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)
issued by the ld. PCIT , Dehradun on 09.04.2021. 8. The ld. PCIT observed that the assessee had settled the dispute under Vivad Se
Vishwas (VSV) Scheme only against the disallowance of purchases from M/s Meet
Enterprises only for Rs 73,45,040/-. Anyway, the difference of purchases from M/s
Meet ... never subject matter of disallowance in assessment by the ld. AO or settlement of dispute by the assessee under VSV scheme. Accordingly the ld. PCIT invoked his revisionary jurisdiction u/s 263 of the Act for disallowing the remaining sum of Rs 33,35,500/-.
9. Before