← All Phrases

“direct tax vivad se vishwas”

Settlement & AmnestyDTVSV 2020DTVSV 20202,154 judgments

Judgments citing direct tax vivad se vishwas

Everest Food Products Pvt Ltd (Formerly Known As S. Narendrakumar and Co.), Mumbai vs. CIT-51, Mumbai

In the result, all the appeals of the assessee are treated as allowed for statistical purposes

ITA 2481/MUM/2023[2015-16]Status: DisposedITAT Mumbai17 Oct 2023AY 2015-16

Bench: Shri B.R. Baskaran (Am) & Shri Rahul Chaudhary (Jm)

Section 132Section 143(3)

decision of Ld CIT(A) in dismissing the appeals on the reasoning that the assessee has opted to settle the disputes under Direct Tax Vivad Se Vishwas Act, 2020. 2. The Ld A.R submitted that the assessing officer has passed two assessment orders in respect of these years. He submitted

Everest Food Products Pvt Ltd (Formerly Known As S Narendrakumar and Co.), Mumbai vs. CIT-51, Mumbai

In the result, all the appeals of the assessee are treated as allowed for statistical purposes

ITA 2480/MUM/2023[2014-15]Status: DisposedITAT Mumbai17 Oct 2023AY 2014-15

Bench: Shri B.R. Baskaran (Am) & Shri Rahul Chaudhary (Jm)

Section 132Section 143(3)

decision of Ld CIT(A) in dismissing the appeals on the reasoning that the assessee has opted to settle the disputes under Direct Tax Vivad Se Vishwas Act, 2020. 2. The Ld A.R submitted that the assessing officer has passed two assessment orders in respect of these years. He submitted

Everest Food Products Pvt Ltd (Formerly Known As S. Narendrakumar and Co.), Mumbai vs. CIT-51, Mumbai

In the result, all the appeals of the assessee are treated as allowed for statistical purposes

ITA 2479/MUM/2023[2013-14]Status: DisposedITAT Mumbai17 Oct 2023AY 2013-14

Bench: Shri B.R. Baskaran (Am) & Shri Rahul Chaudhary (Jm)

Section 132Section 143(3)

decision of Ld CIT(A) in dismissing the appeals on the reasoning that the assessee has opted to settle the disputes under Direct Tax Vivad Se Vishwas Act, 2020. 2. The Ld A.R submitted that the assessing officer has passed two assessment orders in respect of these years. He submitted

Sanjay Singh, New Delhi vs. ACIT, Circle-33(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 128/DEL/2020[2014-15]Status: DisposedITAT Delhi13 Oct 2023AY 2014-15

Bench: SHRI M. BALAGANESH (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

Section 234ASection 271(1)(c)

Sanjay Singh vs. ACIT a copy of Form-5 issued by the competent authority settling the entire dispute under The Direct Tax Vivad se Vishwas Scheme, 2020, wherein the tax portion has been settled. Once the disputed tax is settled under Vivad se Vishwas Scheme, the assessee would be eligible

Bain & Company, Inc., Usa vs. DCIT, Int.Taxation, Gurgaon

In the result, the appeal is allowed

ITA 1620/DEL/2022[2019-20]Status: DisposedITAT Delhi12 Oct 2023AY 2019-20

Bench: Shri Saktijit Dey, Vice- & Dr. B.R.R. Kumarassessment Year: 2019-20

Section 143(3)Section 144C(13)Section 9(1)(vii)

assessment years 2011-12 to 2014-15, assessment years 2016-17 and 2017-18 have been settled by the assessee under the Direct Tax Vivad Se Vishwas Scheme, 2020, which shows tacit acceptability of the additions as FIS/FTS by the assessee. Thus, in the aforesaid premises, the Assessing Officer brought

Inmarsat Solutions Bv, Maharashtra vs. ACIT (International Taxation) Circle 2(1)(1)-Delhi, Delhi

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

ITA 1717/DEL/2022[2018-19]Status: DisposedITAT Delhi04 Oct 2023AY 2018-19

Bench: Shri G. S. Pannua N D Shri Challa Nagendra Prasad

For Appellant: Ms. Aarti Sathe, &
Section 143(3)Section 144CSection 144C(13)Section 9(1)(vi)

