DR SHRIDHAR RA vs. AHEB LIMBIKAI DCIT CC-17, DELHIVS.M/S AKG CONSULTANT PVT. LTD., LUCKNOW

Bench: Sh. Satbeer Singh Godara & Sh. Amitabh Shukla

reassess the total income in respect of each assessment year falling within such six assessment years. Further, Explanation-1 to section 153A(1) with effect from 01.04.2017 states as under: "Explanation 1. —For the purposes of this sub-section, the expression "relevant assessment yeah' shall mean an assessment year preceding the assessment year relevant to the previous year in which

DR. SHRIDHAR RA vs. AHEB LIMBIKAI DCIT CENTRAL CIRCLE 17 , DELHIVS.MS. NAMITA GUPTA, LUCKNOW

Bench: Sh. Satbeer Singh Godara & Sh. Amitabh Shukla

reassess the total income in respect of each assessment year falling within such six assessment years. Further, Explanation-1 to section 153A(1) with effect from 01.04.2017 states as under: "Explanation 1. —For the purposes of this sub-section, the expression "relevant assessment yeah' shall mean an assessment year preceding the assessment year relevant to the previous year in which

DR. SHIRDHAR RA vs. AHEB LIMBIKAI DCIT CENTRAL CIRCLE 17 , DELHIVS.M/S AKG CONSULTANT PVT. LTD., LUCKNOW

reassess the total income of six\n assessment years immediately preceding the\n assessment year relevant to the previous year\nin which such search is conducted or requisition\nis made:\nor\nProvided that the Assessing Officer shall assess or\nreassess the total income in respect of each assessment\nyear falling within such six assessment years.\nFurther, Explanation-1 to section

DR. SHRIDHAR RA vs. AHEB LIMBIKAI DCIT CENTRAL CIRCLE 17, DELHIVS.MS. NAMITA GUPTA, LUCKNOW

reassess the total income of six\n assessment years immediately preceding the\n assessment year relevant to the previous year\nin which such search is conducted or requisition\nis made:\nor\nProvided that the Assessing Officer shall assess or\nreassess the total income in respect of each assessment\nyear falling within such six assessment years.\nFurther, Explanation-1 to section

DR. SHRIDHAR RA vs. AHEB LIMBIKAI DCIT CENTRAL CIRCLE-17 DELHI, DELHIVS.M/S AKG CONSULTANT PVT. LTD., LUCKNOW

reassess the total income of six\n assessment years immediately preceding the\n assessment year relevant to the previous year\nin which such search is conducted or requisition\nis made:\nor\nProvided that the Assessing Officer shall assess or\nreassess the total income in respect of each assessment\nyear falling within such six assessment years.\nFurther, Explanation-1 to section

DR. SHRIDHAR RA vs. AHEB LIMBIKAI DCIT CENTRAL CIRCLE 17 , DELHIVS.ASHWANI KUMAR GUPTA (HUF), KANPUR

reassess the total income of six\n assessment years immediately preceding the\n assessment year relevant to the previous year\nin which such search is conducted or requisition\nis made:\nor\nProvided that the Assessing Officer shall assess or\nreassess the total income in respect of each assessment\nyear falling within such six assessment years.\nFurther, Explanation-1 to section

M/S JINDAL PHOTO LTD.,,NEW DELHI vs. ACIT, NEW DELHI

In the result, all the appeals of the assessee in ITA No

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

reassess the total income of those assessment years on the basis of incriminating material found as a result of the search and any other material or information provided in the returns. Page 43 of 63 ITA No. 5251 to 5257/DEL/2015 [A.Y 2006-07 to A.Y 2012-13] ITA No. 5451/DEL/2016 [A.Y 2013-14]; ITA No. 4492/DEL/2017

M/S. JINDAL PHOTO LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, all the appeals of the assessee in ITA No

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

reassess the total income of those assessment years on the basis of incriminating material found as a result of the search and any other material or information provided in the returns. Page 43 of 63 ITA No. 5251 to 5257/DEL/2015 [A.Y 2006-07 to A.Y 2012-13] ITA No. 5451/DEL/2016 [A.Y 2013-14]; ITA No. 4492/DEL/2017

