ACIT Circle-28(1), New Delhi vs. Modesty Garments, New Delhi
In the result, the appeal of the Revenue stands dismissed
ITA 183/DEL/2020[2014-15]Status: DisposedITAT Delhi29 Mar 2023AY 2014-15
Bench: Shri Shamim Yahya & Ms. Astha Chandraasstt. Year: 2014-15 Acit Vs. M/S Modesty Garments, Circle-28(1), B-304, New Friends Colony, New Delhi. New Delhi – 110 065 Pan Aaafm1598F (Appellant) (Respondent)
For Appellant: Sh. Mohit Gupta, CA, Sh. NeerajFor Respondent: Shri Sumit Kumar Verma, Sr. DR
Section 143(1)Section 194A(3)(iv)Section 194ISection 37(1)Section 40Section 68
…from the sale deed itself that the land was allotted to the assessee firm in the year 2008 i.e., beyond a period of thirty six months. 10.9 I have also found that the High Court of Madras in the case of South India Mineral Corporation Ltd. Vs ACIT Chennai in 417 ITR 306 (Madras) it is specifically held in para 18 & 19 as under:- 8 & CO No 132/Del/2022 "18. We agree with the learned counsel for the Revenue to a certain extent that the circular was issued bearing in mind the cases arising under Sections 54 and 54A of the TP Act, more particularly, relating to residential accommodation, but what we note from the…