Supreme CourtIt is also noteworthy that Asia Satellite withdrew from the appeal in Hon'ble Supreme court under the Direct Tax Vivad se Vishwas Scheme. 9. The assessee has also placed its reliance on the favourable judgement of Mumbai ITAT in the case of its group entity Inmarsat Global Limited ... Supreme CourtIt is also noteworthy that Asia Satellite withdrew from the appeal in Hon'ble Supreme court under the Direct Tax Vivad se Vishwas Scheme. Hence, it is learnt that the assessee's claim, in light of the above judicial pronouncements, was very much in the knowledge

Anju Rani Gupta, Noida vs. ACIT Circle-2, Moradabad

ITA 7120/DEL/2019[2015-16]Status: DisposedITAT Delhi06 Sept 2023AY 2015-16

Bench: Sh. N.K.Billaiya & Sh. Anubhav Sharmasmt. Anju Rani Gupta, Vs. Acit, C-30, Sector 19, Noida, Circle-Ii, Uttar Pardesh Moradabad Pan : Afnpg9818A` (Appellant) (Respondent)

Section 250(6)Section 4Section 5

record. An application has been filed, for withdrawal of the appeal by the assessee, in furtherance of settlement arrived under The Direct Tax Vivad Se Vishwas Act, 2020 (The Act of 2020). 2 3. On behalf of the appellant, from Form 5 under the Act of 2020 has been placed

Anand Infracon, Raipur vs. Principal Commissioner of Income Tax, Raipur-1, Raipur

In the result, the assessee's appeal is allowed regarding our observations above

ITA 100/RPR/2023[2018-19]Status: DisposedITAT Raipur04 Sept 2023AY 2018-19

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.100/Rpr/2023 "नधा"रण वष" / Assessment Year : 2018-19 Anand Infracon 502, Dhebar Arcade, Near Kundan Palace, Raipur-492 001 (C.G.) Pan : Aatfm4011A .......अपीलाथ" / Appellant बनाम / V/S. The Pr. Commissioner Of Income Tax, Raipur-1 (C.G.) ……""यथ" / Respondent

For Appellant: Shri Praveen Jain, CAFor Respondent: Smt. Ila M. Parmar, CIT-DR
Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 36(1)(va)Section 4(7)

VSVT and the same had been accepted by the Pr. CIT vide his order passed u/s.5(2) r.w.s. 6 of the Direct Tax Vivad Se Vishwas Act, 2020 (3 of 2020) and “Form- 7 Anand Infracon Vs. Pr. CIT, Raipur-1 5” was issued; therefore, the Pr. CIT had grossly ... dated 01.10.2019 for VSVT, and the Pr. CIT had accepted the same vide his order passed u/s.5(2) r.w.s. 6 of the Direct Tax Vivad Se Vishwas Act, 2020 (3 of 2020) and issued a certificate to the assessee in “Form-5”; therefore, the Pr. CIT had, based on misconceived

Shri Ravi Chandy, Kochi vs. The ACIT, Non-Corporate Circle 1(1), Kochi

In the result, the assessee’s appeal is allowed for statistical purposes

ITA 792/COCH/2022[2014-2015]Status: DisposedITAT Cochin31 Aug 2023AY 2014-2015

Bench: Shri Sanjay Arora, Am &Shri Manomohan Das, Jm

For Appellant: Sri.Athul M.V., AdvocateFor Respondent: Smt.J.M.Jamuna Devi, Sr.DR
Section 147Section 148(1)Section 54F

said property. The assessee carried the matter in appeal. However, before the same could be disposed of, he settled his dispute under Direct Tax Vivad Se Vishwas Act, 2020 (DSV Act), paying the disputed tax at Rs.7,15,410. The ld. CIT(A), vide order dated 12.3.2021 (Ann. Ravi Chandy

