SSP Aviation Ltd. v. Deputy Commissioner of Income Tax

346 ITR 177High Court2012#252 most cited

What is SSP Aviation Ltd. v. Deputy Commissioner of Income Tax authority for?

The date of initiation of search or requisition for the purpose of abatement of assessment proceedings is the date of search or requisition, or the date of receipt of seized documents by the jurisdictional Assessing Officer, whichever is later. Proceedings under section 153C can only be initiated by the Assessing Officer of the searched person after being satisfied that seized documents belong to another person.

308

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2015 to 2026.

Also referred to as

SSP Aviation Ltd vs DCIT · section 153C · section 132 · abatement of assessment · search initiation date · requisition date · satisfaction of AO · seized documents · jurisdictional AO

Also reported as

20 Taxmann.com 214207 Taxmann 260252 CTR 291

Sections most often in play

Section 153CSection 153ASection 143(3)Section 132Section 147Section 148Section 151Section 149

Issues it is cited on

section 153atosection 153b(1)(a)abatement of assessmentsection 153(c)(1)section 153c proceedingssection 158bdsection 153b(1)section 153c(1)section 153(c)section 113section 4(1)section 158bb(1)

Judgments citing SSP Aviation Ltd. v. Deputy Commissioner of Income Tax

ITO, Ward- 6(4), New Delhi vs. Creative Techno Solutions Pvt. Ltd., New Delhi

ITA 4265/DEL/2017[2012-13]Status: DisposedITAT Delhi27 Feb 2025AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…on Society, 2015 SCC OnLine Bom 3922 : (2015) 378 ITR 84] , SCC OnLine Bom para 8) " 8. Reliance on the judgment of the Division Bench of the High Court of Delhi reported in SSP Aviation Ltd. v. CIT [SSP Aviation Ltd. v. CIT, 2012 SCC OnLine Del 1898 : (2012) 346 ITR 177] is misplaced. There, search was carried out in the case of "P" group of companies. It was found that the assessee before the Hon'ble Delhi High Court had acquired certain development rights from "P" group of companies. Based thereon, the satisfaction was recorded by the assessing officer and he issued notice in terms of Section 153-C. Thereupon…

Pr. Commissioner of Income Tax (Central)- 3 vs. M/S Ridgeview Construction Pvt. Ltd

ITA/618/2019HC Delhi13 Feb 2025

Bench: HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR,HON'BLE MR. JUSTICE YASHWANT VARMA

Section 133ASection 153C

…iety, 2015 SCC OnLine Bom 3922 : (2015) 378 ITR 84] , SCC OnLine Bom para 8) “8. Reliance on the judgment of the Division Bench of the High Court of Delhi reported in SSP Aviation Ltd. v. CIT [SSP Aviation Ltd. v. CIT, 2012 SCC OnLine Del 1898 : (2012) 346 ITR 177] is misplaced. There, search was carried out in the case of “P” group of companies. It was found that the assessee before the Hon' ble Delhi High Court had acquired certain development rights from “P” group of companies. Based thereon, the satisfaction was recorded by the assessing officer and he issued notice in terms of Section 153-C. Th…

Reena Mittal, New Delhi vs. DCIT Central Circle-31, New Delhi

In the result, appeal of the Assessee is partly allowed as indicated above

ITA 1238/DEL/2024[2021-22]Status: DisposedITAT Delhi04 Feb 2025AY 2021-22

Bench: Shri Shamim Yahya & Shri Vimal Kumara.Yr. : 2021-22 Reena Mittal, Vs. Dcit, H.No. 69, West Avenue Road, Central Circle-31, Punjabi Bagh, New Delhi 3Rd Floor, Ara Centre, New Delhi – 110 055 (Pan: Aajpg3891Q) Jnahdewalan Extension, New Delhi -55 (Appellant) (Respondent)

For Appellant: Sh. Suresh Gupta, CAFor Respondent: Ms. Harpreet Kaur Hansra, Sr. D.R
Section 143(3)Section 153CSection 153C(1)

