held in Ranbaxy Laboratories Ltd. vs CIT, 345 ITR 193 (Delhi)that non-reference to TPO renders the order ‘erroneous’ and prejudicial to Revenue.” (emphasis supplied) 9. In view of the aforesaid reasoning and the judicial pronouncements, cited supra, we uphold the order of the PCIT passed u/s 263 of the I.T.Act as correct and in accordance with law. It is ordered accordingly. 8 M/s.PGS Premiere Co…

Gautam Chand Kankaria, Kolkata vs. PCIT-9, Kolkata

In the result, the appeal of the assessee is allowed

ITA 284/KOL/2022[2013-14]Status: DisposedITAT Kolkata28 Sept 2022AY 2013-14

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

Section 143(1)Section 143(3)Section 147Section 148Section 151(1)Section 263

….4,55,239/- was not added to the total income of the assessee. The Hon’ble Bombay High Court in the case of CIT –vs.- Jet Airways reported in (2011) 331 ITR 236 (Bom.), Hon’ble Delhi High Court in the case of Ranbaxy Laboratories Limited –vs.- CIT reported in 336 ITR 136 (Del.), 5 Assessment Year: 2013-2014 Gautam Chand Kankaria Hon’ble Gujarat High Court in the case of CIT –vs.- Mohd. Juned Dadani (2013) 355 ITR 172 (Guj.) and Hon’ble Calcutta High Court in the case of Infinity Infotech, ITA No. 60 of 2014 has examined the scope of section 147 of the Income Tax Act and all the Hon’ble four High Courts are una…

Deputy Commissioner of Income Tax, Circle- Jorhat, Jorhat vs. M/S. Toor Finance Company Ltd, Jorhat

In the result, the appeal of the Revenue is dismissed

ITA 305/GTY/2018[2010-11]Status: DisposedITAT Guwahati20 Sept 2022AY 2010-11

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 143(1)Section 147Section 148

…ed during the reassessment proceedings. For buttressing its contention, it relied upon – (i) the judgment of the Hon’ble Bombay High Court in the case of CIT –vs.- Jet Airways (I) Limited (2011) 331 ITR 236; (ii) Ranbaxy Laboratories Limited –vs.- CIT (2011) 336 ITR 136 (Delhi High Court); (iii) CIT –vs.- Mohmed Junded Dadani 355 ITR page 172 (Gujarat High Court). The ld. 1st Appellate Authority has accepted this contention of the assessee raised by way of additional ground of appeal and deleted the additions. Though the ld. CIT(Appeals) has devoted roughly 30 pages on this proposition but hardly any discussio…

Commissioner of Income Tax (Exemption), Kolkata vs. B.P.Poddar Foundation for Education

In the result, the appeal filed by the revenue is dismissed and the

ITAT/143/2021HC Calcutta13 Sept 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 11(5)Section 13(1)(b)Section 13(1)(c)Section 13(1)(d)Section 133ASection 142(1)Section 143Section 143(2)Section 147Section 148

…(ii) Whether on the facts and circumstances of the case the Learned Income Tax Appellate Tribunal correctly interpret the decision reported in the case of Jet Airways (1) Limited reported 331 ITR 236 (Bom) and Ranbaxy Laboratories Ltd. reported in 336 ITR 136 (Del) on facts in the instant case? 2. We have heard Mr. Vipul Kundalia, learned Senior Standing Counsel assisted by Mr. Anurag Roy, learned Advocate for the appellants and Mr. Sourabh Bagaria assisted by Mr. Saumya Kegriwal and Mr. G.S. Gupta, learned Advocates for the respondents. 3. The respondent assessee filed the ret…

Shariuzzaman Shamsuzzaman Shaikh, Mumbia vs. Assistant Commissioner of Income Tax-26(3), Mumbai

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

ITA 5416/MUM/2019[2010-11]Status: DisposedITAT Mumbai05 Sept 2022AY 2010-11

Bench: Shri Pavan Kumar Gadale & Shri Gagan Goyalmr. Shafuzzaman Shamsuzzaman Shaikh Shop No.2, Building No.2, Mubarak Complex, V.B. Nagar, Kurla (West),Mumbai-400070 Pan: Ayips7233B ...... Appellant Vs. Acit-26(3), C-11, Pratyakshakar Bhavan, B.K.C,. Bandra (East), Mumbai-400051. ..... Respondent Appellant By : None Respondent By : Ms. Kavita Kaushik Date Of Hearing : 07/06/2022 Date Of Pronouncement : 05/09/2022 Order Per Gagan Goyal, A.M:

For Appellant: NoneFor Respondent: Ms. Kavita Kaushik

Section 147Section 148Section 151Section 69

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “SMC”, MUMBAI BEFORE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER AND SHRI GAGAN GOYAL, ACCOUNTANT MEMBER Mr. Shafuzzaman Shamsuzzaman Shaikh Shop No.2, Building No.2, Mubarak Complex, V.B. Nagar, Kurla (West),Mumbai-400070 PAN: AYIPS7233B ...... Appellant Vs. ACIT-26(3), C-11, Pratyakshakar Bhavan, B.K.C,. Bandra (East), Mumbai-400051. ..... Respondent Appellant by : None Respondent by : Ms. Kavita Kaushik Date of hearing : 07/06/2022 Date of pronouncement : 05/09/2022 ORDER PER GAGAN GOYAL, A.M: This appeal by the assessee is directed against the order of Commis…

Narayan Dutt, Panipat vs. ITO, Ward- 3, Panipat

In the result, the appeal is allowed as indicated above

ITA 412/DEL/2019[2010-11]Status: DisposedITAT Delhi24 Aug 2022AY 2010-11

Section 147Section 148

…income to income from other sources. Thus, in my view, it is against the settled principles of law. In this context, reliance can be placed on the following decisions: 1. CIT vs. Jet Airways (I) Ltd., 331 ITR 236 (Bom); 2. Ranbaxy Laboratories Ltd. Vs. CIT 336 ITR 136 (Del.). 4 ITA No.412/Del./2019 6. Thus, following the ratio laid down in the aforesaid judicial precedents, I delete the addition made by the assessing officer. 7. In the result, the appeal is allowed as indicated above. Order pronounced in the open court on 24th August, 2022. (SAKTIJIT DEY) JUDICIAL MEMBER Dated: 24th August, 2022. Mohan L…

Geetanjali Infraprojects Pvt Ltd, New Delhi vs. ITO Ward - 10(1), New Delhi

Appeal of the assessee is allowed

ITA 6919/DEL/2019[2010-11]Status: DisposedITAT Delhi17 Aug 2022AY 2010-11

Bench: Shri Kul Bharat

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

…l precedents in the cases of Oriental Bank of Commerce Vs. Addl. CIT WP(C) 2594/2013 dated 11.08.2014 (Del.); CIT Vs. Jet Airways (I) Ltd. (2011) 331 ITR 236 (Bom.); CIT Vs. Shri Ram Singh (2008) 306 ITR 343 (Raj.); Ranbaxy Laboratories Ltd. Vs. CIT (2011) 60 DTR 77 (Del.) dated 3.6.2011; Reliance Electricals and metals Pvt. Ltd. Vs. ITO – ITA no. 2069/Kol/2017 dated 13.4.2018; and Krishan Kumar Vs. ITO – ITA no. 3985/Del/2017 dated 15.12.2017, the impugned assessment order deserves to be quashed. 4. Learned DR opposed the submissions and supported the orders of the authorities below. 5. Heard the rival c…

Satya Dev Yadav, New Delhi vs. ITO Ward - 3, Rewari

In the result, the appeal is allowed, as indicated above

ITA 9183/DEL/2019[2011-12]Status: DisposedITAT Delhi11 Aug 2022AY 2011-12

Bench: Shri Saktijit Deyassessment Year: 2011-12

Section 147Section 148Section 234B

…addition made cannot be sustained. In support of such contention he relied upon the following decision: 1. CIT Vs. Jet Airways (I) Ltd., 331 ITR 236 (Bom.) 2. CIT Vs. Mohmed Juned Dadani (2013) 355 ITR 172 (Guj.) 3. Ranbaxy Laboratories Ltd. Vs. CIT [2011] 336 ITR 136 8. Learned Departmental Representative relied upon the observations of learned Commissioner (Appeals). 9. I have considered rival submissions and perused the materials on record. From a reading of the assessment order, it is evident, the reason for which the Assessing Officer reopened the assessment under section 147 of the Act is, the alleged…

