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76 results for “section 68”+ Section 10(3)clear

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Key Topics

Addition to Income64Section 6849Section 143(3)48Section 44B42Section 153A41Section 153D40Section 153C39Section 6931Section 14820Unexplained Cash Credit

REENA VERMA,HARIDWAR vs. ITO, WARD-1(3)(5), ROORKEE

In the result, the appeal of the assessee stands partly allowed as above

ITA 2215/DEL/2018[2010-11]Status: DisposedITAT Dehradun09 May 2025AY 2010-11

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 133(6)Section 143(3)Section 147Section 148Section 40ASection 68

10 Reena Verma completed/unabated assessments under sections 147/148 is saved subject to fulfillment of the conditions as envisaged/mentioned under section 147/148 of the Act. In view of the foregoing discussion, we do not see any infirmity in the finding of the Ld. CIT(A) upholding the reopening of the case. Reopening of the case thus is held valid

Showing 1–20 of 76 · Page 1 of 4

15
Disallowance15
Cash Deposit14

ADIT (INTERNATIONAL TAXATION), DEHRADUN vs. M/S. M.I, OVERSEAS LTD., MUMBAI

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5564/DEL/2013[2007-08]Status: DisposedITAT Dehradun08 Jun 2021AY 2007-08

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

3. The learned CIT(A) has erred in rejecting the Appellant‟s claim, wherein the Appellant had offered 2% of the revenues from offshore supply of imported materials from PSC and Non-PSC partners to tax following the assessment order for AY 2006-07, in order to avoid litigation and to buy peace of mind. 4. The learned

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 2956/DEL/2013[2006-07]Status: DisposedITAT Dehradun08 Jun 2021AY 2006-07

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

3. The learned CIT(A) has erred in rejecting the Appellant‟s claim, wherein the Appellant had offered 2% of the revenues from offshore supply of imported materials from PSC and Non-PSC partners to tax following the assessment order for AY 2006-07, in order to avoid litigation and to buy peace of mind. 4. The learned

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5584/DEL/2013[2010-11]Status: DisposedITAT Dehradun08 Jun 2021AY 2010-11

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

3. The learned CIT(A) has erred in rejecting the Appellant‟s claim, wherein the Appellant had offered 2% of the revenues from offshore supply of imported materials from PSC and Non-PSC partners to tax following the assessment order for AY 2006-07, in order to avoid litigation and to buy peace of mind. 4. The learned

ADIT, DEHRADUN vs. M/S. M.I. OVERSEAS LTD., NOIDA

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 3045/DEL/2013[2006-07]Status: DisposedITAT Dehradun08 Jun 2021AY 2006-07

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

3. The learned CIT(A) has erred in rejecting the Appellant‟s claim, wherein the Appellant had offered 2% of the revenues from offshore supply of imported materials from PSC and Non-PSC partners to tax following the assessment order for AY 2006-07, in order to avoid litigation and to buy peace of mind. 4. The learned

ADIT (INTERNATIONAL TAXATION), DEHRADUN vs. M/S. M.I, OVERSEAS LTD., MUMBAI

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5565/DEL/2013[2010-11]Status: DisposedITAT Dehradun08 Jun 2021AY 2010-11

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

3. The learned CIT(A) has erred in rejecting the Appellant‟s claim, wherein the Appellant had offered 2% of the revenues from offshore supply of imported materials from PSC and Non-PSC partners to tax following the assessment order for AY 2006-07, in order to avoid litigation and to buy peace of mind. 4. The learned

MI OVERSEAS LTD.,NEW DELHI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 3072/DEL/2012[2009-10]Status: DisposedITAT Dehradun08 Jun 2021AY 2009-10

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

3. The learned CIT(A) has erred in rejecting the Appellant‟s claim, wherein the Appellant had offered 2% of the revenues from offshore supply of imported materials from PSC and Non-PSC partners to tax following the assessment order for AY 2006-07, in order to avoid litigation and to buy peace of mind. 4. The learned

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5583/DEL/2013[2007-08]Status: DisposedITAT Dehradun08 Jun 2021AY 2007-08

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

3. The learned CIT(A) has erred in rejecting the Appellant‟s claim, wherein the Appellant had offered 2% of the revenues from offshore supply of imported materials from PSC and Non-PSC partners to tax following the assessment order for AY 2006-07, in order to avoid litigation and to buy peace of mind. 4. The learned

