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

disallowance is primarily based on:  A statement recorded under Section 132(4) during search; and  An inference that payments made

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

section Issue Additions made by AO Additions confirmed by CIT(A) Additions deleted by CIT(A) 2018-19 148 Disallowance of purchases expenses u/s 37(1) Alleged cash receipts as unexplained money 69A on account of ticket sales for events 88,636,574 4,018,132

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

section Issue Additions made by AO Additions confirmed by CIT(A) Additions deleted by CIT(A) 2018-19 148 Disallowance of purchases expenses u/s 37(1) Alleged cash receipts as unexplained money 69A on account of ticket sales for events 88,636,574 4,018,132

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

section Issue Additions made by AO Additions confirmed by CIT(A) Additions deleted by CIT(A) 2018-19 148 Disallowance of purchases expenses u/s 37(1) Alleged cash receipts as unexplained money 69A on account of ticket sales for events 88,636,574 4,018,132

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

section Additions made by AO Additions confirmed by CIT(A) Additions deleted by CIT(A) 2018-19 148 Disallowance of purchases expenses u/s 37(1) Alleged cash receipts as unexplained money 69A on account of ticket sales for events 88,636,574 4,018,132

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

section Issue Additions made by AO Additions confirmed by CIT(A) Additions deleted by CIT(A) 2018-19 148 Disallowance of purchases expenses u/s 37(1) Alleged cash receipts as unexplained money 69A on account of ticket sales for events 88,636,574 4,018,132

ACIT, CENTRAL CIRCLE-15, NEW DELHI vs. LUXMAN BUILDERS PVT. LTD., NEW DELHI

In the result, the CO filed by the assessee is allowed and the appeal filed by the Revenue is dismissed

Bench: Shri R.K. Panda & Shri Kul Bharatassessment Year: 2010-11 Acit, Vs Lumax Builders Pvt. Ltd., Central Circle-15, 25, Bazar Lane, New Delhi. Bengali Market, New Delhi. Pan: Aaacl2184R Co No.93/Del/2018 (Ita No.817/Del/2018) Assessment Year: 2010-11 Lumax Builders Pvt. Ltd., Vs. Acit, 25, Bazar Lane, Central Circle-15, Bengali Market, New Delhi New Delhi. Pan: Aaacl2184R (Appellant) (Respondent) Assessee By : Shri Gautam Jain, Advocate & Shri Lalit Mohan, Advocate Revenue By : Ms Paramita M. Biswas, Cit, Dr Date Of Hearing : 16.09.2021 Date Of Pronouncement : 14.12.2021 Order Per R.K. Panda, Am: This Appeal Filed By The Revenue Is Directed Against The Order Dated 3Rd November, 2017 Of The Cit(A)-26, New Delhi, Relating To Assessment Year 2010- 11. Co No.93/Del/2018 2. The Assessee Has Filed The Co Against The Appeal Filed By The Revenue. For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Common Order.

section 132(4) of Sh. Sampat Sharma cannot be treated as incriminating material found during the course of search. In the result, we hold that addition of share capital in the year under consideration has been made without relying on any incriminating material found during the course of search.” 44. In the light of the above decisions, statements recorded

NIRALA DEVELOPERS PVT. LTD.,,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the five appeals are dismissed

Bench: Shri S.K. Yadav & Shri Anadee Nath Misshra

Section as U/s i. Nirala Housing Pvt. Ltd. as NHPL j. Nirala Developers Pvt. Ltd. as NDPL (2) For the sake of convenience, these appeals are being hereby disposed off through this consolidated order, as similar/interlinked issues are involved in these appeals. These appeals pertain to two assessees namely Nirala Housing Pvt. Ltd. (in ITA No. 3135/Del/2015, 3136/Del/2015, 3137/Del/2015) & Nirala

DCIT, NEW DELHI vs. M/S NIRALA HOUSING PVT. LTD.,, NEW DELHI

In the result, all the five appeals are dismissed

Bench: Shri S.K. Yadav & Shri Anadee Nath Misshra

Section as U/s i. Nirala Housing Pvt. Ltd. as NHPL j. Nirala Developers Pvt. Ltd. as NDPL (2) For the sake of convenience, these appeals are being hereby disposed off through this consolidated order, as similar/interlinked issues are involved in these appeals. These appeals pertain to two assessees namely Nirala Housing Pvt. Ltd. (in ITA No. 3135/Del/2015, 3136/Del/2015, 3137/Del/2015) & Nirala

M/S. NIRALA HOUSING PVT. LTD.,,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the five appeals are dismissed