…cision of Hon’ble Jurisdictional Delhi High Court and also on the decision of ITO vs Vikram Sujit Kumar Bhatia 453 ITR 417 (SC), CIT vs Jasjit Singh CA No.6566 of 2023 (SC) dated 26.09.2023, CIT vs RRJ Securities Ltd 380 ITR 612 (Del) and SSP Aviation vs DCIT 346 ITR 177 (Del), the legal proposition emerging is that relevant AY's for the purpose of issue of notice u/s 153C will be counted backward taking the assessment year of the search under proviso to sec 153C as the starting point. If period of six years computed from AY 2022-23 being the year of search as per proviso to sec 153C(1), the present assessment ye…

Chitar Pal, Gurgaon vs. ITO, Ward-1(3), Gurgaon

In the result, appeals of Revenue in ITA No

ITA 3694/DEL/2023[2017-18]Status: DisposedITAT Delhi30 Jan 2025AY 2017-18

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: M/s Chinu BhasinFor Respondent: Shri Monika Singh, CT-DR
Section 1Section 153C

…evant date in the case of a non-searched person being regulated by the First Proviso of Section 153C(1) is an issue which is no longer res integra and stands authoritatively settled by virtue of the decisions of this Court in SSP Aviation Ltd v. Dy.CIT (2012) 346 ITR 177 ( Delhi)( HC) and CIT v. RRJ Securities Ltd 2015 SCC Online Del 13085 as well as the decision of the Supreme Court in CIT v Jasjit Singh 2023 SCC Online SC1265. The aforesaid legal position also stood reiterated by the Supreme Court in ITO v. Vikram Sujitkumar Bhatia 2023 SCC Online SC 370. The submission of the revenue, therefore, that the block…

Arti Dhall, New Delhi vs. DCIT Central Circle-31, New Delhi

In the result, appeal of the Assessee is partly allowed as

ITA 1239/DEL/2024[2021-22]Status: DisposedITAT Delhi28 Jan 2025AY 2021-22

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraआ.अ.सं/.I.T.A No.1239/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22

Section 132Section 143(3)Section 153CSection 153C(1)Section 45

…I.T.A.No.1239/Del/2024 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “A” NEW DELHI BEFORE SHRI CHALLA NAGENDRA PRASAD, JUDICIAL MEMBER AND SHRI AVDHESH KUMAR MISHRA, ACCOUNTANT MEMBER आ.अ.सं/.I.T.A No.1239/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22 Arti Dhall बनाम DCIT H.No.71, Shivaji Park, Vs. Central Circle-31, 3rd Floor, ARA Centre, New Delhi. PAN No.AAJPG3892P Jhandewalan Extension, New Delhi. अपीलाथ" Appellant ""यथ"/Respondent CA Suresh Kumar Gupta Assessee by Revenue by Mr. Javed Akhtar, CIT DR सुनवाईक"तारीख/ Date of hearing: 09.01.2025 28.01.2025 उ"ोषणाक"तारीख/Pronouncement on आदेश /O R D E R PER…

The Modern Construction Co. Pvt. Ltd., Ahmedabad vs. ITO, Ward-2(1)(4), Ahmedabad

The appeal of the assessee is allowed for statistical

ITA 432/AHD/2019[2013-14]Status: DisposedITAT Ahmedabad23 Jan 2025AY 2013-14

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Tushar Hemani, Sr.AdvocateFor Respondent: Dr. Darsi Suman Ratnam, CIT-DR
Section 132Section 153ASection 153CSection 250(6)Section 271(1)(c)

…आयकर अपीलीय अधिकरण, अहमदाबाद न्यायपीठ 'D' अहमदाबाद। IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, AHMEDABAD BEFORE SMT.ANNAPURNA GUPTA, ACCOUNTANT MEMBER AND SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER ITA No.3464/Ahd/2016 AND ITA No.432/Ahd/2019 Assessment Year :2013-14 The Modern Construction Co. Vs. The DCIT, Cent.Cir.1(1) Pvt. Ltd. 5th Floor, H.K. House Ashram Road Ahmedabad. PAN : AAACM 5823 Е Ashram Road Ahmedabad. ITA No.3465/Ahd/2016 Assessment Year : 2013-14 The United Builders Vs. The DCIT, Cent.Cir.1(1) Corporation 23, Arjav Co-op Housing Society, Satellite Road Ahmedabad. Ashram Road Ahmedabad. PAN…

The United Builders Corporation, Ahmedabad vs. Dy.CIT, Central Circle-1(1), Ahmedabad