DCIT, CIRCLE- I, INTERNATIONAL TAXATION, DEHRADUN vs. EXPRESS DRILLING SYSTEMS LLC, DEHRADUN

In the result, cross objection filed by the assessee is partly

ITA 6114/DEL/2017[2009-10]Status: DisposedITAT Dehradun26 Sept 2023AY 2009-10

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshआ.अ.सं/.I.T.A No.6114/Del/2017 िनधा"रणवष"/Assessment Year: 2009-10 बनाम Dcit, Express Drilling Circle-1, Vs. Systems Llc, International Taxation, C/O Nangia & Co., 1St Floor, Ida, 46, Dehradun, Uttarakhand. E.C. Road, Dehradun, Uttarakhand. Pan No.Aabce6891R अपीलाथ" Appellant ""यथ"/Respondent & Cross Objection No. 13/Del/2018 (In I.T.A No.6114/Del/2017) िनधा"रणवष"/Assessment Year: 2009-10 बनाम Express Drilling Systems Llc, Dcit, Vs. C/O Nangia & Co., Circle-1, 1St Floor, Ida, 46, International Taxation, E.C. Road, Dehradun, Dehradun, Uttarakhand. Uttarakhand. Pan No. Aabce6891R अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 144CSection 234BSection 40

3 SCL 422. FAILURE TO ADHERE TO THE MANDATORY PROCEDURE PRESCRIBED UNDER SECTION 144C OF THE ACT WOULD VITIATE THE ENTIRE PROCEEDINGS AND THE SAME CANNOT BE TREATED AS AN IRREGULARITY/CURABLE DEFECT. 22. The appellant has also contended that the failure to follow the procedure under section 144C of the Act, at the highest, was a procedural irregularity

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), DEHRADUN, DEHRADUN vs. CHAKRATA FIRST AND ASSOCIATES, JAIPUR

Appeal is dismissed

ITA 92/DDN/2023[2017-18]Status: DisposedITAT Dehradun23 May 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh(Through Video Conferencing) Assessment Year: 2017-18 Acit, Vs. Chakrata First & Circle-1(1)(1), Associates, C/O- Amit Tak 41 Dehradun Sanjay Marg, Hathori Fort, Jaipur, Rajasthan Pan: Aalfc2896B (Appellant) (Respondent) Assessee By Sh. S.K. Ahuja, Ar Department By Sh. Amar Pal Singh, Sr. Dr

Section 145(3)Section 69A

10% of gross receipts or turnover of Rs. 16,61,28,493 was estimated, which comes to Rs. 1,66,12,849. 7. Findings 7.1. I have considered the submissions and grounds of appeal of the appellant carefully. The assessment order u/s 143(3) has been perused. The details as submitted have been examined. The grounds of appeal

JOINT COMMISSIONER OF INCOME TAX, SUBHASH ROAD DEHADUN vs. M/S TIMES SQUARE, SAHASTRADHARA ROAD

In the result, appeal of the Revenue is dismissed

ITA 42/DDN/2025[2017-18]Status: DisposedITAT Dehradun26 Sept 2025AY 2017-18
Section 143(3)Section 250Section 43CSection 69A

68,650/- which is less than 10%. As per section 43CA difference\nto the extent of 10% is allowable. By Finance Act, 2018, the first\nproviso to Section 43CA(1) was inserted, and this proviso provided\nthat \"where the value adopted or assessed or assessable by the\nauthority for the purpose of payment of stamp duty does

SH. SURENDER KUMAR CHAWLA,RUDRAPUR vs. ACIT, CC- HALDWANI, HALDWANI

In the result, assessee's appeals; ITA No

ITA 74/DDN/2024[2015-16]Status: DisposedITAT Dehradun20 Nov 2025AY 2015-16
Section 142Section 143(3)Section 68Section 69

10,000/- on account of alleged\npurchase of property from Mr. Mohan Pal as alleged unexplained\ninvestment u/s 69 of the Income Tax Act, 1961.\n6. The learned assessing officer as also learned CIT(A) have erred in making\nand confirming addition of Rs.10,66,71,000/- on account of alleged\npurchase of property from Mr. Mohan Pal as alleged

