THE PR. COMMISSIONER OF INCOME TAX -6 vs. MARUTI SUZUKI INDIA LTD.

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

144B of the Act, confirming the additions made by the TPO.  The final assessment order dated 30.07.2023 was accompanied by a notice of demand issued under section Whether a final assessment order passed without passing a draft assessment order as mandated under Section 144C of the Act is tenable or not? Digitally Signed By:KAMLESH KUMAR Signing Date

SRF LIMITED ,DELHI vs. ACIT, CIRCLE-10(1), DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

XI. Disallowance of Depreciation of Goodwill amounting to Rs. 10,77,290/- 59.0 That the Ld. DRP and consequently the Ld. AO have erred in law and on the facts & circumstances of the assessee’s case in making the disallowance of depreciation of Rs. 10,77,290/- on goodwill arising on acquisition of three business units from SRF Polymers

SRF LIMITED,DELHI vs. ASSISTANT / DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 10(1), NEW DELHI, DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

XI. Disallowance of Depreciation of Goodwill amounting to Rs. 10,77,290/- 59.0 That the Ld. DRP and consequently the Ld. AO have erred in law and on the facts & circumstances of the assessee’s case in making the disallowance of depreciation of Rs. 10,77,290/- on goodwill arising on acquisition of three business units from SRF Polymers

SRF LIMITED,NEW DELHI vs. ACIT, CIRCLE-10(1), DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

XI. Disallowance of Depreciation of Goodwill amounting to Rs. 10,77,290/- 59.0 That the Ld. DRP and consequently the Ld. AO have erred in law and on the facts & circumstances of the assessee’s case in making the disallowance of depreciation of Rs. 10,77,290/- on goodwill arising on acquisition of three business units from SRF Polymers

ARUN DUGGAL,FARIDABAD vs. ACIT, CENTRAL CIRCLE- 4, NEW DELHI

In the result, all the appeals of the Assessees are allowed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

xi) There is inconsistency in the statement of Sh. Sanjay Duggal, during the course of search, u/s 132(4) at his residential premise, with regard to deposits in the bank account of M/s Alfa India. There was variance in the statement with regard to source - i) partner capital as source of fund in the bank account of M/s Alfa India

SANJAY DUGGAL,FARIDABAD vs. ACIT, CENTRAL CIRCLE- 4, NEW DELHI

In the result, all the appeals of the Assessees are allowed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

xi) There is inconsistency in the statement of Sh. Sanjay Duggal, during the course of search, u/s 132(4) at his residential premise, with regard to deposits in the bank account of M/s Alfa India. There was variance in the statement with regard to source - i) partner capital as source of fund in the bank account of M/s Alfa India

NANY DUGGAL,FARIDABAD vs. ACIT, CENTRAL CIRCLE- 4 , NEW DELHI

In the result, all the appeals of the Assessees are allowed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

xi) There is inconsistency in the statement of Sh. Sanjay Duggal, during the course of search, u/s 132(4) at his residential premise, with regard to deposits in the bank account of M/s Alfa India. There was variance in the statement with regard to source - i) partner capital as source of fund in the bank account of M/s Alfa India

SANJAY DUGGAL,FARIDABAD vs. ACIT, CENTRAL CIRCLE- 4, NEW DELHI

In the result, all the appeals of the Assessees are allowed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

xi) There is inconsistency in the statement of Sh. Sanjay Duggal, during the course of search, u/s 132(4) at his residential premise, with regard to deposits in the bank account of M/s Alfa India. There was variance in the statement with regard to source - i) partner capital as source of fund in the bank account of M/s Alfa India

SANJAY DUGGAL,FARIDABAD vs. ACIT, CENTRAL CIRCLE- 4, NEW DELHI

In the result, all the appeals of the Assessees are allowed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

xi) There is inconsistency in the statement of Sh. Sanjay Duggal, during the course of search, u/s 132(4) at his residential premise, with regard to deposits in the bank account of M/s Alfa India. There was variance in the statement with regard to source - i) partner capital as source of fund in the bank account of M/s Alfa India

