“reasons recorded”

ACIT, New Delhi vs. Sh Arvind Khanna, New Delhi

The appeal of the Department is dismissed

Bench: Shri G.D. Agrawal & Shri Sudhanshu Srivastavaassessment Year: 2007-08

that reassessment proceedings had been initiated rightly. 8. We have heard the rival submissions and perused the material on record. A perusal of the reasons recorded by the AO clearly shows that the assessment originally completed u/s 143(3) of the Act were reopened by him without any new material ... instant CO before us as well as the judicial pronouncements as discussed aforesaid, we have no hesitation in holding that from the reasons recorded it is very much clear that there was no fresh material available with the AO when he reopened the assessment which was originally completed

ACIT, New Delhi vs. Sh Arvind Khanna, New Delhi

The appeal of the Department is dismissed

Bench: Shri G.D. Agrawal & Shri Sudhanshu Srivastavaassessment Year: 2007-08

that reassessment proceedings had been initiated rightly. 8. We have heard the rival submissions and perused the material on record. A perusal of the reasons recorded by the AO clearly shows that the assessment originally completed u/s 143(3) of the Act were reopened by him without any new material ... instant CO before us as well as the judicial pronouncements as discussed aforesaid, we have no hesitation in holding that from the reasons recorded it is very much clear that there was no fresh material available with the AO when he reopened the assessment which was originally completed

Agya Ram vs. Commissioner of Income Tax

The appeals are allowed but in the circumstances with no order as to

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE NAJMI WAZIRI

that income chargeable to tax had escaped assessment. It is in the above background that the Court is called upon to examine whether the reasons recorded by the AO for reopening the assessments for the aforementioned AYs satisfied the requirement of the law. Although the AO may not have required

Agya Ram vs. Commmissioner of Income Tax

The appeals are allowed but in the circumstances with no order as to

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE NAJMI WAZIRI

that income chargeable to tax had escaped assessment. It is in the above background that the Court is called upon to examine whether the reasons recorded by the AO for reopening the assessments for the aforementioned AYs satisfied the requirement of the law. Although the AO may not have required

DCIT, Rohtak vs. M/S. A.K. Automatic, Rohtak

Appeal is dismissed

Bench: Shri R. S. Syal & Smt Suchitra Kamblei.T.A .No.-2368/Del/2014 (Assessment Year 2010-11)

assessee. 6. The Ld. DR submitted that in the preceding Assessment Year 2009-2010, the GP rate adopted was 19.59% and the reasons recorded by the Assessing Officer for adopting the same in the present assessment year are correct and invocation of Section 145(3) of the Act for rejecting

Pearl Retails Pvt. Ltd., Gurgaon vs. DCIT, New Delhi

In the result, appeal of the assessee is allowed on legal grounds

Bench: In The Income Tax Appellate Tribunal Delhi Bench ‘F’ New Delhi Before Shri G.D. Agrawal. & Shri Chandra Mohan Gargassessment Year: 2004-05

drawn by the assessee from the facts disclosed by the assessee during the assessment proceedings. The ld. AR lastly contended that from the reasons recorded, it is clear that the A.O mentioned that the amount of Rs. 50 lakhs needs to be disallowed which the assessee had returned back during

M/S. Central Gum & Chemicals Limited, New Delhi vs. DCIT, New Delhi

In the result, the assessee’s appeal is allowed

Bench: Sh. Sudhanshu Srivastava & Sh. O.P. Kantassessment Year: 2008-09 M/S. Central Gum & Chemicals Vs. Dcit, Central –Iii, New Ltd., 308, Arunachal Building Delhi 19, Barakhamba Road, New Delhi Gir/Pan :Aaccc4405A (Appellant) (Respondent) Appellant By Sh. V. Raja Kumar, Adv. Respondent By Sh. Sunil Chander Sharma, Cit(Dr) Date Of Hearing 26.07.2016 Date Of Pronouncement 29.07.2016 Order Per O.P. Kant, A.M.: This Appeal By The Assessee Is Directed Against Order Dated 06/11/2013 Of The Learned Commissioner Of Income-Tax (Appeals)-Xxxiii, New Delhi For Assessment Year 2008-09 Raising Following Grounds: “That The Ld. Cit (A) Erred In Confirming The Assessment Order Passed U/S 143 (3) Of The Act On 27.12.2010 Which Is Bad Both On Facts & In Law; 2) That The Authorities Below Erred Both On Facts & In Law In Making An Addition Of Rs.24,17,66,963/- U/S 68 Of The Income-Tax Act, 1961 Without Appreciating The Fact

deposited in the bank accounts of intermediatories and cheques were issued to the beneficiaries of almost the same amounts. It is seen from the reasons recorded by the A.O. for issue of notice under section 148 for the A.Y. 2006-07 (the facts are same for A.Y. 2008-09 which ... that he was an entry provider and that he had deposited his own cash which was used to issue cheques to the beneficiaries. The reasons recorded for issue of notice u/s 148 clearly state that the applicant is an entry provider. Further, the report of the A.O. that the beneficiaries

ACIT, New Delhi vs. M/S. Sng Developers Ltd., New Delhi

In the result, the cross objection filed by the assessee as well as the appeal filed by the Revenue are dismissed

from the Investigation Wing and recorded reasons without applying his mind. The learned Authorized Representative submitted that there was repetition of entries in the reasons recorded by the AO, which shows that, he did not take due care in recording reasons. The learned Authorized Representative relied on the decision ... assessee has not been disputed that the validity of the reopening of the assessment should be judged only with reference to the reasons recorded by the Assessing Officer under sec. 148(2) at the time of issue of notice of reopening and any other material sought to be relied upon