The appeal of the assessee is allowed for statistical

ITA 3465/AHD/2016[2013-14]Status: DisposedITAT Ahmedabad23 Jan 2025AY 2013-14

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

Section 132Section 153ASection 153CSection 250(6)Section 271(1)(c)

…आयकर अपीलीय अधिकरण, अहमदाबाद न्यायपीठ 'D' अहमदाबाद। IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, AHMEDABAD BEFORE SMT.ANNAPURNA GUPTA, ACCOUNTANT MEMBER AND SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER ITA No.3464/Ahd/2016 AND ITA No.432/Ahd/2019 Assessment Year :2013-14 The Modern Construction Co. Vs. The DCIT, Cent.Cir.1(1) Pvt. Ltd. 5th Floor, H.K. House Ashram Road Ahmedabad. PAN : AAACM 5823 Е Ashram Road Ahmedabad. ITA No.3465/Ahd/2016 Assessment Year : 2013-14 The United Builders Vs. The DCIT, Cent.Cir.1(1) Corporation 23, Arjav Co-op Housing Society, Satellite Road Ahmedabad. PAN : AAAFU 6786 D Ashram R…

Modern Construction Co. Pvt. Ltd., Ahmedabad vs. The Dy.CIT, Central Circle-1(1), Ahmedabad

The appeal of the assessee is allowed for statistical

ITA 3464/AHD/2016[2013-14 (Q-4)]Status: DisposedITAT Ahmedabad23 Jan 2025

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Tushar Hemani, Sr.AdvocateFor Respondent: Dr. Darsi Suman Ratnam, CIT-DR
Section 132Section 153ASection 153CSection 250(6)Section 271(1)(c)

…आयकर अपीलीय अधिकरण, अहमदाबाद न्यायपीठ 'D' अहमदाबाद। IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, AHMEDABAD BEFORE SMT.ANNAPURNA GUPTA, ACCOUNTANT MEMBER AND SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER ITA No.3464/Ahd/2016 AND ITA No.432/Ahd/2019 Assessment Year :2013-14 The Modern Construction Co. Vs. The DCIT, Cent.Cir.1(1) Pvt. Ltd. 5th Floor, H.K. House Ashram Road Ahmedabad. PAN : AAACM 5823 Е The United Corporation Ashram Road Ahmedabad. Ashram Road Ahmedabad. ITA No.3465/Ahd/2016 Assessment Year : 2013-14 Builders Vs. The DCIT, Cent.Cir.1(1) 23, Arjav Co-op Housing Society, Satellite Road Ahmedabad. PAN…

Partistha Commercial Centre Private Limited, Delhi vs. Commissioner of Income Tax (Appeals), Delhi

ITA 4264/DEL/2024[2016-17]Status: DisposedITAT Delhi23 Jan 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…on Society, 2015 SCC OnLine Bom 3922 : (2015) 378 ITR 84] , SCC OnLine Bom para 8) " 8. Reliance on the judgment of the Division Bench of the High Court of Delhi reported in SSP Aviation Ltd. v. CIT [SSP Aviation Ltd. v. CIT, 2012 SCC OnLine Del 1898 : (2012) 346 ITR 177] is misplaced. There, search was carried out in the case of "P" group of companies. It was found that the assessee before the Hon'ble Delhi High Court had acquired certain development rights from "P" group of companies. Based thereon, the satisfaction was recorded by the assessing officer and he issued notice in terms of Section 153-C. Thereupon…

DCIT, Ghaziabad vs. M/S. Devidayal Aluminium Industries Pvt. Ltd., Ghaziabad

ITA 4297/DEL/2016[2013-14]Status: DisposedITAT Delhi08 Jan 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…on Society, 2015 SCC OnLine Bom 3922 : (2015) 378 ITR 84] , SCC OnLine Bom para 8) " 8. Reliance on the judgment of the Division Bench of the High Court of Delhi reported in SSP Aviation Ltd. v. CIT [SSP Aviation Ltd. v. CIT, 2012 SCC OnLine Del 1898 : (2012) 346 ITR 177] is misplaced. There, search was carried out in the case of "P" group of companies. It was found that the assessee before the Hon'ble Delhi High Court had acquired certain development rights from "P" group of companies. Based thereon, the satisfaction was recorded by the assessing officer and he issued notice in terms of Section 153-C. Thereupon…