RAJESH AGGARWAL ,DEHRADUN vs. THE DEPUTY COMMISSIONER OF INCOME TAX OFFICER, CENTRAL CIRCLE, DEHRADUN

In the result, all the appeals of the assessee are allowed

ITA 199/DDN/2019[2013-14]Status: DisposedITAT Dehradun23 Jun 2023AY 2013-14
Section 115BSection 132Section 132(4)Section 139(1)Section 153ASection 68

10) is decided in favour of the assessees and the orders of the Commissioner of Income- tax(Appeals) on this issue is upheld on the ground that the returns filed under section 153A are returns filed under section 139(1).” 14. On perusal of provisions of section 153A of the Act, we find that there

MUSSORIE DEHRADUN DEVELOPMENT AUTHORITY ,DEHRADUN vs. DY.CIT, DEHRADUN

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

ITA 55/DDN/2023[2014-15]Status: DisposedITAT Dehradun19 Feb 2025AY 2014-15

Bench: the date of agreement. In his reply AR of the assessee submitted that only Rs.14,00,415/- was received during the year and the assessee has inadvertently forgot to include this amount in its income. So, this may be considered as income from transfer of the above property. He furnished receipt of the above amount which is place on record. MDDA

Section 4Section 43C

3 MDDA relevant year on receipt of amount of Rs.14,10,001/- whose value for stamp purposes was Rs.1,30,68,000/-. It was submitted that the appellant assessee was required to pay stamp duty on the free-hold charges. Our attention was drawn towards finding of the AO wherein the AO and the Ld. CIT(A) had held that

DCIT, RISHIKESH vs. M/S UTTRANCHAL IRON & ISPAT LTD.,, KOTDWAR

In the result, this appeal of the assessee (ITA No

ITA 2078/DEL/2017[2012-13]Status: DisposedITAT Dehradun09 May 2025AY 2012-13

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 143(3)Section 145Section 145(3)Section 80

3) of the Act is highly presumptive, arbitrary and unjust. 8. That, in view of the facts and circumstances, the assessing officer has erred in law and on facts in making the addition on account of Low Net Profit at Rs.1,26,68,177.00 by estimating the net profit @1.82%, which is highly arbitrary, unjust and against the facts

UTTRANCHAL IRON & ISPAT LTD.,KOTDWAR vs. DCIT, CIRCLE- 1(4)(1), RISHIKESH

In the result, this appeal of the assessee (ITA No

ITA 4201/DEL/2018[2013-14]Status: DisposedITAT Dehradun09 May 2025AY 2013-14

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 143(3)Section 145Section 145(3)Section 80

3) of the Act is highly presumptive, arbitrary and unjust. 8. That, in view of the facts and circumstances, the assessing officer has erred in law and on facts in making the addition on account of Low Net Profit at Rs.1,26,68,177.00 by estimating the net profit @1.82%, which is highly arbitrary, unjust and against the facts

G & T RESOURCES (EUROPE) LTD.,NEW DELHI vs. ADIT, DEHRADUN

In the result, the appeal of the assessee is allowed

ITA 5553/DEL/2012[2004-05]Status: DisposedITAT Dehradun29 Apr 2022AY 2004-05

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 5553/Del/2012 : Asstt. Year: 2004-05 G&T Resources (Europe) Ltd., Vs Adit, C/O F-04 & 05, Triveni Commercial International Taxation, Complex, Sheikh Sarai, Phase-I, Dehradun New Delhi-110017 (Appellant) (Respondent) Pan No. Aabcg9877F Assessee By : None Revenue By : Sh. T. S. Mapwal, Sr. Dr Date Of Hearing: 25.04.2022 Date Of Pronouncement: 29.04.2022 Order Per Dr. B. R. R. Kumar: The Present Appeal Has Been Filed By The Assessee Against The Order Passed By The Ao U/S 143(3) Of The Income Tax Act, 1961 Dated 23.11.2006. 2. The Assessee Has Raised Revised Grounds Of Appeal: “1. That, On The Facts & In The Circumstances Of The Case & In Law, The Learned Ao Has Erred On Facts & In Law In Initiating Proceedings Under Section 148 Read Together With Section 147 Of The Income 1Ax Act, 1961. 2. That In The Absence Of Any New Facts, Other Than The Ones Already On Record Based On Which The Assessment Order Was Passed, Initiating Proceedings Under Section 148 After Expiry Of Four Years Are Bad In Law & Void Abinitio. 3. That, The Learned Ao Having Considered The Facts, Applied The Spirit Of The Boards Instructions As Contained In Notification 1767 In A Speaking Assessment Order Erred In Initiating Proceedings Under Section 148 After The Expiry Of Four Years Merely Because In A Subsequent

