ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

153A of the Act. So in this case before us, since the AO of the searched person as well as that of the other/third party/assessee foundation are the same, he/AO of assessee can issue notice u/s 153C of the Act only after satisfaction of this condition precedent also in addition to the requirement of Satisfaction of searched person

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

153A of the Act. So in this case before us, since the AO of the searched person as well as that of the other/third party/assessee foundation are the same, he/AO of assessee can issue notice u/s 153C of the Act only after satisfaction of this condition precedent also in addition to the requirement of Satisfaction of searched person

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

153A of the Act. So in this case before us, since the AO of the searched person as well as that of the other/third party/assessee foundation are the same, he/AO of assessee can issue notice u/s 153C of the Act only after satisfaction of this condition precedent also in addition to the requirement of Satisfaction of searched person

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

153A of the Act. So in this case before us, since the AO of the searched person as well as that of the other/third party/assessee foundation are the same, he/AO of assessee can issue notice u/s 153C of the Act only after satisfaction of this condition precedent also in addition to the requirement of Satisfaction of searched person

DCIT-CENTRAL CIRCLE-2, FARIDABAD vs. A2Z INFRA ENGINEERS LTD., GURGAON

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

disallowance without arriving at a prima facie satisfaction with respect to infraction by the assessee of clause (c) of sub-section (1) of Section 271 of the Act. A requirement which is mandated by the provision itself. 15.7 Learned ASG also sought to place reliance on the Memorandum as well as Clause 48 of the Notes on Clauses appended

A2Z MAINTENANCE & ENGINEERING SERVICES LTD.,GURGAON vs. DCIT, CENTRAL CIRCLE-II, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

disallowance without arriving at a prima facie satisfaction with respect to infraction by the assessee of clause (c) of sub-section (1) of Section 271 of the Act. A requirement which is mandated by the provision itself. 15.7 Learned ASG also sought to place reliance on the Memorandum as well as Clause 48 of the Notes on Clauses appended

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. CCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

disallowance without arriving at a prima facie satisfaction with respect to infraction by the assessee of clause (c) of sub-section (1) of Section 271 of the Act. A requirement which is mandated by the provision itself. 15.7 Learned ASG also sought to place reliance on the Memorandum as well as Clause 48 of the Notes on Clauses appended

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT CC-2 , FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

disallowance without arriving at a prima facie satisfaction with respect to infraction by the assessee of clause (c) of sub-section (1) of Section 271 of the Act. A requirement which is mandated by the provision itself. 15.7 Learned ASG also sought to place reliance on the Memorandum as well as Clause 48 of the Notes on Clauses appended

DCIT CC-2 , FARIDABAD vs. A2Z MAINTENANCE AND ENGINEERING SERVICES LTD., GURGAON

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

disallowance without arriving at a prima facie satisfaction with respect to infraction by the assessee of clause (c) of sub-section (1) of Section 271 of the Act. A requirement which is mandated by the provision itself. 15.7 Learned ASG also sought to place reliance on the Memorandum as well as Clause 48 of the Notes on Clauses appended

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

disallowance without arriving at a prima facie satisfaction with respect to infraction by the assessee of clause (c) of sub-section (1) of Section 271 of the Act. A requirement which is mandated by the provision itself. 15.7 Learned ASG also sought to place reliance on the Memorandum as well as Clause 48 of the Notes on Clauses appended

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

disallowance without arriving at a prima facie satisfaction with respect to infraction by the assessee of clause (c) of sub-section (1) of Section 271 of the Act. A requirement which is mandated by the provision itself. 15.7 Learned ASG also sought to place reliance on the Memorandum as well as Clause 48 of the Notes on Clauses appended

INFRA ENGINEERS LTD.,GURGAON vs. DCIT, CC-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

disallowance without arriving at a prima facie satisfaction with respect to infraction by the assessee of clause (c) of sub-section (1) of Section 271 of the Act. A requirement which is mandated by the provision itself. 15.7 Learned ASG also sought to place reliance on the Memorandum as well as Clause 48 of the Notes on Clauses appended

DEPUTY COMMISSIONER , DELHI vs. RAVINDRA SINGH, GREATER NOIDA

In the result, the Appeals of the Revenue in I

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 2456/Del/2023 (A.Y 2011-12) I.T.A. No. 2457/Del/2023 (A.Y 2012-13) I.T.A. No. 2458/Del/2023 (A.Y 2013-14) I.T.A. No. 2459/Del/2023 (A.Y 2014-15)

1. The Ld. CIT(A) has erred on facts and in law in deleting the disallowance of Rs. 6,09,00,000/-made by the Assessing Officer u/s 69 of the Income-tax Act, 1961. 2. The Ld. CIT(A) has erred in deleting the addition of Rs. 6,09,00,000/- in light of the decision the Apex Court

DEPUTY COMMISSIONER, DELHI vs. RAVINDRA SINGH, GREATER NOIDA

In the result, the Appeals of the Revenue in I

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 2456/Del/2023 (A.Y 2011-12) I.T.A. No. 2457/Del/2023 (A.Y 2012-13) I.T.A. No. 2458/Del/2023 (A.Y 2013-14) I.T.A. No. 2459/Del/2023 (A.Y 2014-15)

1. The Ld. CIT(A) has erred on facts and in law in deleting the disallowance of Rs. 6,09,00,000/-made by the Assessing Officer u/s 69 of the Income-tax Act, 1961. 2. The Ld. CIT(A) has erred in deleting the addition of Rs. 6,09,00,000/- in light of the decision the Apex Court

DEPUTY COMMISSIONER, DELHI vs. RAVINDRA SINGH, GREATER NOIDA

In the result, the Appeals of the Revenue in I

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 2456/Del/2023 (A.Y 2011-12) I.T.A. No. 2457/Del/2023 (A.Y 2012-13) I.T.A. No. 2458/Del/2023 (A.Y 2013-14) I.T.A. No. 2459/Del/2023 (A.Y 2014-15)

1. The Ld. CIT(A) has erred on facts and in law in deleting the disallowance of Rs. 6,09,00,000/-made by the Assessing Officer u/s 69 of the Income-tax Act, 1961. 2. The Ld. CIT(A) has erred in deleting the addition of Rs. 6,09,00,000/- in light of the decision the Apex Court

COMMISSIONER OF INCOME TAX-7 vs. RRJ SECURITIES LTD

Bench: The Tribunal, Were Filed By The Revenue (Being

section 153C(1) and read with 153A(1) get attracted. Moreover, there is no legal requirement that initiation of proceedings should only be with respect to such years in respect of which there is some material. Now coming to the issue that the satisfaction note should contain some satisfaction on the part of the AO leading to undisclosed income

COMMISSIONER OF INCOME TAX-7 vs. RRJ SECURITIES LTD

Bench: The Tribunal, Were Filed By The Revenue (Being

section 153C(1) and read with 153A(1) get attracted. Moreover, there is no legal requirement that initiation of proceedings should only be with respect to such years in respect of which there is some material. Now coming to the issue that the satisfaction note should contain some satisfaction on the part of the AO leading to undisclosed income

COMMISSIONER OF INCOME TAX-7 vs. RRJ SECURITIES LTD

Bench: The Tribunal, Were Filed By The Revenue (Being

section 153C(1) and read with 153A(1) get attracted. Moreover, there is no legal requirement that initiation of proceedings should only be with respect to such years in respect of which there is some material. Now coming to the issue that the satisfaction note should contain some satisfaction on the part of the AO leading to undisclosed income