Dharmendra Kumar, Sambhal vs. ITO, Ward-2(5), Chandausi

In the result, appeals of Revenue in ITA No

ITA 3698/DEL/2023[2017-18]Status: DisposedITAT Delhi03 Jan 2025AY 2017-18

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Monika Singh, CT-DR
Section 153Section 153C

…evant date in the case of a non-searched person being regulated by the First Proviso of Section 153C(1) is an issue which is no longer res integra and stands authoritatively settled by virtue of the decisions of this Court in SSP Aviation Ltd v. Dy.CIT (2012) 346 ITR 177 ( Delhi)( HC) and CIT v. RRJ Securities Ltd 2015 SCC Online Del 13085 as well as the decision of the Supreme Court in CIT v Jasjit Singh 2023 SCC Online SC1265. The aforesaid legal position also stood reiterated by the Supreme Court in ITO v. Vikram Sujitkumar Bhatia 2023 SCC Online SC 370. The submission of the revenue, therefore, that the block…

Mukul Rani Thakur, Dehradun vs. Deputy Commissioner of Income Tax, Central Circle-31, Delhi, New Delhi

In the result, the appeal of the assessee is allowed

ITA 1483/DEL/2024[2021-22]Status: DisposedITAT Delhi20 Nov 2024AY 2021-22

Bench: Shri Pradip Kumar Kedia & Shri Pradip Kumar Kedia & Shri Pradip Kumar Kedia & Shri Vimal Kumarshri Vimal Kumar

Section 143Section 143(3)Section 153DSection 250Section 65B

…No.6566 of Singh CA No.6566 of 2023 (SC) dated 26.09.2023, CIT vs RRJ Securities Ltd 380 ITR 612 2023 (SC) dated 26.09.2023, CIT vs RRJ Securities Ltd 380 ITR 612 2023 (SC) dated 26.09.2023, CIT vs RRJ Securities Ltd 380 ITR 612 (Del) and SSP Aviation vs DCIT 346 ITR 177 (Del), the legal (Del) and SSP Aviation vs DCIT 346 ITR 177 (Del), the legal (Del) and SSP Aviation vs DCIT 346 ITR 177 (Del), the legal proposition emerging is that relevant AY's for the purpose of issue of proposition emerging is that relevant AY's for the purpose of issue of proposition emerging is that relevant AY's for the purpose of issue o…

Deputy Commissioner of Income Tax, Central Circle 1(2), Chennai vs. Bondalapati Shivaji Rao, Chennai

In the result, appeal filed by the assessee stands allowed and appeal filed by the Revenue is dismissed

ITA 1103/CHNY/2023[2019-20]Status: DisposedITAT Chennai18 Sept 2024AY 2019-20

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1044/Chny/2023 िनधा"रण वष"/Assessment Year: 2019-20 V. Shri Bondalapati Shivaji Rao, The Dcit, 121, Shankar Nagar, M.G. Road, Central Circle-1(2), Pammal, Chennai-600 075. Chennai. [Pan: Aahpb 0083 D] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.1103/Chny/2023 िनधा"रण वष"/Assessment Year: 2019-20 V. The Dcit, Shri Bondalapati Shivaji Rao, Central Circle-1(2), 121, Shankar Nagar, Chennai. M.G. Road, Pammal, Chennai-600 075. [Pan: Aahpb 0083 D] (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri B. Ramakrishnan, FCAFor Respondent: Shri V. Nandakumar, CIT
Section 127Section 132Section 143(2)Section 143(3)Section 153C

…wing decisions:- − CIT v. Jasjit Singh (458 ITR 437) (SC) − ITO v. Vikram Sujitkumar Bhatia (453 ITR 417) (SC) − Pr.CIT Vs Ojjus Medicare (P) Ltd (465 ITR 101) (Del HC) − A.R. Safiullah v. ACIT (W.P (MD) No.4327 of 2021) (Mad HC) − SSP Aviation Ltd. v. DCIT (346 ITR 177) (Del HC) − Pepsi Foods Pvt. Ltd. v. ACIT (367 ITR 112) (Del HC) − CIT v. RRJ Securities Ltd. (380 ITR 612) (Del HC) − PCIT v. R.L. Allied Industries (ITA No.370/2015) (Del HC) − CIT v. Gopi Apartments (365 ITR 411) (All.HC) ITA No.1103/Chny/2023 (AY 2019-20) Bondalapati Shivaji Rao :: 5 :: 5. Per contra, the Ld. CIT, DR appearing for the Revenu…

