“Section 133(6)”

Section References (mined)Section 133Section 133(6)6,687 judgments

The decision most relied on for Section 133(6) is CIT v. Simit P. Sheth (356 ITR 451), cited in 1,465 judgments on BharatTax.

Leading authorities on Section 133(6)

CIT v. Simit P. Sheth

356 ITR 451 · 2013 · High Court

1,465

citing judgments

Additions for alleged bogus purchases should be restricted to the profit element, not the entire turnover. The profit element is often estimated at 12.5% of the purported bogus purchases.

CIT v. Orissa Corporation Pvt. Ltd.

159 ITR 78 · 1986 · Supreme Court

897

citing judgments

When an assessee provides the identity and address of a creditor or investor for a cash credit or share capital under Section 68, the burden shifts to the Department to establish lack of genuineness or creditworthiness, requiring it to conduct further inquiries; mere non-compliance by third parties to summons cannot be the sole basis for an adverse inference against the assessee.

Raymond Woollen Mills Ltd. v. ITO

236 ITR 34 · 1999 · Supreme Court

862

citing judgments

For reassessment proceedings under Section 148, the Assessing Officer only needs prima facie material to have a reason to believe income has escaped assessment. Conclusive proof or evaluation of the sufficiency and correctness of such material is not required at the stage of issuing the notice.

CIT v. Lovely Exports (P) Ltd.

216 CTR 195 · 2008 · Supreme Court

854

citing judgments

If an assessee company receives share application money from alleged bogus shareholders and provides their details to the Assessing Officer, no addition can be made under Section 68 in the company's hands; the Department must proceed against the shareholders by reopening their individual assessments.

CIT v. Tata Elxsi Ltd.

349 ITR 98 · 2012 · High Court

818

citing judgments

When computing deduction under Section 10A, if communication or telecommunication expenses are excluded from export turnover, they must also be excluded from total turnover to maintain consistency and apply the ordinary meaning of 'turnover' in context.

CIT v. Bholanath Poly Fab. Pvt. Ltd.

355 ITR 290 · 2013 · High Court

712

citing judgments

If an assessee makes purchases from bogus parties, but the underlying goods are genuinely acquired and sold, only the profit margin embedded in such purchases, and not the entire value of the bogus purchases, should be added to the assessee's income.

(Central)-1 v. NRA Iron & Steel (P) Ltd.

103 Taxmann.com 48 · 2019 · Supreme Court

696

citing judgments

When assessing cash credits, share capital, or loans, the assessee bears the onus to prove the identity, creditworthiness, and genuineness of transactions. This burden is not discharged merely by documentary evidence if field inquiries reveal accommodation entries or dealings with paper/shell companies.

CIT v. Daulat Ram Rawatmull

87 ITR 349 · 1973 · Supreme Court

525

citing judgments

The onus to prove that an apparent transaction or explanation is not real lies with the person who claims it to be so. If an assessee provides a plausible explanation for a transaction, the revenue must establish that the apparent transaction is not genuine.

Judgments citing Section 133(6)

