VAYAS MULTI TRADING PVT LTD , NEW DELHI vs. ACIT, CENTRAL CIRCLE-14 , NEW DELHI
The appeal is allowed as above
ITA 2295/DEL/2022[2012-13]Status: DisposedITAT Delhi29 Dec 2023AY 2012-13
Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaassessment Year: 2012-13 Vayas Multi Trading Pvt. Ltd., Vs Acit, Ajay Kanjhlia & Associates, Central Circle-14, Lgf, The Statesman House, New Delhi. Barakhamba Road, New Delhi – 110 001. Pan: Aabcl1268K (Appellant) (Respondent) Assessee By : Shri C.S. Anand, Advocate Revenue By : Shri Amit Katoch, Sr. Dr Date Of Hearing : 12.12.2023 Date Of Pronouncement : .12.2023 Order Per Anubhav Sharma, Jm:
For Appellant: Shri C.S. Anand, AdvocateFor Respondent: Shri Amit Katoch, Sr. DR
Section 119Section 143(3)
loans or advances of past years as dividend. The Revenue however relied on a circular issued by the Central Board of Revenue under Section 5(8) of the Indian Income Tax Act, 1922
which corresponded to Section 119 of the present Act and this circular provided that if any such ... where referring to another circular issued by the Central Board of Revenue under Section 5(8) of the Indian Income Tax Act, 1922 on which reliance was placed on behalf of the assessee, this Court observed: “Now, coming to the question as to the effect of instructions issued under Section