ACIT, NEW DELHI vs. SH MAHAGUN INDIA PVT. LTD.,, DELHI

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

survey action u/s 133A of the assessee 20.03.2007. Thereafter a search and seizure operation was also conducted by the Investigation Wing V(I), Delhi in Mahagun group of cases on 27.08.2008 which included the premises of the assessee u/s 132 of the Income-tax Act, 1961 [the Act, for short]. After centralizing the assessee’s case, notice u/s 153A

MAHUGUN INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

survey action u/s 133A of the assessee 20.03.2007. Thereafter a search and seizure operation was also conducted by the Investigation Wing V(I), Delhi in Mahagun group of cases on 27.08.2008 which included the premises of the assessee u/s 132 of the Income-tax Act, 1961 [the Act, for short]. After centralizing the assessee’s case, notice u/s 153A

ACIT, NEW DELHI vs. SH MAHAGUN INDIA PVT. LTD.,, DELHI

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

survey action u/s 133A of the assessee 20.03.2007. Thereafter a search and seizure operation was also conducted by the Investigation Wing V(I), Delhi in Mahagun group of cases on 27.08.2008 which included the premises of the assessee u/s 132 of the Income-tax Act, 1961 [the Act, for short]. After centralizing the assessee’s case, notice u/s 153A

MAHAGUN INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

survey action u/s 133A of the assessee 20.03.2007. Thereafter a search and seizure operation was also conducted by the Investigation Wing V(I), Delhi in Mahagun group of cases on 27.08.2008 which included the premises of the assessee u/s 132 of the Income-tax Act, 1961 [the Act, for short]. After centralizing the assessee’s case, notice u/s 153A

M/S. OIL INDUSTRY DEVELOPMENT BOARD,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the three appeals filed by the assessee are allowed

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

survey u/s 133A was conducted on the assessee’s premises in the course of which certain documents belonged to certain entities who had applied for shares in the assessee company were found. The AO called upon the assessee to prove the nature and source of the monies received as share capital, the creditworthiness of the applicants and the genuineness

M/S. OIL INDUSTRY DEVELOPMENT BOARD,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the three appeals filed by the assessee are allowed

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

survey u/s 133A was conducted on the assessee’s premises in the course of which certain documents belonged to certain entities who had applied for shares in the assessee company were found. The AO called upon the assessee to prove the nature and source of the monies received as share capital, the creditworthiness of the applicants and the genuineness

M/S. OIL INDUSTRY DEVELOPMENT BOARD,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the three appeals filed by the assessee are allowed

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

survey u/s 133A was conducted on the assessee’s premises in the course of which certain documents belonged to certain entities who had applied for shares in the assessee company were found. The AO called upon the assessee to prove the nature and source of the monies received as share capital, the creditworthiness of the applicants and the genuineness

ACIT, CENTRAL CIRCLE - 04, NEW DELHI vs. JAGATJIT INDUSTRIES LIMITED, NEW DELHI

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

u/s 133A of the Act was also conducted on various premises of the assessee. Based on the survey report the ld AO noted that there is a discrepancy in rebate and discount in the books of account of the assessee and in the ledger account of the assessee in the books of account of some of its distributors of state

ACIT, CENTRAL CIRCLE - 04, NEW DELHI vs. JAGATJIT INDUSTRIES LIMITED, NEW DELHI

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

u/s 133A of the Act was also conducted on various premises of the assessee. Based on the survey report the ld AO noted that there is a discrepancy in rebate and discount in the books of account of the assessee and in the ledger account of the assessee in the books of account of some of its distributors of state

VEDANTA LTD ,GURGAON vs. ACIT, CIRCLE- 26(2), NEW DELHI

Bench: Shri N.K. Billaiya & Shri Kuldip Singh[Assessment Year: 2014-15]

u/s 32AC of the Act. This ground is, accordingly, allowed. 82. The next ground relates to the addition of Rs.1095.93 crores on account of out of books receivables. 83. Facts on record show that during the course of survey conducted under section 133A of the Act on 20.3.2014 at the business premises of the appellant, certain documents were impounded, which

M/S FIREPRO WIRELESS & TECHNOLOGIES PVT. LTD.,,NEW DELHI vs. ACIT, NEW DELHI

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

u/s 133 A is reproduced below: A simultaneous survey operation was conducted on M/s Jay Enn Infotech Pvt. Ltd. and M/s Binary Network Solution Pvt. Ltd. under section 133A of Income Tax Act, 1961 on 24/09/2009 at 105,A/2, Saraswati House - 27, Nehru Place, New Delhi with an action under section 132 on Tulip Group of cases. Smt. Nirmala Jain

ACIT, NEW DELHI vs. M/S. ACB INDIA LTD.,, NEW DELHI

Accordingly, ground No. 1 and 2 of the appeal of the revenue is dismissed and similarly the Cross objection of the assessee is supportive in nature and same is allowed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

survey u/s 132 and 133A of the Act were conducted on 12.04.2012 in case of assessee along with the other cases of Aryan Sainik Group. Consequent to that notice u/s 153A was issued on 09.10.2013 which was complied by the assessee by filing return on 26.08.2014 at Rs. 1452111350/-. During the assessment proceedings it was noted that assessee has claimed