Balaka Vinimay Pvt. Ltd., Kolkata vs. ITO, Ward-2(1), Kolkata

In the result, appeals of the assessee in ITA No

ITA 161/KOL/2024[2008-09]Status: DisposedITAT Kolkata21 Jun 2024AY 2008-09

Bench: Shri Sanjay Garg, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. No. 160 & 161/Kol/2024 Assessment Year: 2008-09 Balaka Vinimay Pvt. Ltd. Income Tax Officer, Ward – 2(1), 9/12, Lal Bazar Street Vs Kolkata Kolkata - 700001 [Pan : Aadcb2610B] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri A.K. Tibrewal, A/R & Saurav Gupta, A/R Revenue By : Shri Abhijit Kundu, Cit, Sr. D/R सुनवाई क" तारीख/Date Of Hearing : 09/04/2024 घोषणा क" तारीख /Date Of Pronouncement: 21/06/2024 आदेश/O R D E R Per Dr. Manish Borad: The Instant Appeals Are Directed At The Instance Of The Assessee Against The Separate Orders Of The National Faceless Appeal Centre, Delhi, (Hereinafter The “Ld. Cit(A)”). Ita No. 160/Kol/2024 Is Against The Order Of The Ld. Cit(A) Dt. 29/11/2023, Passed U/S 250 Of The Income Tax Act, 1961 (Hereinafter ‘The Act’) Arising Out Of The Penalty Order Passed By The Ld. Assessing Officer U/S 271(1)(C) Of The Act & Ita No. 161/Kol/2023, Is Against The Order Of The Ld. Cit(A) Dt. 28/11/2023, Arising Out Of The Order Of The Ld. Assessing Officer Passed U/S 143(3) R.W.S. 254 Of The Act, For Assessment Year 2008-09. 2. Though The Assessee Has Raised Various Grounds In Both These Appeals, But The Effective Issue Raised In Ita No. 161/Kol/2024 Is Against The Addition Made U/S 68 Of The Act For Unexplained Share Capital Confirmed By The Ld. Cit(A) & In Ita No. 160/Kol/2024 Is Against The Levy Of Penalty U/S 271(1)(C) Of The Act On The Addition Made

For Appellant: Shri A.K. Tibrewal, A/R and Saurav Gupta, A/RFor Respondent: Shri Abhijit Kundu, CIT, Sr. D/R

Section 142(1)Section 143(3)Section 147Section 148Section 250Section 263Section 271(1)(c)Section 68

received against the issue of equity capital during the year, both the share applicants of replied to the notice under section 133(6) of the Act and have filed complete details including bank statements, income tax returns, audited balance sheets, confirmation of accounts etc.. It was also submitted that

Balaka Vinimay Pvt. Ltd., Kolkata vs. ITO, Ward-2(1), Kolkata

In the result, appeals of the assessee in ITA No

ITA 160/KOL/2024[2008-09]Status: DisposedITAT Kolkata21 Jun 2024AY 2008-09

For Appellant: Shri A.K. Tibrewal, A/R and Saurav Gupta, A/RFor Respondent: Shri Abhijit Kundu, CIT, Sr. D/R

Section 142(1)Section 143(3)Section 147Section 148Section 250Section 263Section 271(1)(c)Section 68

Deputy Commissioner of Income Tax, Circle-49(1), Kolkata, Ultadanga vs. The Rifle Factory Co-Operative Society Ltd, Ishapore

In the result, appeal of the revenue is dismissed

ITA 813/KOL/2023[2017-18]Status: DisposedITAT Kolkata21 Jun 2024AY 2017-18

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 813/Kol/2023 Assessment Year: 2017-18 Deputy Commissioner Of Income The Rifle Factory Co-Operative Tax, Circle – 49(1), Kolkata Vs Society Limited Nawabganj, P.O.- Ishapore Dist. – North 24 Parganas Pin - 743144 [Pan : Aaaat6436E] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Somak Basu, Advocate Revenue By : Shri Arun Kanti Dutta, Addl. Cit, Sr. D/R सुनवाई क" तारीख/Date Of Hearing : 18/04/2024 घोषणा क" तारीख /Date Of Pronouncement: 21/06/2024 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeal Is Directed At The Instance Of The Revenue Against The Order Of The National Faceless Appeals Centre, Delhi, (Hereinafter The “Ld. Cit(A)”), Dated 11/05/2023, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2017-18. 2. The Revenue Has Raised The Following Grounds Of Appeal:- “1. That On The Facts & Circumstances Of The Case, The Order Passed By The Ld. Cit(A), Inf Ac Has Passed The Order In Favour Of The Appellant Society Without Giving The Due Opportunity To The Ao As No Letter Calling For Remand Report Was Either Sent/Triggered Through Name-Based/Designation Based Email Of The Ao, But In The Appellate Order, It Is Mentioned That The Ao Was Directed To Submit A Remand Report In This Case On 20.04.2023 When The Ld. Cit Appeal, Imf Ac Accepted Additional/Fresh Documents Like Bank Statement Of Sbi Bank Having Account No. 11223335284 Furnished By The Assessee.