For Appellant: NoneFor Respondent: Sh. T. S. Mapwal, Sr. DR
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 44B

10% and income on sale of the spares carried outside India @1% as the deemed profit which has been duly examined and accepted by the AO. 5. The assessment was concluded by the Assistant Commissioner of Income-tax (OSD), Range-I, Dehradun vide assessment order dated 22.11.2006 under section 143(3) of the Act. The assessment was reopened

SIDHARTH BUILDWELL LLP,DEHRADUN vs. ACIT, C- 1(2)(1), DEHRADUN

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

ITA 129/DDN/2024[2017-18]Status: DisposedITAT Dehradun27 Feb 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmansidharth Buildwell Llp Vs. Acit, 1, Darshiningate, Kanwali, Circle 1(2)(1), Kanwali B.O. Dehradun Haripuram, Dehradun Pan: Acufs6966M (Appellant) (Respondent) Assessee By: Ms. Komal Sachev, Ca Revenue By: Sh. A.S.Rana, Sr. Dr Date Of Hearing: 14.01.2026 Date Of Order : 27.02.2026 Order Per S. Rifaur Rahman: The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Ld. Cit(A)”, For Short] Dated 07.06.2024 For The Assessment Year 2017-18. 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income On 07.11.2017 Declaring Income At Rs. 95,08,920/- For Assessment Year 2017- 18. The Case Was Selected For Complete Scrutiny Through Cass With The Reasons “Higher Turnover Reported In Service Tax Return As Compared To Itr, Large Increase In Unsecured Loans During The Year, Real Estate Business

For Appellant: Ms. Komal Sachev, CAFor Respondent: Sh. A.S.Rana, Sr. DR
Section 115BSection 133(6)Section 142(1)Section 143(2)Section 68

10. Vijay Pal Singh Bisht 76000 3 4. Further, notices u/s 133(6) of the Act were also issued to the above said parties to submit confirmations alongwith bank statements and copies of ITR. It is found that some notices were returned back undelivered and also no replies were received from the parties. Subsequently, a show cause notice was issued

INTECSEA ASIA PACIFIC SDN BHD,MALAYSIA vs. ACIT, INTERNATIONAL TAXATION, CIRCLE- 1, DEHRADUN

The appeal of the assessee is allowed

ITA 5577/DEL/2018[2015-16]Status: DisposedITAT Dehradun08 Oct 2021AY 2015-16

Bench: Shri Amit Shukla & Shri B.R.R. Kumarasstt. Year : 2015-16 Intecsea Asia Pacific N Vs. Acit, International Bhd Taxation, Circle-1, Kpmg Salarpuria Knowledge Dehradun City, Orwell Unit 3, 6Th Floor Sy. No. 83/2, Plot 2, Raidurg, Hyderabad 500081 (Appellant) (Respondent)

For Appellant: Shri Ajit Jain, CA
Section 143(2)Section 143(3)Section 44BSection 44DSection 9

3, are therefore, partly allowed.” 8. We have heard both the parties and also perused the relevant finding of the impugned order as well as material preferred to before us. During the relevant assessment year the appellant assessee has received consideration from ONGC and Leighton India for providing engineering consultancy services. During the course of assessment proceeding

DEPUTY COMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN, DEHRADUN vs. KAMAL JEWELLERS, DEHRADUN

In the result, Appeal of the Revenue in ITA

ITA 161/DDN/2025[2017-18]Status: DisposedITAT Dehradun14 Jan 2026AY 2017-18

Bench: Sh. Yogesh Kumar Us & Sh. Manish Agarwal

For Appellant: Sh. Rajiv Sahini, CAFor Respondent: Ms. Poonam Sharma, CIT-DR
Section 139(4)Section 143(3)Section 68

3. The turnover as per audited financial statement is Rs. 92,88,33,383/- and the said turnover has been accepted by the order of DC, VAT dated 25.01.2020. 4. The books of accounts have been accepted by the AO and the AO has not tinkered with the purchase; sale & trading results shown by the assessee. 5. All the sales