Manish Mittal, Narnaul vs. ITO Ward - 1, Narnaul

ITA 1467/DEL/2020[2013-14]Status: DisposedITAT Delhi08 Aug 2022AY 2013-14

Bench: Sh. N. K. Billaiya & Sh. Yogesh Kumar Usassessment Year: 2013-14

Section 147Section 148

…the say of the Counsel that such assessment order is bad in law and deserved to be quashed. 10. Strong reliance was placed on the decision of the Hon’ble Bombay High Court in the case of Jet Airways India Limited 331 ITR 236 and Ranbaxy Laboratories Limited 336 ITR 136 (Del). 11. Per contra the DR strongly supported the findings of the AO and the CIT(A). 12. As mentioned elsewhere the reasons for reopening the assessment/ was cash deposit in the Savings Bank account amounting to Rs.53.73 lacs and purchased of immovable property amounting to Rs.27.63 lacs. However, the assessment has been completed by making a…

Rajesh Kumar, Narnaul vs. ITO Ward - 2, Narnaul

In the result, the appeal of the assessee is allowed

ITA 1465/DEL/2020[2013-14]Status: DisposedITAT Delhi03 Aug 2022AY 2013-14

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 1465/Del/2020 : Asstt. Year : 2013-14 Rajesh Kumar, Vs Income Tax Officer, Krishan Nagar, Narnaul, Ward-2, Mohindergarh, Narnaul, Narnaul, Haryana-123001 Haryana-123001 (Appellant) (Respondent) Pan No. Axqpk2406F Assessee By : Sh. Lalit Mohan, Ca & Ms. Monika Agarwal, Adv. Revenue By : Ms. Indu Bala Saini, Sr. Dr Date Of Hearing: 30.06.2022 Date Of Pronouncement: 03.08.2022

For Appellant: Sh. Lalit Mohan, CA &For Respondent: Ms. Indu Bala Saini, Sr. DR

Section 147Section 148Section 151

…respect to which income has escaped assessment, he may none the less, assess or reassess the income in respect of any issue which has escaped assessment and which comes to his notice subsequently in the course of the proceedings under the section. 2. [2011] 336 ITR 136 (Del) (Del) [IN THE DELHI HIGH COURT] RANBAXY LABORATORIES LTD. Vs. COMMISSIONER OF INCOME-TAX A. K. SIKRI and M. L. MEHTA JJ. June 3, 2011. Section(s): Income-tax Act, 1961, ss. 147,148 RE-ASSESSMENT — ITEMS OF INCOME SAID TO HAVE ESCAPED ASSESSMENT ON WHICH REASSESSMENT PROPOSED NOT ADDED BUT OTHER DEDUCTIONS REDUCED —NOT PERMISSIBLE —INCOM…

Shantilal Surji Gala, Bhandup West vs. Income Tax Officer – 29(3)(4), Mumbai

Appeal of the assessee is allowed

ITA 1833/MUM/2021[2011-12]Status: DisposedITAT Mumbai26 Jul 2022AY 2011-12

Bench: Shri Aby T Varkey & Shri Amarjit Singhassessment Years: 2011-12 M/S. Shantilal Surji Gala, Income Tax Officer – 29(3)(4), 603/C, Maven Mahavir C-10, Pratyaksh Bhavan, Universe, Room No.308, Vs. Lbs Road, Bkc, Bandra East, Bhandup West, Mumbai - 400051 Mumbai – 400 078 Pan: Ajrpg9242Q (Appellant) (Respondent) Present For: Assessee By : Shri Chintan Shah, A.R. Revenue By : Shri Amit Kumar Soni, D.R. Date Of Hearing : 11 . 07 . 2022 Date Of Pronouncement : 26 . 07 . 2022 O R D E R Per Amarjit Singh: This Appeal Is Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals), Nfac, Delhi.

For Appellant: Shri Chintan Shah, A.RFor Respondent: Shri Amit Kumar Soni, D.R

Section 143(3)Section 147Section 148

…e on the decision of Hon'ble Jurisdictional High Court in case of CIT vs. Jet Airways (I) Ltd. (2010) 195 taxman 117 (Bom.). The Ld. Counsel has also placed reliance on the decision of Hon’ble Delhi High Court in case of Ranbaxy Laboratory Ltd. vs. CIT (2011) 60 DTR 77 (Delhi-HC). 4. On the other hand, the Ld. D.R. supported the order of the lower authority. 5. Heard both the sides and perused the material on record. 3 M/s. Shantilal Surji Gala 6. Without reiterating the facts as elaborated above it is undisputed fact that the AO has not made any addition on the basis of which he formed reasons to believe that…