Bondalapati Shivaji Rao, Chennai vs. Assistant Commissioner of Income Tax, Central Circle - 1(2), Chennai

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

ITA 1044/CHNY/2023[AY 2019-20]Status: DisposedITAT Chennai18 Sept 2024

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1044/Chny/2023 निर्धारण वर्ष/Assessment Year: 2019-20 Shri Bondalapati Shivaji Rao, 121, Shankar Nagar, M.G. Road, Pammal, Chennai-600 075. [Pan: Aahpb 0083 D] (अपीलार्थी/Appellant) The Dcit, Central Circle-1(2), Chennai. (अपीलार्थी/Appellant) V. The Dcit, Central Circle-1(2), Chennai. (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita No.1103/Chny/2023 निर्धारण वर्ष/Assessment Year: 2019-20 V. Shri Bondalapati Shivaji Rao, 121, Shankar Nagar, M.G. Road, Pammal, Chennai-600 075. [Pan: Aahpb 0083 D] (प्रत्यर्थी/Respondent) Assessee By : Shri B. Ramakrishnan, Fca Shri S. Dwarakesh, Ca Shri Shrenik Chordia, Ca Department By : Shri V. Nandakumar, Cit सुनवाईकीतारीख/Date Of Hearing : 08.08.2024 घोषणाकीतारीख /Date Of Pronouncement : 18.09.2024 आदेश / Order Per Aby T. Varkey, Jm: These Appeals Preferred By The Assessee & The Revenue Are Against The Order Of The Learned Commissioner Of Income Tax (Appeals)- 18, Chennai (Hereinafter In Short `The Ld.Cit(A)') Dated 26.07.2023 Passed For Assessment Year (Hereinafter In Short `Ay') 2019-20.

For Appellant: Shri B. Ramakrishnan, FCAFor Respondent: Shri V. Nandakumar, CIT
Section 127Section 132Section 143(2)Section 143(3)Section 153C

…n the following decisions:- CIT v. Jasjit Singh (458 ITR 437) (SC) ITO v. Vikram Sujitkumar Bhatia (453 ITR 417) (SC) Pr.CIT Vs Ojjus Medicare (P) Ltd (465 ITR 101) (Del HC) A.R. Safiullah v. ACIT (W.P (MD) No.4327 of 2021) (Mad HC) SSP Aviation Ltd. v. DCIT (346 ITR 177) (Del HC) Pepsi Foods Pvt. Ltd. v. ACIT (367 ITR 112) (Del HC) CIT v. RRJ Securities Ltd. (380 ITR 612) (Del HC) PCIT v. R.L. Allied Industries (ITA No.370/2015) (Del HC) CIT v. Gopi Apartments (365 ITR 411) (All.HC) ITA No.1044/Chny/2023 (AY 2019-20) ITA No.1103/Chny/2023 (AY 2019-20) Bondalapati Shivaji Rao :: 5 :: 5. Per contra, the Ld. CIT, D…

D G Land Developers Private Limited, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle -4(4), Central Range - 4, Mumbai

ITA 411/MUM/2024[2013-14]Status: DisposedITAT Mumbai22 Aug 2024AY 2013-14
Section 132Section 133ASection 143(3)Section 153CSection 234BSection 234CSection 274Section 43C

…h Court has rightly distinguished the said judgment as not applicable giving the following reasons: "8. Reliance on the judgment of the Division Bench of the High Court of Delhi reported in case of SSP Aviation Ltd. v. Deputy Commissioner of Income Tax [2012] 346 ITR 177 is misplaced. There, search was carried out in the case of "P" group of companies. It was found that the assessee before the Hon'ble Delhi High Court had acquired certain development rights from "P" group of companies. Based thereon, the satisfaction was recorded by the Assessing Officer and he issued notice in terms of Section 153C. Thereupon th…

D G Land Developers Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Central Circle - 12(2)(1), Mumbai

