SHRI CHETAN SETH,NEW DELHI vs. ITO, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

dividend u/s 2(22)(e) of the Act. Accordingly, the Assessing Officer taxed an amount of Rs.3,90,00,000/- as deemed income u/s 2(22)(e) of the Act in the hands of the assessee Shri Chetan Seth. 7. Against the said assessment order, the assessee preferred an appeal before the ld. CIT(A). The ld. CIT(A) vide

SHRI CHETAN SETH,NEW DELHI vs. ITO, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

dividend u/s 2(22)(e) of the Act. Accordingly, the Assessing Officer taxed an amount of Rs.3,90,00,000/- as deemed income u/s 2(22)(e) of the Act in the hands of the assessee Shri Chetan Seth. 7. Against the said assessment order, the assessee preferred an appeal before the ld. CIT(A). The ld. CIT(A) vide

CHETAN SETH,NEW DELHI vs. ITO,WARD-15(3), DELHI

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

dividend u/s 2(22)(e) of the Act. Accordingly, the Assessing Officer taxed an amount of Rs.3,90,00,000/- as deemed income u/s 2(22)(e) of the Act in the hands of the assessee Shri Chetan Seth. 7. Against the said assessment order, the assessee preferred an appeal before the ld. CIT(A). The ld. CIT(A) vide

ISWAR CHAND DUBEY,DELHI vs. ITO,WARD-68 (1), DELHI

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

dividend u/s 2(22)(e) of the Act. Accordingly, the Assessing Officer taxed an amount of Rs.3,90,00,000/- as deemed income u/s 2(22)(e) of the Act in the hands of the assessee Shri Chetan Seth. 7. Against the said assessment order, the assessee preferred an appeal before the ld. CIT(A). The ld. CIT(A) vide

PUNIT KUMAR AGGARWAL,DELHI vs. ITO,WARD-36(2), DELHI

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

dividend u/s 2(22)(e) of the Act. Accordingly, the Assessing Officer taxed an amount of Rs.3,90,00,000/- as deemed income u/s 2(22)(e) of the Act in the hands of the assessee Shri Chetan Seth. 7. Against the said assessment order, the assessee preferred an appeal before the ld. CIT(A). The ld. CIT(A) vide

HARMANDER SINGH SRAN,NEW DELHI vs. ACIT, CC- 29, NEW DELHI

In the result, the appeal of the assessee is allowed

deemed dividend. Accordingly, he\nrecorded the reasons and initiated the reassessment proceedings\nu/s 148 of the Act by issue of notice

MITHLESH KUMAR TRIPATHI,DELHI vs. ITO,WARD-24(4), DELHI

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishra

reassessment notice was issued despite the absence of any failure on the appellant's part to disclose material facts fully and truly. As a result, the entire assessment proceedings are bad in law and void ab initio. 3. Improper Characterization of Transactions: 3.1 That the CIT(A) and AO incorrectly treated the reimbursements received from Anupam Chempharma

COMMISSIONER OF INCOME TAX (CENTRAL)-III vs. KABUL CHAWLA

deemed dividend income under Section 2 (22) (e) of the Act corresponding to the respective protective assessments in the hands of two entities, i.e. STPPL and PPDPL. 13. Replying to the above arguments, Mr. C.S. Aggarwal, learned Senior Counsel for the Assessee, referred to the observations in CIT v. Anil Kumar Bhatia (supra) and the subsequent judgements and emphasised that

COMMISSIONER OF INCOME TAX (CENTRAL)-III vs. KABUL CHAWLA

deemed dividend income under Section 2 (22) (e) of the Act corresponding to the respective protective assessments in the hands of two entities, i.e. STPPL and PPDPL. 13. Replying to the above arguments, Mr. C.S. Aggarwal, learned Senior Counsel for the Assessee, referred to the observations in CIT v. Anil Kumar Bhatia (supra) and the subsequent judgements and emphasised that

COMMISSIONER OF INCOME TAX (CENTRAL)-III vs. KABUL CHAWLA

deemed dividend income under Section 2 (22) (e) of the Act corresponding to the respective protective assessments in the hands of two entities, i.e. STPPL and PPDPL. 13. Replying to the above arguments, Mr. C.S. Aggarwal, learned Senior Counsel for the Assessee, referred to the observations in CIT v. Anil Kumar Bhatia (supra) and the subsequent judgements and emphasised that

INCOME TAX OFFICER, GHAZIABAD vs. RAJEEV KUMAR ARORA, GHAZIABAD

In the result, the appeals of the revenue are dismissed and Rule 27

Bench: Shri M. Balaganesh & Shri Vimal Kumar

deemed dividend considering the same to have been paid as loans in lieu of dividend. ITA Nos. 622, 641, 698 & 642/Del/2024 Rajeev Kumar Arora 8. But from perusal of the reasons recorded for reopening the assessment reproduced supra , which is common to all the years under consideration except change in figures, we find that the ld. AO in para

INCOME TAX OFFICER, GHAZIABAD vs. RAJEEV KUMAR ARORA, GHAZIABAD

In the result, the appeals of the revenue are dismissed and Rule 27

Bench: Shri M. Balaganesh & Shri Vimal Kumar

deemed dividend considering the same to have been paid as loans in lieu of dividend. ITA Nos. 622, 641, 698 & 642/Del/2024 Rajeev Kumar Arora 8. But from perusal of the reasons recorded for reopening the assessment reproduced supra , which is common to all the years under consideration except change in figures, we find that the ld. AO in para

