DCIT, CENTRAL CIRCLE-1, GURUGRAM vs. PLATINUM TOWERS P.LTD, NEW DELHI

In the result, assessee’s application under Rule 27 of ITAT Rules is allowed and Revenue’s appeal is dismissed

bogus purchases was its income which has been surrendered by it to the Govt. (ii) Since the company M/s Spaze Towers Pvt. Ltd. is being separately assessed to tax and being a separate legal entity, appropriation of its funds by the directors/promoters or their family members for the purpose of their personal expenses amounts to income of the directors/promoters

PARKASH SACHDEVA,NEW DELHI vs. ACIT CENTRAL CIRCLE 18, NEW DELHI

purchasing the bogus\naccommodation entries and that the income so earned has been rolled over. The PCIT stated that\nbenefit of roll over would be admissible only if the applicant is able to show organic linkage\nbetween the source and the application of income by matching the dates and availability.\n2.4.1 From the expel sheet found during search

ASHISH KALRA,NEW DELHI vs. ACIT, CENTRAL CIRCLE-4, NEW DELHI

In the result, the appeal of the assessee for Assessment Year 2008-09 in ITA

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.4309/Del/2019 (Assessment Year 2009-10) Mr. Ashish Kalra Acit, C-3/313, Mig Flats, Janakpuri, Central Circle-4, New Delhi-110058. Vs. New Delhi. Pan-Aippk0526N (Appellant) (Respondent) Assessee By Shri Tarandeep Singh, Adv. Department By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 16/07/2025 Date Of Pronouncement 14/10/2025 O R D E R Per Manish Agarwal, Am: These Two Appeals Are Filed By The Assessee Against The Common Order Of Ld. Commissioner Of Income Tax (Appeals)-23, New Delhi [Cit(A), In Short] Dated 28.01.2019 In Appeal No. 159/2016-17 & 3/2017-18 For Asst. Years 2008-09 & 2009-10 Respectively, Both Arising Out Of Order Passed U/S 147 R.W.S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’). 2. Since, Both The Appeals Are Having Identical Issues, Therefore, They Are Adjudicated By A Common Order. First We Take Up The Appeal For Assessment Year 2008-09 In Ita No.4308/Del/2019. Ashish Kalra Vs. Acit

section 292C are also not applicable in the Ashish Kalra vs. ACIT instant case since action of search u/s 132 was not undertaken upon the 'A'. In the impugned order CIT(A) has relied upon various statements of representatives from M/s Bright. In this regard it is submitted as under: (1) Statement dated 25th November 2010 of Mr. Rashid Masood

ASHISH KALRA,NEW DELHI vs. ACIT, CENTRAL CIRCLE-4, NEW DELHI

In the result, the appeal of the assessee for Assessment Year 2008-09 in ITA

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.4309/Del/2019 (Assessment Year 2009-10) Mr. Ashish Kalra Acit, C-3/313, Mig Flats, Janakpuri, Central Circle-4, New Delhi-110058. Vs. New Delhi. Pan-Aippk0526N (Appellant) (Respondent) Assessee By Shri Tarandeep Singh, Adv. Department By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 16/07/2025 Date Of Pronouncement 14/10/2025 O R D E R Per Manish Agarwal, Am: These Two Appeals Are Filed By The Assessee Against The Common Order Of Ld. Commissioner Of Income Tax (Appeals)-23, New Delhi [Cit(A), In Short] Dated 28.01.2019 In Appeal No. 159/2016-17 & 3/2017-18 For Asst. Years 2008-09 & 2009-10 Respectively, Both Arising Out Of Order Passed U/S 147 R.W.S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’). 2. Since, Both The Appeals Are Having Identical Issues, Therefore, They Are Adjudicated By A Common Order. First We Take Up The Appeal For Assessment Year 2008-09 In Ita No.4308/Del/2019. Ashish Kalra Vs. Acit

section 292C are also not applicable in the Ashish Kalra vs. ACIT instant case since action of search u/s 132 was not undertaken upon the 'A'. In the impugned order CIT(A) has relied upon various statements of representatives from M/s Bright. In this regard it is submitted as under: (1) Statement dated 25th November 2010 of Mr. Rashid Masood