DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

bogus expenditure collapses. IV. Section 65B Compliance IV. Section 65B Compliance – Electro IV. Section 65B Compliance IV. Section 65B Compliance Electro Electronic Evidence Electro nic Evidence nic Evidence nic Evidence • No chain-of-custody documentation has been placed to establish reliability of alleged seized digital extracts relied upon by the Assessing Officer. V. Comparative Position – Sunil Aggarwal V. Comparative Position

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT CENTRAL CIRCLE -05 , DELHI

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

bogus expenditure collapses. IV. Section 65B Compliance IV. Section 65B Compliance – Electro IV. Section 65B Compliance IV. Section 65B Compliance Electro Electronic Evidence Electro nic Evidence nic Evidence nic Evidence • No chain-of-custody documentation has been placed to establish reliability of alleged seized digital extracts relied upon by the Assessing Officer. V. Comparative Position – Sunil Aggarwal V. Comparative Position

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

purchases as\ngenuine. The disallowance is primarily based on:\nA statement recorded under Section 132(4) during search; and\nAn inference that payments made through banking channels\nwere allegedly returned in cash.\nThe Assessee respectfully submits that:\nThe statement was retracted before the Assessing Officer;\nThe retraction was supported by documentary evidence;\nThe addition is unsupported by corroborative material

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

purchases as\ngenuine. The disallowance is primarily based on:\nA statement recorded under Section 132(4) during search; and\nAn inference that payments made through banking channels\nwere allegedly returned in cash.\nThe Assessee respectfully submits that:\nThe statement was retracted before the Assessing Officer;\nThe retraction was supported by documentary evidence;\nThe addition is unsupported by corroborative material

VESTIGE MARKETING PVT LTD,NEW DELHI vs. DCIT, CENTRAL CIRCLE- 05, DELHI

purchases as\ngenuine. The disallowance is primarily based on:\nA statement recorded under Section 132(4) during search; and\nAn inference that payments made through banking channels\nwere allegedly returned in cash.\nThe Assessee respectfully submits that:\nThe statement was retracted before the Assessing Officer;\nThe retraction was supported by documentary evidence;\nThe addition is unsupported by corroborative material

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT CENTRAL CIRCLE-05, DELHI

purchases as\ngenuine. The disallowance is primarily based on:\nA statement recorded under Section 132(4) during search; and\nAn inference that payments made through banking channels\nwere allegedly returned in cash.\nThe Assessee respectfully submits that:\nThe statement was retracted before the Assessing Officer;\nThe retraction was supported by documentary evidence;\nThe addition is unsupported by corroborative material

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

purchases as\ngenuine. The disallowance is primarily based on:\nA statement recorded under Section 132(4) during search; and\nAn inference that payments made through banking channels\nwere allegedly returned in cash.\nThe Assessee respectfully submits that:\nThe statement was retracted before the Assessing Officer;\nThe retraction was supported by documentary evidence;\nThe addition is unsupported by corroborative material

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT, CENTRAL CIRCLE-05, DELHI

purchases as\ngenuine. The disallowance is primarily based on:\n➤ A statement recorded under Section 132(4) during search; and\n➤ An inference that payments made through banking channels\nwere allegedly returned in cash.\nThe Assessee respectfully submits that:\n➤ The statement was retracted before the Assessing Officer;\n➤ The retraction was supported by documentary evidence;\n➤ The addition

VESTIGE MARKETING PVT. LTD.,DELHI vs. DCIT, CENTRAL CIRCLE- 05, DELHI

purchases as\ngenuine. The disallowance is primarily based on:\n➤ A statement recorded under Section 132(4) during search; and\nAn inference that payments made through banking channels\nwere allegedly returned in cash.\nThe Assessee respectfully submits that:\nThe statement was retracted before the Assessing Officer;\nThe retraction was supported by documentary evidence;\nThe addition is unsupported by corroborative material

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

purchases as\nbogus. The disallowance is primarily based on:\nA statement recorded under Section 132(4) during search; and\nAn inference that payments made through banking channels\nwere allegedly returned in cash.\nThe Assessee respectfully submits that:\nThe statement was retracted before the Assessing Officer;\nThe retraction was supported by documentary evidence;\nThe addition is unsupported by corroborative material