ACIT, NEW DELHI vs. M/S. ACB INDIA LTD.,, NEW DELHI

Accordingly, ground No. 1 and 2 of the appeal of the revenue is dismissed and similarly the Cross objection of the assessee is supportive in nature and same is allowed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

survey u/s 132 and 133A of the Act were conducted on 12.04.2012 in case of assessee along with the other cases of Aryan Sainik Group. Consequent to that notice u/s 153A was issued on 09.10.2013 which was complied by the assessee by filing return on 26.08.2014 at Rs. 1452111350/-. During the assessment proceedings it was noted that assessee has claimed

ACIT, NEW DELHI vs. M/S. ACB INDIA LTD.,, NEW DELHI

Accordingly, ground No. 1 and 2 of the appeal of the revenue is dismissed and similarly the Cross objection of the assessee is supportive in nature and same is allowed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

survey u/s 132 and 133A of the Act were conducted on 12.04.2012 in case of assessee along with the other cases of Aryan Sainik Group. Consequent to that notice u/s 153A was issued on 09.10.2013 which was complied by the assessee by filing return on 26.08.2014 at Rs. 1452111350/-. During the assessment proceedings it was noted that assessee has claimed

MIRHA EXPORTS PRIVATE LTD. ,DELHI vs. DCIT CENTRAL CIRCLE, GZBD, UTTAR PRADESH

In the result, both appeals of the assessee are allowed and both appeals of the Revenue are dismissed

Bench: Shri Sudhir Kumar & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 873/Del/2022 2012-13 Dcit M/S. Mirha Exports Pvt.Ltd. (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 2. 655/Del/2022 2012-13 M/S. Mirha Exports Dcit (Assessee’S Appeal) Pvt.Ltd. Central Circle 30, Bazar Lane, Ghaziabad Bengali Market, Central Delhi-110001 Pan-Aaacm8612P 3. 1233/Del/2022 2013-14 Dcit M/S. Mirha Exports Pvt. Ltd. (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 4. 656/Del/2022 2013-14 M/S. Mirha Exports Dcit (Assessee’S Appeal) Pvt. Ltd. Central Circle Ghaziabad 30, Bazar Lane, Bengali Market, Central Delhi-110001 Pan-Aaacm8612P 5. 1234/Del/2022 2015-16 Dcit M/S. Mirha Exports Pvt. Ltd. (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 6. 657/Del/2022 2015-16 M/S. Mirha Exports Dcit Pvt. Ltd. (Assessee’S Appeal) Central Circle 30, Bazar Lane, Ghaziabad Bengali Market, Central Delhi-110001 Pan-Aaacm8612P M/S. Mirha Exports Pvt. Ltd. 7. 874/Del/2022 2016-17 Dcit (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 8. 658/Del/2022 2016-17 M/S. Mirha Exports Dcit Pvt. Ltd. (Assessee’S Appeal) Central Circle Ghaziabad 30, Bazar Lane, Bengali Market, Central Delhi-110001 Pan-Aaacm8612P M/S. Mirha Exports Pvt. Ltd. 9. 875/Del/2022 2017-18 Dcit (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P

survey was carried out u/s 133A of the Act at the business premises of the assessee. Consequently, proceedings u/s 153C were initiated in the case of assessee. Looking to the complex nature of the documents seized, reference was made for special audit u/s 142(2A) of the Act and the Special Audit Report was received on 26.06.2018. Subsequently, following

MIRHA EXPORTS PRIVATE LTD. ,DELHI vs. DCIT CENTRAL CIRCLE, GZBD , U.P

In the result, both appeals of the assessee are allowed and both appeals of the Revenue are dismissed

Bench: Shri Sudhir Kumar & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 873/Del/2022 2012-13 Dcit M/S. Mirha Exports Pvt.Ltd. (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 2. 655/Del/2022 2012-13 M/S. Mirha Exports Dcit (Assessee’S Appeal) Pvt.Ltd. Central Circle 30, Bazar Lane, Ghaziabad Bengali Market, Central Delhi-110001 Pan-Aaacm8612P 3. 1233/Del/2022 2013-14 Dcit M/S. Mirha Exports Pvt. Ltd. (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 4. 656/Del/2022 2013-14 M/S. Mirha Exports Dcit (Assessee’S Appeal) Pvt. Ltd. Central Circle Ghaziabad 30, Bazar Lane, Bengali Market, Central Delhi-110001 Pan-Aaacm8612P 5. 1234/Del/2022 2015-16 Dcit M/S. Mirha Exports Pvt. Ltd. (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 6. 657/Del/2022 2015-16 M/S. Mirha Exports Dcit Pvt. Ltd. (Assessee’S Appeal) Central Circle 30, Bazar Lane, Ghaziabad Bengali Market, Central Delhi-110001 Pan-Aaacm8612P M/S. Mirha Exports Pvt. Ltd. 7. 874/Del/2022 2016-17 Dcit (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 8. 658/Del/2022 2016-17 M/S. Mirha Exports Dcit Pvt. Ltd. (Assessee’S Appeal) Central Circle Ghaziabad 30, Bazar Lane, Bengali Market, Central Delhi-110001 Pan-Aaacm8612P M/S. Mirha Exports Pvt. Ltd. 9. 875/Del/2022 2017-18 Dcit (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P

survey was carried out u/s 133A of the Act at the business premises of the assessee. Consequently, proceedings u/s 153C were initiated in the case of assessee. Looking to the complex nature of the documents seized, reference was made for special audit u/s 142(2A) of the Act and the Special Audit Report was received on 26.06.2018. Subsequently, following