For Appellant: Shri Somak Basu, AdvocateFor Respondent: Shri Arun Kanti Dutta, Addl. CIT, Sr. D/R

Section 143(2)Section 250Section 69A

adverse inference was drawn. Further, notice dated 13,12;20l8 was issued on the same Issue under Section 133(6) by the Income Tax Officer (1 & C1)-4, Kolkata, on account of high value Financial Transaction in from of cash deposit during the financial year 2016- 17. In view

Construction Technique, Mumbai vs. ACIT, Circle-20(1), Mumbai

In the result, the appeal of the assessee is partly allowed

ITA 747/MUM/2024[2010-11]Status: DisposedITAT Mumbai21 Jun 2024AY 2010-11

Bench: Shri Amarjit Singh & Shri Rahul Chaudhary

For Appellant: Aditya RamchandranFor Respondent: H.M. Bhatt

Section 133(6)Section 147Section 148Section 69C

Page 1 ITA No.747/Mum/2024 Construction Technique Vs. ACIT, Circle-20(1) IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, MUMBAI

ACIT 2(2)(1), Mumbai vs. Mediacom Communications Private Limited, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 68/MUM/2024[AY 2016-17]Status: DisposedITAT Mumbai21 Jun 2024

Bench: Shri Amarjit Singh & Shri Rahul Chaudhary, Acit 2(2)(1) Vs. Mediacom Room No. 545, 5 Th Floor Communications Private Aayakar Bhavan, Limited, 349 Business M.K. Road, Point, Western Express Maharashtra - 400020 Highway Andheri Eeast Maharashtra – 400059 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aafcm6252N Appellant .. Respondent

For Appellant: Nikhil TiwariFor Respondent: Smiti Samant

Section 133(6)Section 143(3)Section 250Section 41(1)

P a g e | 1 ACIT, 2(2)(1) Vs. Mediacom Communication Pvt. Ltd. IN THE INCOME TAX APPELLATE TRIBUNAL

Assistant Commissioner of Income Tax - 4(2)(1), Mumbai vs. Iifl Home Finance Limited, Mumbai

In the result, ground no. 4 of the revenue is allowed for statistical purposes

ITA 1297/MUM/2024[2021-22]Status: DisposedITAT Mumbai21 Jun 2024AY 2021-22

Bench: Shri Anikesh Banerjee & Shri Gagan Goyal

For Appellant: Shri Pritesh MehtaFor Respondent: Shri H.M. Bhatt (SR.DR.)

Section 143(3)Section 144BSection 250Section 43BSection 43DSection 69CSection 80M

solely on the basis of noncompliance to 133(6) notice. The AO noted in the assessment order, that he had issued notice under section 133 (6) of the Act to the concerned party, however, he did not receive any replies. Therefore, as the assessee did not furnish the necessary evidence

Pramod Kumar Singh, Kalyan, Thane vs. Commissioner of Income Tax (Appeals), Thane, Maharashtra

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 4759/MUM/2023[2014-15]Status: DisposedITAT Mumbai21 Jun 2024AY 2014-15

Bench: Shri Amarjit Singh & Shri Rahul Chaudhary, Pramod Kumar Singh, Vs. Ito Ward 17(2)(1) A Wing Room No. 2, Mumbai Shalaka Chsl, Manpada Road, Gandhinagar, Dombivali East, Kalyan – 421204 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Atzps5807M Appellant .. Respondent

For Appellant: Rahul BombaleFor Respondent: H.M. Bhatt

Section 133(6)Section 144BSection 147Section 148Section 194CSection 250Section 68Section 69

P a g e | 1 Pramod Kumar Singh Vs. CIT(A) IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, MUMBAI

Jitendra Udaylal Jain, Maharashtra vs. National Faceless Appeal Centre (NFAC), Delhi