Laxmi Narayan Agarwal, Jaipur vs. PCIT, Jaipur-2, Income Tax Department

In the result, appeal of the assessee is allowed

ITA 296/JPR/2023[2016-17]Status: DisposedITAT Jaipur29 Aug 2023AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Shri Arvind Kumar (CIT) a
Section 142(1)Section 143(2)Section 143(3)Section 263

under: the case 6.1 As regards the validity of revision proceeding u/s 263 despite the application of assessee having been finalized under Direct Tax Vivad se Vishwas (for short DTVSV Act) Act, 2020, the contentions of assessee is not in the spirit of the provisions of DTVSV Act, 2020. Rather ... prolonged litigation, the assessee opted to apply in the scheme announced by the Hon’ble Finance Minister in finance act, 2020 as “direct tax vivad se vishwas scheme act, 2020” and accordingly an application under form-1 and 2 was filed on 31.01.2021 (APB 45-55). In response

ACIT Circle-52(1), New Delhi vs. Subhash Chander Khaneja, New Delhi

In the result, the appeal is dismissed

ITA 1265/DEL/2020[2009-10]Status: DisposedITAT Delhi25 Aug 2023AY 2009-10

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Dey, Hon’Ble Vice-Assessment Year: 2009-10 . Acit, Vs. Sh. Subhash Chander Circle-52(1), Khaneja, New Delhi 303-304, 27, Barakhamba Road, New Delhi Pan :Aaipk2679K (Appellant) (Respondent)

August, 2023, intimating that the assessee had opted for settling the dispute arising in the appeal AY: 2009-10 under the Direct Tax Vivad Se Vishwas Scheme, 2020 and assessee’s declaration has been accepted by the competent authority with issuance of Form No. 5. 3. Learned Departmental Representative could

Aman Arora, Udaipur vs. DCIT, Circle-1, Udaipur

In the result, the appeal of the assessee is dismissed as withdrawn

ITA 38/JODH/2019[2013-14]Status: DisposedITAT Jodhpur17 Aug 2023AY 2013-14

Bench: Shri Pavan Kumar Gadale & Dr. Dipak P. Ripoteassessment Year : 2013-14 Aman Arora, Dcit, 23, Sikh Colony, Udaipur, Vs Circle-1, Udaipur, (Rajasthan) Rajasthan Pan: Afupa0996C Appellant / Assessee Respondent / Revenue Assessee By None Revenue By Ms. Prerana Choudhary-Jcit-Dr Date Of Hearing 17.08.2023 Date Of Pronouncement 17.08.2023 Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-1, Udaipur Dated 29.11.2018 Emanating From Order Of Deputy Commissioner Of Income Tax, Udaipur Under Section 143(3) Of The Act For A.Y. 2013-14 Dated 11.01.2016. Ld. Ar Of The Assessee Filed A Letter Dated 04Th August, 2023 2. That Assessee Has Opted For Direct Tax Vivad Se Vishwas Act, 2020. The Department Has Issued Form No. 3, 4 & 5 To The Assessee. Assessee Had Enclosed Copies Of The Same. The Assessee Requested To Withdraw The Appeal. The Copy Of The Letter Is As Under:- Aman Arora

Section 143(3)

dated 11.01.2016. Ld. AR of the assessee filed a letter dated 04th August, 2023 2. that assessee has opted for Direct Tax Vivad Se Vishwas Act, 2020. The Department has issued Form No. 3, 4 and 5 to the assessee. Assessee had enclosed copies of the same. The assessee requested

C.G. Ispat Pvt. Ltd., Raipur vs. Assistant Commissioner of Income Tax, Circle-1(1), Raipur

In the result, appeal filed by the assessee partly allowed for fresh adjudication in terms of our observations hereinabove

ITA 54/RPR/2023[2010-11]Status: DisposedITAT Raipur11 Aug 2023AY 2010-11

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita No.54/Rpr/2023 निर्धारण वर्ष /Assessment Year: 2010-11 V. M/S.C.G.Ispat Pvt.Ltd., The Assistant Commissioner- Raipur Gram Bahesar, Of Income Tax, Near Siltara Industrial Area, Circle-1(1), Raipur, Raipur. Chhattisgarh-492 001. [Pan: Aaccc 4876 B] (अपीलार्थीर्थी/Appellant) (प्रत्यर्थी/Respondent) : अपीलार्थी की ओर से/ Appellant By Mr.R.B.Doshi, Ca प्रत्यर्थी की ओर से /Respondent By : Mr.Satya Prakash Sharma, Sr.Dr सुनवाई ई की तारीखरीख/Date Of Hearing : 07.08.2023 घोषणा की तारीखरीख /Date Of Pronouncement : 11.08.2023

