Underwater Services Co. Ltd. v. ACIT

Swastik Vegetable Oil Products Private Limited, Hyderabad vs. ACIT., Central Circle - 2(1), Hyderabad

…ial. The Ld. AR to support his contention that no assessment under Section 153C could be framed in the absence of incriminating material had relied on the judgment of the Hon'ble High Court of Bombay in the case of Underwater Services Co. Ltd. Vs. ACIT (2022) 448 ITR 691 (Bom). Also, the Ld. AR had pressed into service various judicial pronouncements on the aspect of recording of satisfaction under section 153C of the Act, viz. (i). CIT Vs. Calcutta Knitwears, Ludhiana (2014) 362 ITR 673 (SC); (ii). Pr. CIT Vs. Milia Tracon P. Ltd. (2025) 473 ITR 155 (Cal); (iii). CIT Vs. SRM Systems & Software Ltd. (2025) 475 IT…

Swastik Vegetable Oil Products Private Limited, Hyderabad vs. ACIT., Central Circle - 2(1), Hyderabad

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

…ial. The Ld. AR to support his contention that no assessment under Section 153C could be framed in the absence of incriminating material had relied on the judgment of the Hon’ble High Court of Bombay in the case of Underwater Services Co. Ltd. Vs. ACIT (2022) 448 ITR 691 (Bom). Also, the Ld. AR had pressed into service various judicial pronouncements on the aspect of recording of satisfaction under section 153C of the Act, viz. (i). CIT Vs. Calcutta Private Limited vs. ACIT Knitwears, Ludhiana (2014) 362 ITR 673 (SC); (ii). Pr. CIT Vs. Milia Tracon P. Ltd. (2025) 473 ITR 155 (Cal); (iii). CIT Vs. SRM Systems & S…

Swastik Vegetable Oil Products Private Limited, Hyderabad vs. ACIT., Central Circle - 2(1), Hyderabad

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

…ial. The Ld. AR to support his contention that no assessment under Section 153C could be framed in the absence of incriminating material had relied on the judgment of the Hon’ble High Court of Bombay in the case of Underwater Services Co. Ltd. Vs. ACIT (2022) 448 ITR 691 (Bom). Also, the Ld. AR had pressed into service various judicial pronouncements on the aspect of recording of satisfaction under section 153C of the Act, viz. (i). CIT Vs. Calcutta Private Limited vs. ACIT Knitwears, Ludhiana (2014) 362 ITR 673 (SC); (ii). Pr. CIT Vs. Milia Tracon P. Ltd. (2025) 473 ITR 155 (Cal); (iii). CIT Vs. SRM Systems & S…

Swastik Vegetable Oil Products Private Limited, Hyderabad vs. DCIT., Central Circle - 2(1), Hyderabad

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

…ial. The Ld. AR to support his contention that no assessment under Section 153C could be framed in the absence of incriminating material had relied on the judgment of the Hon’ble High Court of Bombay in the case of Underwater Services Co. Ltd. Vs. ACIT (2022) 448 ITR 691 (Bom). Also, the Ld. AR had pressed into service various judicial pronouncements on the aspect of recording of satisfaction under section 153C of the Act, viz. (i). CIT Vs. Calcutta Private Limited vs. ACIT Knitwears, Ludhiana (2014) 362 ITR 673 (SC); (ii). Pr. CIT Vs. Milia Tracon P. Ltd. (2025) 473 ITR 155 (Cal); (iii). CIT Vs. SRM Systems & S…

Swastik Vegetable Oil Products Private Limited, Hyderabad vs. ACIT., Central Circle - 2(1), Hyderabad

In the result, the appeals of the assessee company in ITA Nos

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

…ial. The Ld. AR to support his contention that no assessment under Section 153C could be framed in the absence of incriminating material had relied on the judgment of the Hon’ble High Court of Bombay in the case of Underwater Services Co. Ltd. Vs. ACIT (2022) 448 ITR 691 (Bom). Also, the Ld. AR had pressed into service various judicial pronouncements on the aspect of recording of satisfaction under section 153C of the Act, viz. (i). CIT Vs. Calcutta Private Limited vs. ACIT Knitwears, Ludhiana (2014) 362 ITR 673 (SC); (ii). Pr. CIT Vs. Milia Tracon P. Ltd. (2025) 473 ITR 155 (Cal); (iii). CIT Vs. SRM Systems & S…