In the result, the appeal filed by the assessee is allowed

ITA 4543/MUM/2023[2011-12]Status: DisposedITAT Mumbai21 Jun 2024AY 2011-12

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawal

Section 10(38)Section 143(1)Section 234ASection 271(1)(c)Section 68Section 69C

unaccounted money, but he did not dig deeper. Notices issued 17 ITA. No. 4543/MUM/2023 (A.Y.: 2011-12) Jitendra udaylal Jain, Mumbai. under sections 133(6)/131 of the Act were issued to M/s Gold Line International Finvest Limited, but nothing emerged from this effort. The payment for the shares ... attempt to delve into the question of infusion of Respondent’s unaccounted money, but he did not dig deeper. Notices issued under Sections 133(6)/131 of the Act were issued to M/s Gold Line International Finvest Limited, but nothing emerged from this effort. The payment for the shares

Bharatkumar Bhikhabhai Chavda, Hariyala Kheda vs. Income Tax Officer, Ward-3, Nadiad

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 797/AHD/2024[2017-18]Status: HeardITAT Ahmedabad20 Jun 2024AY 2017-18

Bench: The Income-Tax Appellate Tribunal, Ahmedabad Bench, Ahmedabad In Ita No. 797/Ahd/2024 For Assessment Year 2017-18 Has Arisen From The Appellate Order Vide Din & Order No. Itba/Nfac/S/250/ 2023-24/1059995984(1) Dated 22-01-2024 Passed By Learned Commissioner Of Income-Tax(Appeals),National Faceless Appeal Centre(Nfac), Delhi , Which Appeal In Turn Has Arisen From The Assessment Order Dated 07-11-2019 Passed By The 2

For Appellant: NoneFor Respondent: Shri M. Anand Kumar, Sr. D.R

Section 115BSection 133(6)Section 139Section 142(1)Section 144Section 253(3)Section 69A

THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “SMC” BENCH Before: Shri Ramit Kochar, Accountant Member Assessment Year 2017-18 Bharatkumar The

Income Tax Officer Ward-4(4), Nagpur vs. Aruna Dinesh Jaiswal, Nagpur

In the result, appeal filed by the Revenue is dismissed

ITA 221/NAG/2023[2017-18]Status: DisposedITAT Nagpur20 Jun 2024AY 2017-18

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Manoj G. MoryaniFor Respondent: Shri Surjit Kumar Saha

Section 133(6)Section 142(1)Section 143(2)Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI K.M. ROY

The ITO, Ward-1(2)(3), Ahmedabad vs. Shri Mahesh Somabhai Patel, Ahmedabad

In the result, the appeal of the Revenue is dismissed

ITA 1854/AHD/2019[2014-15]Status: DisposedITAT Ahmedabad19 Jun 2024AY 2014-15

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 10Section 10(38)Section 143(3)

attempt to delve into the question of infusion of Respondent's unaccounted money, but he did not dig deeper. Notices issued under sections 133(6)/131 of the Act were issued to M/s Gold Line International Finvest Limited, but nothing emerged from this effort. The payment for the shares

M/S. Alang Metal Exim Pvt. Limited., Bhavnagar vs. ACIT, Circle-1, Bhavnagar

In the result, the appeal of the assessee is treated as partly allowed for statistical purposes

ITA 2329/AHD/2018[2012-13]Status: DisposedITAT Ahmedabad19 Jun 2024AY 2012-13

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar, Accountnat Member Assessment Year : 2012-13 M/S.Alang Metal Exim Pvt.Ltd. The Acit Shop No.3, Arpan Flat Vs Circle-1 Shishuvihar Circle, Bhavnagar Bhavnagar – 364 001 (Gujarat) Pan:Aaeca 9651 Q ….. अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Tushar Hemani, Sr.Adv. & Shri Parimalsinh B. Parmar, Ar Revenue By : Shri Sudhendu Das, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 13 /06/2024 घोषणा क" तार"ख /Date Of Pronouncement: 19/06/2024 आदेश/O R D E R Per Makarand V. Mahadeokarthis Appeal Is Filed By The Assessee Against The Order Dated 20-9-2018 Passed By The Ld.Commissioner Of Income Tax (Appeals)–6, Ahmedabad [Hereinafter Referred To As “The Ld.Cit(A)”] In Confirming The Addition Of Rs.7,00,00,000/- Under Section 68 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) & Disallowance Of Rs.3,30,000/- Out Of Loading & Unloading Charges Made By The Assessing Officer (Hereinafter Referred To As “Ao”) In His Assessment Order Passed Under Section 143(3) Of The Act For The Assessment Year (Ay) 2012-13. M/S.Alang Metal Exim Pvt.Ltd. Vs. Acit Asst. Year : 2012-13