For Respondent: Mr.Satya Prakash Sharma
Section 143(3)Section 147Section 148Section 2Section 271Section 4

Therefore, the appeal of the assessee was treated as infructuous under the provisions of sub-sec.2 of Sec.4 of the Direct Tax Vivad Se Vishwas Act, :: 4 :: 2020. The Ld.AR further submitted that the assessee has opted for DTVSV, 2020 against the penalty order u/s.271

Archit Gupta, New Delhi vs. ACIT, Central Circle-29, New Delhi

ITA 5369/DEL/2018[2014-15]Status: HeardITAT Delhi03 Aug 2023AY 2014-15

Bench: Sh. M. Balaganesh & Sh.Anubhav Sharmaita No. 5369/Del/2018, A.Y. 2014-15 Archit Gupta Vs. Acit C/O. Ravi Gupta, Advocate, Central Circle 29 E-6A, Kailash Colony New Delhi New Delhi-110048 Pan : Aeupg2360R Appellant Respondent

Section 250Section 4Section 5

record. An application has been filed, for withdrawal of the appeal by the assessee, in furtherance of settlement arrived under The Direct Tax Vivad Se Vishwas Act, 2020 (The Act of 2020). 3. On behalf of the appellant, from Form 5 under the Act of 2020 has been placed

Chhattisgarh State Beverage Corporation Ltd., Raipur vs. Deputy Commissioner of Income Tax, Circle-3(1), Raipur

In the result, appeal of the assessee is allowed for statistical purposes in terms of our aforesaid observations

ITA 198/RPR/2022[2013-14]Status: DisposedITAT Raipur03 Aug 2023AY 2013-14

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 198/Rpr/2022 "नधा"रण वष" / Assessment Year : 2013-14 Chhattisgarh State Beverages Corporation Limited Aabkari Bhavan, Chokra Nala, Labhandi, Raipur-492 001 (C.G.) Pan : Aaccc3163B .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax, Circle-3(1), Raipur. ……""यथ" / Respondent

For Appellant: Shri Praveen Jain, CAFor Respondent: Dr. Simran Bhullar, CIT-DR
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 37

dated 08.02.2016 the assessee company filed an appeal before the CIT(Appeals). As the assessee had opted for the Direct Tax Vivad Se Vishwas Act, 2020 as regards its appeal pending before the CIT(Appeals) against the order passed by the. A.O u/s. 143(3) dated 08.02.2016, therefore the said ... dismissed the appeal of the assessee by treating the same as infructuous for the reason that the assessee company had opted for Direct Tax Vivad Se Vishwas Act, 2020 vide its application dated 29.12.2020 and had made full payment of taxes in terms of “Form 5” dated

Vijay Kumar Gupta, Faridabad vs. ACIT Circle-II, Faridabad

In the result, the appeal of the assessee is allowed

ITA 1720/DEL/2023[2011-12]Status: DisposedITAT Delhi26 Jul 2023AY 2011-12

Bench: Shri Kul Bharat[Assessment Year : 2011-12] Vijay Kumar Gupta, Vs Acit, 304 Ssr Corporate Park, Circle-Ii, Nhpc Metro Station, Faridabad, Faridabad. Haryana-121003. Pan-Aaqpg5692J Appellant Respondent Appellant By Shri Vijay Kumar Singla, Ca Respondent By Shri Om Parkash, Sr.Dr Date Of Hearing 20.07.2023 Date Of Pronouncement 26.07.2023 Order

Section 271(1)(c)Section 3Section 4Section 5Section 5(2)

opted for Vivad Se Vishwas Scheme and has filed a declaration in accordance with the provisions of section 3 of the Direct Tax Vivad se Vishwas Act, 2020 (“the Act”) before the PCIT, Faridabad. Accordingly, Certificate under sub-section (1) of section 5 of the Act was issued