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT, CENTRAL CIRCLE- 05, DELHI

purchases as\ngenuine. The disallowance is primarily based on:\nA statement recorded under Section 132(4) during search; and\nAn inference that payments made through banking channels\nwere allegedly returned in cash.\nThe Assessee respectfully submits that:\nThe statement was retracted before the Assessing Officer;\nThe retraction was supported by documentary evidence;\nThe addition is unsupported by corroborative material

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

purchases as\nbogus. The disallowance is primarily based on:\n➤ A statement recorded under Section 132(4) during search; and\nAn inference that payments made through banking channels\nwere allegedly returned in cash.\nThe Assessee respectfully submits that:\nThe statement was retracted before the Assessing Officer;\nThe retraction was supported by documentary evidence;\nThe addition is unsupported by corroborative material

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT, CENTRAL CIRCLE-05, DELHI

purchases as\nbogus. The disallowance is primarily based on:\n➤ A statement recorded under Section 132(4) during search; and\n➤ An inference that payments made through banking channels\nwere allegedly returned in cash.\nThe Assessee respectfully submits that:\n➤ The statement was retracted before the Assessing Officer;\n➤ The retraction was supported by documentary evidence;\n➤ The addition

LAKHMI CHAND CHARITABLE SOCIETY,NEW DELHI vs. PCIT CENTRAL 3, NEW DELHI

Bench: Shri S. Rifaur Rahman & Ms.Madhumita Roylakhmi Chand Vs. Principal Commissioner Charitable Society, Of Income Tax, Central-3 Elephanta Lane, Behind Room No. 325, 3Rd Floor, Sector-10/6 Market, New Income Tax Building, E-3 Golak Dham, Sector-10, Ara Centre, Jhandewalan Dwarka, Extension, New Delhi - 110075 New Delhi - 110055

section.  Wordings used in sec 12AB(4) "has noticed occurrence of one or more specified violations during any previous year" make legislative intent very clear about covering years prior to 01.04.2021  Hon'ble ITAT, Delhi in Young Indian Vs CIT(Exemption) (ITA No.7751/Del/2017) has held that order of cancellation of registration even passed on subsequent date would take effect from

SUPER CASSETTES INDUSTRIES PVT LTD,NEW DELHI vs. DCIT CENTRAL CIRCLE-3, DELHI

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

Bogus expenses to SCIPL. 8.22 In respect of transaction with M/s Sagal International Pvt Ltd, Ld. Counsel for the assessee highlighted that the AO has erroneously added Rs. 38,50,000/- instead of Rs. 32,50,000/- to the total income of appellant company being 5% of job work amount of Rs. 6,50,00,000/-. On verification of this

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3, DELHI vs. SUPER CASSETTES INDUSTRIES PRIVATE LIMITED, DELHI

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

Bogus expenses to SCIPL. 8.22 In respect of transaction with M/s Sagal International Pvt Ltd, Ld. Counsel for the assessee highlighted that the AO has erroneously added Rs. 38,50,000/- instead of Rs. 32,50,000/- to the total income of appellant company being 5% of job work amount of Rs. 6,50,00,000/-. On verification of this

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3, DELHI vs. SUPER CASSETTES INDUSTRIES PRIVATE LIMITED, DELHI

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

Bogus expenses to SCIPL. 8.22 In respect of transaction with M/s Sagal International Pvt Ltd, Ld. Counsel for the assessee highlighted that the AO has erroneously added Rs. 38,50,000/- instead of Rs. 32,50,000/- to the total income of appellant company being 5% of job work amount of Rs. 6,50,00,000/-. On verification of this

SUPER CASSETTES INDUSTRIES PVT LTD,DELHI vs. DCIT CENTRAL CIRCLE-3, DELHI

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

Bogus expenses to SCIPL. 8.22 In respect of transaction with M/s Sagal International Pvt Ltd, Ld. Counsel for the assessee highlighted that the AO has erroneously added Rs. 38,50,000/- instead of Rs. 32,50,000/- to the total income of appellant company being 5% of job work amount of Rs. 6,50,00,000/-. On verification of this

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3, NEW DELHI, DELHI vs. SUPER CASSETTES INDUSTRIES PVT. LTD., DELHI

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

Bogus expenses to SCIPL. 8.22 In respect of transaction with M/s Sagal International Pvt Ltd, Ld. Counsel for the assessee highlighted that the AO has erroneously added Rs. 38,50,000/- instead of Rs. 32,50,000/- to the total income of appellant company being 5% of job work amount of Rs. 6,50,00,000/-. On verification of this