MIRHA EXPORTS PRIVATE LTD. ,DELHI vs. DCIT CENTRAL CIRCLE, GZBD, UTTAR PRADESH

In the result, both appeals of the assessee are allowed and both appeals of the Revenue are dismissed

Bench: Shri Sudhir Kumar & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 873/Del/2022 2012-13 Dcit M/S. Mirha Exports Pvt.Ltd. (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 2. 655/Del/2022 2012-13 M/S. Mirha Exports Dcit (Assessee’S Appeal) Pvt.Ltd. Central Circle 30, Bazar Lane, Ghaziabad Bengali Market, Central Delhi-110001 Pan-Aaacm8612P 3. 1233/Del/2022 2013-14 Dcit M/S. Mirha Exports Pvt. Ltd. (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 4. 656/Del/2022 2013-14 M/S. Mirha Exports Dcit (Assessee’S Appeal) Pvt. Ltd. Central Circle Ghaziabad 30, Bazar Lane, Bengali Market, Central Delhi-110001 Pan-Aaacm8612P 5. 1234/Del/2022 2015-16 Dcit M/S. Mirha Exports Pvt. Ltd. (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 6. 657/Del/2022 2015-16 M/S. Mirha Exports Dcit Pvt. Ltd. (Assessee’S Appeal) Central Circle 30, Bazar Lane, Ghaziabad Bengali Market, Central Delhi-110001 Pan-Aaacm8612P M/S. Mirha Exports Pvt. Ltd. 7. 874/Del/2022 2016-17 Dcit (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 8. 658/Del/2022 2016-17 M/S. Mirha Exports Dcit Pvt. Ltd. (Assessee’S Appeal) Central Circle Ghaziabad 30, Bazar Lane, Bengali Market, Central Delhi-110001 Pan-Aaacm8612P M/S. Mirha Exports Pvt. Ltd. 9. 875/Del/2022 2017-18 Dcit (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P

survey was carried out u/s 133A of the Act at the business premises of the assessee. Consequently, proceedings u/s 153C were initiated in the case of assessee. Looking to the complex nature of the documents seized, reference was made for special audit u/s 142(2A) of the Act and the Special Audit Report was received on 26.06.2018. Subsequently, following

MIRHA EXPORTS PRIVATE LTD., DELHI vs. DCIT CENTRAL CIRCLE, GZBD

In the result, both appeals of the assessee are allowed and both appeals of the Revenue are dismissed

Bench: Shri Sudhir Kumar & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 873/Del/2022 2012-13 Dcit M/S. Mirha Exports Pvt.Ltd. (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 2. 655/Del/2022 2012-13 M/S. Mirha Exports Dcit (Assessee’S Appeal) Pvt.Ltd. Central Circle 30, Bazar Lane, Ghaziabad Bengali Market, Central Delhi-110001 Pan-Aaacm8612P 3. 1233/Del/2022 2013-14 Dcit M/S. Mirha Exports Pvt. Ltd. (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 4. 656/Del/2022 2013-14 M/S. Mirha Exports Dcit (Assessee’S Appeal) Pvt. Ltd. Central Circle Ghaziabad 30, Bazar Lane, Bengali Market, Central Delhi-110001 Pan-Aaacm8612P 5. 1234/Del/2022 2015-16 Dcit M/S. Mirha Exports Pvt. Ltd. (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 6. 657/Del/2022 2015-16 M/S. Mirha Exports Dcit Pvt. Ltd. (Assessee’S Appeal) Central Circle 30, Bazar Lane, Ghaziabad Bengali Market, Central Delhi-110001 Pan-Aaacm8612P M/S. Mirha Exports Pvt. Ltd. 7. 874/Del/2022 2016-17 Dcit (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 8. 658/Del/2022 2016-17 M/S. Mirha Exports Dcit Pvt. Ltd. (Assessee’S Appeal) Central Circle Ghaziabad 30, Bazar Lane, Bengali Market, Central Delhi-110001 Pan-Aaacm8612P M/S. Mirha Exports Pvt. Ltd. 9. 875/Del/2022 2017-18 Dcit (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P

survey was carried out u/s 133A of the Act at the business premises of the assessee. Consequently, proceedings u/s 153C were initiated in the case of assessee. Looking to the complex nature of the documents seized, reference was made for special audit u/s 142(2A) of the Act and the Special Audit Report was received on 26.06.2018. Subsequently, following