M/S. JINDAL PHOTO LTD.,NEW DELHI vs. ACIT, NEW DELHI

reassess the total income of\nthose assessment years on the basis of incriminating material found as a\nresult of the search and any other material or information provided in\nthe returns.\n57. The Special Bench, Hyd emphasized that the assessee has to\nprovide information in the Return for consideration. In the instant\ncase, the exemption of sales tax subsidy

M/S. JINDAL PHOTO LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, all the appeals of the assessee in ITA No

reassess the total income of\nthose assessment years on the basis of incriminating material found as a\nresult of the search and any other material or information provided in\nthe returns.\n\n57. The Special Bench, Hyd emphasized that the assessee has to\nprovide information in the Return for consideration. In the instant\ncase, the exemption of sales tax subsidy

M/S. JINDAL PHOTO LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, all the appeals of the assessee in ITA No

reassess the total income of\nthose assessment years on the basis of incriminating material found as a\nresult of the search and any other material or information provided in\nthe returns.\n\n57. The Special Bench, Hyd emphasized that the assessee has to\nprovide information in the Return for consideration. In the instant\ncase, the exemption of sales tax subsidy

M/S. JINDAL PHOTO LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, all the appeals of the assessee in ITA No

reassess the total income of\nthose assessment years on the basis of incriminating material found as a\nresult of the search and any other material or information provided in\nthe returns.\n\n57. The Special Bench, Hyd emphasized that the assessee has to\nprovide information in the Return for consideration. In the instant\ncase, the exemption of sales tax subsidy

M/S. JINDAL PHOTO LTD.,NEW DELHI vs. ACIT, NEW DELHI

reassess the total income of\nthose assessment years on the basis of incriminating material found as a\nresult of the search and any other material or information provided in\nthe returns.\n\n57. The Special Bench, Hyd emphasized that the assessee has to\nprovide information in the Return for consideration. In the instant\ncase, the exemption of sales tax subsidy

M/S. JINDAL PHOTO LTD.,NEW DELHI vs. ACIT, NEW DELHI

reassess the total income of\nthose assessment years on the basis of incriminating material found as a\nresult of the search and any other material or information provided in\nthe returns.\n\n57. The Special Bench, Hyd emphasized that the assessee has to\nprovide information in the Return for consideration. In the instant\ncase, the exemption of sales tax subsidy

JINDAL PHOTO LTD.,NEW DELHI vs. ACIT, CC- 30, NEW DELHI

reassess the total income of\nthose assessment years on the basis of incriminating material found as a\nresult of the search and any other material or information provided in\nthe returns.\n\n57. The Special Bench, Hyd emphasized that the assessee has to\nprovide information in the Return for consideration. In the instant\ncase, the exemption of sales tax subsidy

DCIT- CC-31, NEW DELHI vs. REALTIME MARKETING PVT. LTD., DELHI

Bench: Dr. B. R. R. Kumar, Sh. Yogesh Kumar Us

158B(b), it is at once clear that a statement recorded under section 132(4) can be used in evidence for making a block assessment only if the said statement is made in the context of other evidence or material discovered during the search. A statement of a person, which is not relatable to any incriminating document or material found

DCIT, CC-31, NEW DELHI vs. ENN VEE HOLDINGS PVT. LTD., NEW DELHI

Bench: Dr. B. R. R. Kumar, Sh. Yogesh Kumar Us

158B(b), it is at once clear that a statement recorded under section 132(4) can be used in evidence for making a block assessment only if the said statement is made in the context of other evidence or material discovered during the search. A statement of a person, which is not relatable to any incriminating document or material found

DCIT, CC-31, NEW DELHI vs. ENN VEE HOLDINGS PVT. LTD., NEW DELHI

Bench: Dr. B. R. R. Kumar, Sh. Yogesh Kumar Us

158B(b), it is at once clear that a statement recorded under section 132(4) can be used in evidence for making a block assessment only if the said statement is made in the context of other evidence or material discovered during the search. A statement of a person, which is not relatable to any incriminating document or material found