INCOME TAX OFFICER, GHAZIABAD vs. RAJEEV KUMAR ARORA, GHAZIABAD

In the result, the appeals of the revenue are dismissed and Rule 27

Bench: Shri M. Balaganesh & Shri Vimal Kumar

deemed dividend considering the same to have been paid as loans in lieu of dividend. ITA Nos. 622, 641, 698 & 642/Del/2024 Rajeev Kumar Arora 8. But from perusal of the reasons recorded for reopening the assessment reproduced supra , which is common to all the years under consideration except change in figures, we find that the ld. AO in para

INCOME TAX OFFICER WARD 2(2)(2), GHAZIABAD vs. RAJEEV KUMAR ARORA, GHAZIABAD

In the result, the appeals of the revenue are dismissed and Rule 27

Bench: Shri M. Balaganesh & Shri Vimal Kumar

deemed dividend considering the same to have been paid as loans in lieu of dividend. ITA Nos. 622, 641, 698 & 642/Del/2024 Rajeev Kumar Arora 8. But from perusal of the reasons recorded for reopening the assessment reproduced supra , which is common to all the years under consideration except change in figures, we find that the ld. AO in para

ASSISSTANT COMMISSIONER OF INCOME TAX, JHANDEWALAN EXTN. vs. OM PRAKASH ARORA, CONNAUGHT PLACE

In the result, appeal of the Revenue vide ITA No

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2015-16] Assistant Commissioner Of Om Prakash Arora, Income Tax, Central Circle-01, M-3, Flat No.103, Avg Bhawan E-2, Jhandewalan Extn. Vs The Variety Books Depot. New Delhi-110055 Connaught Place, New Delhi-110001 Pan-Accpa9774F Assessee Revenue Cross Objection No.42/Del/2025 (Arising Out Of Ita No.5031/Del/2024) [Assessment Year: 2015-16] Om Prakash Arora, Assistant Commissioner Of Income M-3, Flat No.103, Avg Tax, Central Circle-01, Bhawan The Variety Books Vs E-2, Jhandewalan Extn. Depot. Connaught Place, New Delhi-110055 New Delhi-110001 Pan-Accpa9774F Assessee Revenue [Assessment Year: 2016-17] Assistant Commissioner Of Om Prakash Arora, Income Tax, Central Circle-01, M-3, Flat No.103, Avg Bhawan E-2, Jhandewalan Extn. Vs The Variety Books Depot. New Delhi-110055 Connaught Place, New Delhi-110001 Pan-Accpa9774F Assessee Revenue

deemed dividend under section 2(22)(e) of the Act had escaped assessment. In response to the said notice, the Appellant filed return of income on 20.02.2019. The Appellant also requested for supply of reasons recorded before issue of notice under section 148 of the Act for reopening the assessment. The certifiedof the reasons recorded was supplied to the Appellant

ASSISSTANT COMMISSIONER OF INCOME TAX, JHANDEWALAN EXTN. vs. OM PRAKASH ARORA, CONNAUGHT PLACE

In the result, appeal of the Revenue vide ITA No

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2015-16] Assistant Commissioner Of Om Prakash Arora, Income Tax, Central Circle-01, M-3, Flat No.103, Avg Bhawan E-2, Jhandewalan Extn. Vs The Variety Books Depot. New Delhi-110055 Connaught Place, New Delhi-110001 Pan-Accpa9774F Assessee Revenue Cross Objection No.42/Del/2025 (Arising Out Of Ita No.5031/Del/2024) [Assessment Year: 2015-16] Om Prakash Arora, Assistant Commissioner Of Income M-3, Flat No.103, Avg Tax, Central Circle-01, Bhawan The Variety Books Vs E-2, Jhandewalan Extn. Depot. Connaught Place, New Delhi-110055 New Delhi-110001 Pan-Accpa9774F Assessee Revenue [Assessment Year: 2016-17] Assistant Commissioner Of Om Prakash Arora, Income Tax, Central Circle-01, M-3, Flat No.103, Avg Bhawan E-2, Jhandewalan Extn. Vs The Variety Books Depot. New Delhi-110055 Connaught Place, New Delhi-110001 Pan-Accpa9774F Assessee Revenue

deemed dividend under section 2(22)(e) of the Act had escaped assessment. In response to the said notice, the Appellant filed return of income on 20.02.2019. The Appellant also requested for supply of reasons recorded before issue of notice under section 148 of the Act for reopening the assessment. The certifiedof the reasons recorded was supplied to the Appellant

M/S ATMA RAM PROPERTIES PRIVATE LIMITED

deemed dividend under Section 2(22)(e) of the Act. This amount reflected the advance given by a group company, i.e. Atma Ram Builders Pvt. Ltd., to the appellant-assessee. On appeal, the Commissioner of Income Tax (Appeals), [CIT (Appeals), for short], rejected the argument of the appellant that the aforesaid amount of Rs.1,56,51,530/- reflected only

COMMISSIONER OF INCOME TAX vs. LATE SHRI C.R. DASS

Appeal is dismissed on the aforesaid ground

deemed dividend would not arise. It was argued by the assessee that Section 2(22)(e) created a legal fiction and such a provision has to be strictly 2011:DHC:1620-DB ITA No. 610/2009 Page 6 of 9 construed. The CIT(A) accepted this plea of the assessee as well. It was now the turn of the Revenue

SH. VIPIN SHARMA,NEW DELHI vs. ACIT, FARIDABAD

In the result, the assessee’s appeal stands allowed

Bench: SHRI SHAMIM YAHYA (Accountant Member), SHRI YOGESH KUMAR US (Judicial Member)

reassessment under section 147 of the Act and AO without disposing of the objections filed by the assessee, passed the assessment order u/s. 147 of the Act dated 4 ITA No.7027 /Del./2014 30.9.2013 thereby making an addition of Rs. 18 lacs on account of deemed dividend