For Appellant: Shri Tushar Hemani, Sr.Adv. &For Respondent: Shri Sudhendu Das, CIT-DR

Section 143(3)Section 68

that neither the AO nor the Ld.CIT(A) made efforts to cross-verify the transactions with the concerned investors by issuing notices under Section 133(6) of the Act or summons under Section 131 of the Act. The Ld.CIT(A) confirmed the addition based on suspicion, which cannot substitute evidence

Three M Paper Boards Limited, Mumbai vs. DCIT-2 (3)(1), Mumbai

In the result, the appeal filed by assessee is allowed for statistical purposes

ITA 1548/MUM/2024[2012-13]Status: DisposedITAT Mumbai19 Jun 2024AY 2012-13

Bench: Shri Pavan Kumar Gadale & Smt Renu Jauhridy. Commissioner Of Three M Paper Boards Vs. Income Tax–2(3)(1), Limited, Room No. Ab–615, A33/34, Royal Ayakar Bhavan, Industrial Estate, M.K. Road, 5–Bnaigaoncrossroad, Mumbai–400020. Wadala, Mumbai–400031. Pan/Gir No. Aaact1650J (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 115JSection 250

IN THE INCOME TAX APPELLATE TRIBUNAL, “E” BENCH MUMBAI BEFORE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER & SMT RENU JAUHRI, ACCOUNTANT

Mahendra Mamtora, Mumbai vs. ITO 30(2)(3), Mumbai

In the result, the appeal filed by the assessee is treated as allowed for statistical purposes

ITA 1119/MUM/2024[2011-2012]Status: DisposedITAT Mumbai19 Jun 2024AY 2011-2012

Bench: Shri Pavan Kumar Gadale & Smt. Renu Jauhrii T A. No. 1119/Mum/2024 (A.Y.2011-12)

Section 147Section 148Section 234BSection 271(1)(c)Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL, “E” BENCH MUMBAI BEFORE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER & SMT. RENU JAUHRI, ACCOUNTANT

Shailesh K Patel-HUF, Ahmedabad vs. ITO, Ward-3(3)(5), Ahmedabad

In the result, appeal preferred by the assessee is dismissed

ITA 288/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad18 Jun 2024AY 2015-16

Bench: Ms. Suchitra Raghunath Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 288/Ahd/2019 (िनधा"रण वष" िनधा"रण वष" िनधा"रण वष" / Assessment Year: 2015-16) िनधा"रण वष" Shailesh K. Patel Huf The Income Tax Officer बनाम बनाम/ बनाम बनाम C/O. Ketan H. Shah, Ward – 3(3)(5), Vs. Advocate Ahmedabad 512, Time Square – I, Op. Ram Baug Bungalow, Thaltej Shilaj Road, Thaltej, Ahmedabad, Gujarat 380059 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aalhs9548E (Appellant) .. (Respondent) Shri Ketan Shah & Shri Aman Shah, अपीलाथ" ओर से /Appellant By : A.Rs. ""यथ" क" ओर से/Respondent By : Shri Ashok Kumar Suthar, Sr. Dr 04/06/2024 Date Of Hearing Date Of Pronouncement 18/06/2024 O R D E R Per Shri Narendra Prasad Sinha, Am: This Appeal Is Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals)-3, Ahmedabad, (In Short ‘The Cit(A)’) Dated 24.01.2019 For The Assessment Year 2015-16. 2. The Assessee Has Taken Following Grounds Of Appeal:

For Appellant: A.RsFor Respondent: Shri Ashok Kumar Suthar, Sr. DR

Section 10(38)Section 133(6)Section 143(2)Section 145Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, AHMEDABAD BEFORE Ms. SUCHITRA RAGHUNATH KAMBLE, JUDICAL MEMBER & SHRI NARENDRA PRASAD SINHA

Debabrata Banerjee, Kolkata vs. DCIT, Cir-34, Kolkata.

