DCIT, CENTRAL CIRCLE-II, GURGAON vs. SUDHIR DHINGRA, NEW DELHI

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

2(22)(e) made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A of the Income

DCIT, CENTRAL CIRCLE-II, GURGAON vs. SUDHIR DHINGRA, NEW DELHI

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

2(22)(e) made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A of the Income

ANOOP THATAI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-II, GURGAON

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

2(22)(e) made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A of the Income

DCIT, CENTRAL CIRCLE-II, GURGAON vs. SUDHIR DHINGRA, NEW DELHI

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

2(22)(e) made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A of the Income

ACIT, CENTRAL CIRCLE-II, GURGAON vs. ANOOP THATAI, NEW DELHI

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

2(22)(e) made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A of the Income

DCIT, CENTRAL CIRCLE-II, GURGAON vs. SUDHIR DHINGRA, NEW DELHI

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

2(22)(e) made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A of the Income

DCIT, CENTRAL CIRCLE-II, GURGAON vs. SUDHIR DHINGRA, NEW DELHI

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

2(22)(e) made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A of the Income

SUDHIR DHINGRA,NEW DELHI vs. DCIT, CENTRAL CIRCLE-II, GURGAON

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

2(22)(e) made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A of the Income

DCIT, CENTRAL CIRCLE-II, GURGAON vs. SUDHIR DHINGRA, NEW DELHI

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

2(22)(e) made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A of the Income

COMMISSIONER OF INCOME TAX vs. PAWAN GUPTA

The appeals are dismissed

reassessment, would have to be followed and the same would include the time limit prescribed for a notice under section 16 (2). The Court observed that once the language of section 17 itself required that other provisions, to the extent applicable, would apply considering the return is filed under section 14, it contemplated that both procedural and substantive provisions would

COMMISSIONER OF INCOME TAX vs. PAWAN GUPTA

The appeals are dismissed

reassessment, would have to be followed and the same would include the time limit prescribed for a notice under section 16 (2). The Court observed that once the language of section 17 itself required that other provisions, to the extent applicable, would apply considering the return is filed under section 14, it contemplated that both procedural and substantive provisions would

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

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

section 2(6A) of the Indian Income-tax Act, 1922, plainly seeks to bring within the tax net accumulated profit which are distributed by closely held companies to its shareholders in the form of loans. The purpose being that persons, who manage such closely held companies, should not arrange their affairs in a manner that they assist the shareholders

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

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

section 2(6A) of the Indian Income-tax Act, 1922, plainly seeks to bring within the tax net accumulated profit which are distributed by closely held companies to its shareholders in the form of loans. The purpose being that persons, who manage such closely held companies, should not arrange their affairs in a manner that they assist the shareholders

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

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

section 2(6A) of the Indian Income-tax Act, 1922, plainly seeks to bring within the tax net accumulated profit which are distributed by closely held companies to its shareholders in the form of loans. The purpose being that persons, who manage such closely held companies, should not arrange their affairs in a manner that they assist the shareholders

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

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

section 2(6A) of the Indian Income-tax Act, 1922, plainly seeks to bring within the tax net accumulated profit which are distributed by closely held companies to its shareholders in the form of loans. The purpose being that persons, who manage such closely held companies, should not arrange their affairs in a manner that they assist the shareholders

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

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

section 2(6A) of the Indian Income-tax Act, 1922, plainly seeks to bring within the tax net accumulated profit which are distributed by closely held companies to its shareholders in the form of loans. The purpose being that persons, who manage such closely held companies, should not arrange their affairs in a manner that they assist the shareholders

SHRI ANIL NANDA,NEW DELHI vs. DCIT, NEW DELHI

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

Bench: Shri R.K. Panda & Shri Kuldip Singhassessment Year: 2007-08 Anil Nanda, Vs Dcit, 12-C, Friends Colony, Circle-68(1), New Delhi. New Delhi. Pan Aafpn4381A (Appellant) (Respondent) Assessee By : Shri Deepak Ostwal, Ca Revenue By : Shri Satpal Gulati, Cit, Dr Date Of Hearing : 02.06.2021 Date Of Pronouncement : 18.08.2021 Order Per R.K. Panda, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 31St March, 2017 Of The Cit(A)-32, New Delhi Relating To Assessment Year 2007-08. 2. Facts Of The Case, In Brief, Are That The Assessee Is An Individual & It Filed Its Return Of Income On 30Th July, 2007 Declaring Total Income At Rs.8,25,64,675/-. The Assessment Was Completed U/S 143(3) Of The Act On 30Th October, 2009 Accepting The Returned Income. Subsequently, The Ao Reopened The Assessment U/S 147 Of The It Act, 1961 After Recording The Following Reasons:-

section 2(22)(e) was attracted. g) The satisfaction of the AO is not his satisfaction, but, borrowed satisfaction. h) Further, it is a case of reason to suspect and not reason to believe. 5. However, the AO rejected all the objections raised by the assessee challenging the validity of the reassessment

RAJAN GUPTA vs. COMMISSIONER OF INCOME TAX

The appeal is allowed as aforesaid

reassessment, which may be pending before an income-tax authority on the date on which an application under sub-section (1) of section 245C is made. xxxxx xxxxx xxxxx xxxxx‖ 11. Section 245C provides that an assessee may, at any stage of a ―case‖ relating to him, make an application in such form and in such manner