DUGGAL & SONS BUILDWELL (P) LTD.,FARIDABAD vs. ACIT, CENTRAL CIRCLE- 4, NEW DELHI

In the result, all the appeals of the Assessees are allowed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

xi) There is inconsistency in the statement of Sh. Sanjay Duggal, during the course of search, u/s 132(4) at his residential premise, with regard to deposits in the bank account of M/s Alfa India. There was variance in the statement with regard to source - i) partner capital as source of fund in the bank account of M/s Alfa India

DUGGAL & SONS BUILDWELL (P) LTD.,FARIDABAD vs. ACIT, CENTRAL CIRCLE- 4, NEW DELHI

In the result, all the appeals of the Assessees are allowed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

xi) There is inconsistency in the statement of Sh. Sanjay Duggal, during the course of search, u/s 132(4) at his residential premise, with regard to deposits in the bank account of M/s Alfa India. There was variance in the statement with regard to source - i) partner capital as source of fund in the bank account of M/s Alfa India

NEERU DUGGAL,FARIDABAD vs. ACIT, CENTRAL CIRCLE- 4 , NEW DELHI

In the result, all the appeals of the Assessees are allowed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

xi) There is inconsistency in the statement of Sh. Sanjay Duggal, during the course of search, u/s 132(4) at his residential premise, with regard to deposits in the bank account of M/s Alfa India. There was variance in the statement with regard to source - i) partner capital as source of fund in the bank account of M/s Alfa India

DUGGAL & SONS BUILDWELL (P) LTD.,FARIDABAD vs. ACIT, CENTRAL CIRCLE- 4, NEW DELHI

In the result, all the appeals of the Assessees are allowed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

xi) There is inconsistency in the statement of Sh. Sanjay Duggal, during the course of search, u/s 132(4) at his residential premise, with regard to deposits in the bank account of M/s Alfa India. There was variance in the statement with regard to source - i) partner capital as source of fund in the bank account of M/s Alfa India

RAJNISH TALWAR,NEW DELHI vs. ACIT, CENTRAL CIRCLE-4, NEW DELHI

In the result, all the appeals of the Assessees are allowed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

xi) There is inconsistency in the statement of Sh. Sanjay Duggal, during the course of search, u/s 132(4) at his residential premise, with regard to deposits in the bank account of M/s Alfa India. There was variance in the statement with regard to source - i) partner capital as source of fund in the bank account of M/s Alfa India

RAJNISH TALWAR,NEW DELHI vs. ACIT, CENTRAL CIRCLE-4, NEW DELHI

In the result, all the appeals of the Assessees are allowed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

xi) There is inconsistency in the statement of Sh. Sanjay Duggal, during the course of search, u/s 132(4) at his residential premise, with regard to deposits in the bank account of M/s Alfa India. There was variance in the statement with regard to source - i) partner capital as source of fund in the bank account of M/s Alfa India

ARUN DUGGAL,FARIDABAD vs. ACIT, CENTRAL CIRCLE- 4, NEW DELHI

In the result, all the appeals of the Assessees are allowed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

xi) There is inconsistency in the statement of Sh. Sanjay Duggal, during the course of search, u/s 132(4) at his residential premise, with regard to deposits in the bank account of M/s Alfa India. There was variance in the statement with regard to source - i) partner capital as source of fund in the bank account of M/s Alfa India

DUGGAL & SONS BUILDWELL (P) LTD.,FARIDABAD vs. ACIT, CENTRAL CIRCLE- 4, NEW DELHI

In the result, all the appeals of the Assessees are allowed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

xi) There is inconsistency in the statement of Sh. Sanjay Duggal, during the course of search, u/s 132(4) at his residential premise, with regard to deposits in the bank account of M/s Alfa India. There was variance in the statement with regard to source - i) partner capital as source of fund in the bank account of M/s Alfa India

POONAM DUGGAL,FARIDABAD vs. ACIT, CENTRAL CIRCLE-4, NEW DELHI

In the result, all the appeals of the Assessees are allowed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

xi) There is inconsistency in the statement of Sh. Sanjay Duggal, during the course of search, u/s 132(4) at his residential premise, with regard to deposits in the bank account of M/s Alfa India. There was variance in the statement with regard to source - i) partner capital as source of fund in the bank account of M/s Alfa India