In the result, appeal of the assessee is allowed

ITA 1084/KOL/2023[2013-13]Status: DisposedITAT Kolkata18 Jun 2024AY 2013-13

Bench: Shri Rajesh Kumar, Am& Shri Pradip Kumar Choubey, Jm]

Section 143(3)Section 144Section 144BSection 147Section 148

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, KOLKATA [Before Shri Rajesh Kumar, AM& Shri Pradip Kumar Choubey, JM] I.T.A

Valaram Suresh Kumar, Bangalore vs. Income Tax Officer, Ward-6(2)(1), Bangalore

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes

ITA 729/BANG/2024[2017-18]Status: DisposedITAT Bangalore18 Jun 2024AY 2017-18

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2017-18

For Appellant: Shri Shreehari Kutsa, Advocate

Section 133(6)Section 139(1)Section 142(1)Section 250Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL SMC-‘A’ BENCH : BANGALORE BEFORE SMT. BEENA PILLAI, JUDICIAL MEMBER AND SHRI LAXMI PRASAD

ITO-11(1)(1), Mumbai, Aayakar Bhawan, M.K. Marg vs. Sateri Constructions Pvt. Ltd., Jogeshwari East, Mumbai

In the result, the appeal filed the revenue is treated as allowed

ITA 4443/MUM/2023[2017-18]Status: DisposedITAT Mumbai18 Jun 2024AY 2017-18

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjeeassessment Year : 2017-18

For Appellant: Ms. Sujatha Iyangar, Sr.ARFor Respondent: Shri Satyaprakash Singh

Section 133Section 133(6)Section 69A

support of the same the assessee furnished address and PAN number of the above company. 3. Accordingly, the assessing officer issued notice under section 133 (6) of the Act to M/s Bagla international P Ltd, but it was returned as “unclaimed”. When this fact was pointed out, the assessee submitted ... International P Ltd was furnished. 6. However, the important point which remained unaddressed is that the notices issued by the assessing officer under section 133(6) of the Act to the above said concern was not responded. Since it was claimed that the above said concern was under liquidation

Vinod Kumar Rana, Vijay Nagar Ghaziabad vs. The Commissioner of Income Tax (Appeals), Ghaziabad

In the result, appeal of the assessee is allowed for statistical purposes

ITA 1176/DEL/2024[2012-2013]Status: DisposedITAT Delhi18 Jun 2024AY 2012-2013

Bench: Shri Pradip Kumar Kedia

For Respondent: Shri Om Prakash, Sr.DR

Section 133(6)Section 144Section 147Section 250(6)

When the matter was called for hearing, the ld. counsel for the assessee pointed out at the outset that upon inquiry under Section 133(6) by the AO with the bank on 14.12.2019, the bank vide e-mail 2 dated 27.12.2019 furnished certain information towards the bank account

Dharam Singh, U.P vs. Pr. CIT Bareilly, U.P

In the result, the appeal is allowed

ITA 821/DEL/2022[2017-18]Status: DisposedITAT Delhi18 Jun 2024AY 2017-18

Bench: Shri Saktijit Dey, Vice- & Shri Naveen Chandraassessment Year: 2017-18

Section 143(3)Section 263Section 3Section 44A

also conducted discreet inquiries from third parties, including the banks, wherein, the assessee has held account by issuing notices under section 133(6) of the Act. The result of such inquiries has been meticulously noted down by the Assessing Officer in the order-sheet maintained in the assessment record. Extracts