Finquest Financial Solutions Pvt Ltd, Mumbai vs. DCIT, CC-3(4), Mumbai

In the result, both the appeals of the assessee for AY

ITA 734/MUM/2023[2017-18]Status: DisposedITAT Mumbai28 Jun 2023AY 2017-18

Bench: Shri Aby T. Varkey, Jm & Ms. Padmavathy S, Am आयकर अपील सं/ I.T.A. No.733/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2018-19) आयकर अपील सं/ I.T.A. No.734/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2017-18) Finquest Financial Solutions बिधम/ Deputy Commissioner Of Pvt. Ltd. Income Tax, Cc-3(4), Vs. 602, 6Th Floor, Boston Room No.1915, 19Th House, Suren Road, Floor, Air India Building, Andheri (E), Nariman Point, Mumbai-400 093 Mumbai-400 021 स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaacf8117G (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri V. G. Ginde & Kumar Kale Revenue By: Shri Ankush Kapoor, Cit-Dr सुनवाई की तारीख / Date Of Hearing: 07/06/2023 घोषणा की तारीख /Date Of Pronouncement: 28/06/2023 आदेश / O R D E R Per Aby T. Varkey, Jm: These Are Appeals Preferred By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax Appeals-51, Mumbai [Hereinafter Referred To As The “Ld. Cit(A)”] Dated 16.01.2023, For Ay. 2018-19 & Ay. 2017-18 Respectively. 2. As Per The Request Of The Ld. Authorized Representative (Ar) Of The Assessee, First Of All, We Will Adjudicate The Appeal For Ay. 2018-19 First. 3. At The Outset, The Ld. Ar Does Not Press Ground No. 1 Which Is Against The Action Of The Ld. Cit(A) Confirming The Addition Of Rs.19,25,000/- Made By The Assessing Officer (Ao), Being Disallowance Of Fees Paid To The Roc. Therefore, This Ground Of Appeal Of Assessee Stands Dismissed. (Ay. 2018-19 & Ay. 2017-18) Finquest Financial Solutions Pvt. Ltd.

For Appellant: Shri V. G. Ginde & Kumar KaleFor Respondent: Shri Ankush Kapoor, CIT-DR
Section 132Section 143(3)Section 153ASection 69B

pending before the Ld. CIT(A), the assessee opted for the Vivad Se Vishwas Scheme (as per section 4(5) of the Direct Tax Vivad Se Vishwas Act, 2020) and assessee offered tax on the total addition made including Rs.4,48,68,500/- u/s 69B of the Act which

Finquest Financial Solutions Pvt Ltd, Mumbai vs. DCIT, CC-3(4), Mumbai

In the result, both the appeals of the assessee for AY

ITA 733/MUM/2023[2018-19]Status: DisposedITAT Mumbai28 Jun 2023AY 2018-19

Bench: Shri Aby T. Varkey, Jm & Ms. Padmavathy S, Am आयकर अपील सं/ I.T.A. No.733/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2018-19) आयकर अपील सं/ I.T.A. No.734/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2017-18) Finquest Financial Solutions बिधम/ Deputy Commissioner Of Pvt. Ltd. Income Tax, Cc-3(4), Vs. 602, 6Th Floor, Boston Room No.1915, 19Th House, Suren Road, Floor, Air India Building, Andheri (E), Nariman Point, Mumbai-400 093 Mumbai-400 021 स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaacf8117G (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri V. G. Ginde & Kumar Kale Revenue By: Shri Ankush Kapoor, Cit-Dr सुनवाई की तारीख / Date Of Hearing: 07/06/2023 घोषणा की तारीख /Date Of Pronouncement: 28/06/2023 आदेश / O R D E R Per Aby T. Varkey, Jm: These Are Appeals Preferred By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax Appeals-51, Mumbai [Hereinafter Referred To As The “Ld. Cit(A)”] Dated 16.01.2023, For Ay. 2018-19 & Ay. 2017-18 Respectively. 2. As Per The Request Of The Ld. Authorized Representative (Ar) Of The Assessee, First Of All, We Will Adjudicate The Appeal For Ay. 2018-19 First. 3. At The Outset, The Ld. Ar Does Not Press Ground No. 1 Which Is Against The Action Of The Ld. Cit(A) Confirming The Addition Of Rs.19,25,000/- Made By The Assessing Officer (Ao), Being Disallowance Of Fees Paid To The Roc. Therefore, This Ground Of Appeal Of Assessee Stands Dismissed. (Ay. 2018-19 & Ay. 2017-18) Finquest Financial Solutions Pvt. Ltd.

