BHOPAL SINGH CHAUDHARY,DEHRADUN vs. ITO SRINAGAR, SRINAGAR GARHWAL

Bench: Shri Mahavir Singh & Shri Manish Agarwal

section 56(2) of the Act, the assessee should be taxed in the hands of the assessee as Income from other sources and which has escaped assessment. Accordingly, case was re-opened u/s 147 of the Act after obtaining approval from the competent authority and in terms of the reassessment

PAL MINERAL INDUSTRIES (P) LIMITED,HALDWANI vs. DC/ACIT, CENTRAL CIRCLE, HALDWANI, HALDWANI

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

56. We also bear in mind the pertinent observations made in RRJ Securities when the Court held that merely because an article or thing may have been recovered in the course of a search would not mean that concluded assessments have to "necessarily" be reopened under Section 153C and that those assessments are not liable to be revised unless

PAL MINERAL INDUSTRIES (P) LIMITED,HALDWANI vs. DC/ACIT, CENTRAL CIRCLE, HALDWANI, HALDWANI

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

56. We also bear in mind the pertinent observations made in RRJ Securities when the Court held that merely because an article or thing may have been recovered in the course of a search would not mean that concluded assessments have to "necessarily" be reopened under Section 153C and that those assessments are not liable to be revised unless

MOHAN PAL,HALDWANI, NAINITAL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HALDWANI, ACIT-DCIT, CENTRAL CIRCLE, HALDWANI

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

56. We also bear in mind the pertinent observations made in RRJ Securities when the Court held that merely because an article or thing may have been recovered in the course of a search would not mean that concluded assessments have to "necessarily" be reopened under Section 153C and that those assessments are not liable to be revised unless

MOHAN PAL,HALDWANI, NAINITAL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HALDWANI, ACIT - DCIT, CENTRAL CIRCLE, HALDWANI

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

56. We also bear in mind the pertinent observations made in RRJ Securities when the Court held that merely because an article or thing may have been recovered in the course of a search would not mean that concluded assessments have to "necessarily" be reopened under Section 153C and that those assessments are not liable to be revised unless

MOHAN PAL,HALDWANI, NAINITAL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HALDWANI, ACIT - DCIT, CENTRAL CIRCLE, HALDWANI

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

56. We also bear in mind the pertinent observations made in RRJ Securities when the Court held that merely because an article or thing may have been recovered in the course of a search would not mean that concluded assessments have to "necessarily" be reopened under Section 153C and that those assessments are not liable to be revised unless

SHRI ABHISHEK JOSHI,DEHRADUN vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX , DEHRADUN

In the result, the appeal of the assessee is allowed

Bench: Sh. Saktijit Dey & Shri M. Balaganeshshri Abhishek Joshi, Vs. The Pr. Cit, C/O. Parimal Patet, Gk Patet & Dehradun Co, 14 Abhishek Tower, Subhash Road, Dehradun (Appellant) (Respondent) Pan: Ajopj4300M Assessee By : Dr. Rakesh Gupta, Adv Shri Somil Aggarwal, Adv Revenue By: Shri N. S. Jangpangi, Cit Dr Date Of Hearing 26/07/2023 Date Of Pronouncement 15/09/2023

Section 263 on the basis of suspicions, surmises and conjectures. Shri Abhishek Joshi 3. That in any case and in any view of the matter, action of Ld. PCIT is bad in law and against the facts and circumstances of the case, since opportunity of being heard in person not considered and without hearing the Assessee the order