Bench: Shri S.K. Yadav & Shri Anadee Nath Misshra

Section as U/s i. Nirala Housing Pvt. Ltd. as NHPL j. Nirala Developers Pvt. Ltd. as NDPL (2) For the sake of convenience, these appeals are being hereby disposed off through this consolidated order, as similar/interlinked issues are involved in these appeals. These appeals pertain to two assessees namely Nirala Housing Pvt. Ltd. (in ITA No. 3135/Del/2015, 3136/Del/2015, 3137/Del/2015) & Nirala

M/S. NIRALA HOUSING PVT. LTD.,,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the five appeals are dismissed

Bench: Shri S.K. Yadav & Shri Anadee Nath Misshra

Section as U/s i. Nirala Housing Pvt. Ltd. as NHPL j. Nirala Developers Pvt. Ltd. as NDPL (2) For the sake of convenience, these appeals are being hereby disposed off through this consolidated order, as similar/interlinked issues are involved in these appeals. These appeals pertain to two assessees namely Nirala Housing Pvt. Ltd. (in ITA No. 3135/Del/2015, 3136/Del/2015, 3137/Del/2015) & Nirala

M/S. NIRALA HOUSING PVT. LTD.,,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the five appeals are dismissed

Bench: Shri S.K. Yadav & Shri Anadee Nath Misshra

Section as U/s i. Nirala Housing Pvt. Ltd. as NHPL j. Nirala Developers Pvt. Ltd. as NDPL (2) For the sake of convenience, these appeals are being hereby disposed off through this consolidated order, as similar/interlinked issues are involved in these appeals. These appeals pertain to two assessees namely Nirala Housing Pvt. Ltd. (in ITA No. 3135/Del/2015, 3136/Del/2015, 3137/Del/2015) & Nirala

DCIT, NEW DELHI vs. SH. AMANDEEP SINGH SRAN, NEW DELHI

Accordingly, the appeal of the ld AO is allowed and CO of the assessee is dismissed

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi(Through Video Conferencing) Amandeep Singh Saran, Vs. Acit, B-53, B-1, Community Centre, Central Circle-4, Janakpuri, New Delhi New Delhi Pan: Auvps5370E (Appellant) (Respondent) Dcit, Vs. Amandeep Singh Saran, Central Circle-29, 7/73, Punjabi Bagh West New Delhi Pan: Auvps5370E

132(4). 13. In the present case, during the course of the statement made by the assessee, during the course of the search on 4 March, 2010, that she had lent Rs.16 crores in aggregate to three individuals during financial year 2009-2010. This was in response to a query by the revenue officials during the course of search when

DCIT, NEW DELHI vs. SH. HARMENDER SINGH SRAN, NEW DELHI

Accordingly, the appeal of the ld AO is allowed and CO of the assessee is dismissed

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi(Through Video Conferencing) Amandeep Singh Saran, Vs. Acit, B-53, B-1, Community Centre, Central Circle-4, Janakpuri, New Delhi New Delhi Pan: Auvps5370E (Appellant) (Respondent) Dcit, Vs. Amandeep Singh Saran, Central Circle-29, 7/73, Punjabi Bagh West New Delhi Pan: Auvps5370E

132(4). 13. In the present case, during the course of the statement made by the assessee, during the course of the search on 4 March, 2010, that she had lent Rs.16 crores in aggregate to three individuals during financial year 2009-2010. This was in response to a query by the revenue officials during the course of search when

LSL TOOLS (P) LTD,GURUGRAM vs. ACIT , CENTRAL CIRCLE-1, FARIDABAD

In the result, both the appeals are allowed

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

132(4) of the Act without reference to any material detected as a result of search. AO rejected the same and observed involvement in the functioning of the entity of which she is an employee. Based on the above information, AO invoked the provisions of section 40A(2)(b) of the Act and disallowed

LSL TOOLS (P) LTD.,GURGAON vs. ACIT, CC-1, FARIDABAD

In the result, both the appeals are allowed

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

132(4) of the Act without reference to any material detected as a result of search. AO rejected the same and observed involvement in the functioning of the entity of which she is an employee. Based on the above information, AO invoked the provisions of section 40A(2)(b) of the Act and disallowed

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

section Additions made Additions confirmed Additions deleted by AO by CIT(A) by CIT(A) 2018-19 148 Disallowance of purchases expenses u/s 37(1) Alleged cash receipts as unexplained money 69A on account of ticket sales for events 88,636,574 1,352,382 87,284,192 4,018,132

PR. COMMISSIONER OF INCOME TAX CENTRAL 2 NEW DELHI vs. MEETA GUTGUTIA PROP M/S FERNS N PETALS

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE CHANDER SHEKHAR

132 (4) of the Act. At this stage, it must be noted that no statement was made by the Assessee herself. A statement was made under Section 133A by Shri Pawan Gadia. 12. The disclosures made of undisclosed income for various AYs were estimated by the AO as under: “(a) AY 2001-02 @ 50% of disclosed amount Rs.55