ITA 407/MUM/2024[2014-15]Status: DisposedITAT Mumbai22 Aug 2024AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

Section 132Section 133ASection 143(3)Section 153CSection 234BSection 234CSection 274Section 43C

…h Court has rightly distinguished the said judgment as not applicable giving the following reasons: "8. Reliance on the judgment of the Division Bench of the High Court of Delhi reported in case of SSP Aviation Ltd. v. Deputy Commissioner of Income Tax [2012] 346 ITR 177 is misplaced. There, search was carried out in the case of "P" group of companies. It was found that the assessee before the Hon'ble Delhi High Court had acquired certain development rights from "P" group of companies. Based thereon, the satisfaction was recorded by the Assessing Officer and he issued notice in terms of Section 153C. Thereupon th…

D G Land Developers Private Limited, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle -4(4), Mumbai

In the result, the appeals of the assessee for assessment year

ITA 404/MUM/2024[2015-16]Status: DisposedITAT Mumbai22 Aug 2024AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

For Respondent: Mr. Sanjeev Mehta a/w Saurabh
Section 132Section 4

…the High Court "8. Reliance on the judgment of the Division Bench of the High Court of Delhi reported in case of Delhi reported in case of SSP Aviation Ltd. v. Deputy of SSP Aviation Ltd. v. Deputy Commissioner of Income Tax Commissioner of Income Tax [2012] 346 ITR 177 is misplaced. There, is misplaced. There, search was carried out in the case of "P" group of companies. It was search was carried out in the case of "P" group of companies. It was search was carried out in the case of "P" group of companies. It was found that the assessee before the Hon'ble Delhi High C found that the assessee before the Hon'ble…

D G Land Developers Private Limited, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle -4(4), Mumbai

In the result, the appeals of the assessee for assessment year

ITA 403/MUM/2024[2016-17]Status: DisposedITAT Mumbai22 Aug 2024AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

For Respondent: Mr. Sanjeev Mehta a/w Saurabh
Section 132Section 4

…the High Court "8. Reliance on the judgment of the Division Bench of the High Court of Delhi reported in case of Delhi reported in case of SSP Aviation Ltd. v. Deputy of SSP Aviation Ltd. v. Deputy Commissioner of Income Tax Commissioner of Income Tax [2012] 346 ITR 177 is misplaced. There, is misplaced. There, search was carried out in the case of "P" group of companies. It was search was carried out in the case of "P" group of companies. It was search was carried out in the case of "P" group of companies. It was found that the assessee before the Hon'ble Delhi High C found that the assessee before the Hon'ble…

D G Land Developers Private Limited, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle -4(4), Mumbai

In the result, the appeals of the assessee for assessment year

ITA 402/MUM/2024[2017-18]Status: DisposedITAT Mumbai22 Aug 2024AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

For Respondent: Mr. Sanjeev Mehta a/w Saurabh
Section 132Section 4

…the High Court "8. Reliance on the judgment of the Division Bench of the High Court of Delhi reported in case of Delhi reported in case of SSP Aviation Ltd. v. Deputy of SSP Aviation Ltd. v. Deputy Commissioner of Income Tax Commissioner of Income Tax [2012] 346 ITR 177 is misplaced. There, is misplaced. There, search was carried out in the case of "P" group of companies. It was search was carried out in the case of "P" group of companies. It was search was carried out in the case of "P" group of companies. It was found that the assessee before the Hon'ble Delhi High C found that the assessee before the Hon'ble…

John Distilleries Pvt Ltd., Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(1), Bangalore

In the result, appeals of the assessee in ITA No

ITA 987/BANG/2023[2016-17]Status: DisposedITAT Bangalore24 Jul 2024AY 2016-17

Bench: Shri Chandra Poojari & Shri Keshav Dubey

…h Court has rightly distinguished the said judgment as not applicable giving the following reasons: "8. Reliance on the judgment of the Division Bench of the High Court of Delhi reported in case of SSP Aviation Ltd. v. Deputy Commissioner of Income Tax [2012] 346 ITR 177 is misplaced. There, search was carried out in the case of "P" group of companies. It was found that the assessee before the Hon'ble Delhi High Court had acquired certain development rights from "P" group of companies. Based thereon, the satisfaction was recorded by the Assessing Officer and he issued notice in terms of Section 153C. Thereupon th…