For Appellant: Shri V. G. Ginde & Kumar KaleFor Respondent: Shri Ankush Kapoor, CIT-DR
Section 132Section 143(3)Section 153ASection 69B

pending before the Ld. CIT(A), the assessee opted for the Vivad Se Vishwas Scheme (as per section 4(5) of the Direct Tax Vivad Se Vishwas Act, 2020) and assessee offered tax on the total addition made including Rs.4,48,68,500/- u/s 69B of the Act which

Shreepal Humad, Indore vs. The Pr CIT-1, Indore

In the result, appeal of assessee is allowed

ITA 125/IND/2021[2016-17]Status: DisposedITAT Indore21 Jun 2023AY 2016-17

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanishreepal Humad Pr. Cit-1 Near Civil Hospital, Bus Indore Vs. Stand Road, Manasa Madhya Pradesh (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaxph1346 K Assessee By Shri Ashish Goyal & N.D. Patwa, Ars Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 13.04.2023 Date Of Pronouncement 21 .06.2023

Section 12ASection 138Section 263

Appeals under Section 246A of the Income Tax Act, 1961. 34. The Finance Minister in the parliament had introduced the “Direct Tax Vivad Se Vishwas Act, 2020. The respective petitioners opted to settle the dispute with Income Tax Department by filing declarations in Form ... under Section 263 of the Income Tax Act, 1961 was without jurisdiction inasmuch as the petitioners have settled the case under the Direct Tax Vivad Se Vishwas Act, 2020. 39. The question therefore that arises for consideration is whether the impugned proceedings initiated after the petitioners opted to settle

Veena Goel Represented Legal Heir of Moti Lal Goel, Ghaziabad vs. ITO Ward 13(2), New Delhi

In the result, the appeal of the assessee is dismissed

ITA 1190/DEL/2023[2017-18]Status: DisposedITAT Delhi19 Jun 2023AY 2017-18

Bench: Shri Saktijit Dey & Shri M. Balaganeshassessment Year: 2009-10 Smt. Sapna Gupta, Vs The Pr. Cit, 299, Awas Vikas Colony, Dehradun. Vivek Vihar, Haridwar – 249 407, Uttarakhand. Pan: Acspg4083D (Appellant) (Respondent) Assessee By : Shri Rohit Jain, Advocate & Ms Deepashri Rao, Ca Revenue By : Shri N.S. Jangpangi, Cit, Dr Date Of Hearing : 27.04.2023 Date Of Pronouncement : 08.06.2023 Order Per M. Balaganesh, Am: This Appeal In Ita No.16/Ddn/2021 For Ay 2009-10 Arises Out Of The Order Of The Pr. Commissioner Of Income Tax (Appeals), Dehradun, [Hereinafter Referred To As „Ld. Pcit‟, In Short] In Din & Order No. Itba/Rev/F/Rev5/2020- 21/1031815348(1) Dated 27.03.2021 Against The Order Of Assessment Passed U/S 148/147 R.W.S. 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As „The Act‟) Dated 26Th/28Th December, 2018 By The Ld. Assessing Officer, Ward 1(3)(3), Haridwar (Hereinafter Referred To As „Ld. Ao‟). 2. The Only Issue To Be Decided In This Appeal Is As To Whether The Ld. Pcit Was Justified In Invoking Revisionary Jurisdiction U/S 263 Of The Act In Respect Of Disallowance Of Purchases Of Rs 33,35,500/- In The Facts & Circumstances Of The Instant Case.

For Appellant: Shri Rohit Jain, Advocate &For Respondent: Shri N.S. Jangpangi, CIT, DR
Section 147Section 148Section 263Section 263(2)

limitation prescribed under section 263(2) of the Act; (b) initiated to cancel/set-aside reassessment order which had attained finality under the Direct Tax Vivad se Vishwas Act, 2020 (“the VsV”); and (c) initiated to revise reassessment order in respect of issues which were not even subject matter of reopening proceedings ... revenue. The assessee submitted that the demand raised in the re-assessment proceedings dated 26.12.2018 was settled by her by availing the Direct Tax Vivad Se Vishwas Act, 2020 and the dispute was settled thereon. In support thereon, the assessee submitted Form 3 dated 23.02.2021 issued by the ld. PCIT