DEPUTY COMMISSIONER , DELHI vs. RAVINDRA SINGH, GREATER NOIDA

In the result, the Appeals of the Revenue in I

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 2456/Del/2023 (A.Y 2011-12) I.T.A. No. 2457/Del/2023 (A.Y 2012-13) I.T.A. No. 2458/Del/2023 (A.Y 2013-14) I.T.A. No. 2459/Del/2023 (A.Y 2014-15)

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. thereby, in respect of DCIT Vs. Ravindra Singh completed/unabated assessments, no addition can be made by the AD in absence of Meaning any incriminating material found during the course of search under Section 132 or requisition under Section 132A of the Act, 1961. However, the completed/unabated assessments

RAKESH KUMAR GUPTA,DELHI vs. LD. ITO, WARD 35(1), DELHI, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2021-22] Rakesh Kumar Gupta, Income Tax Officer, Ward-35(1), B-2/38, Ground Floor, E-2, Civic Centre, Delhi-110002 Ashok Vihar, Phase-Ii, Vs Delhi-110052 Pan-Aafhr8657H Appellant Respondent

reassessment, referred to in clause (a) of subsection (1), in a case where an order under sub- section (4) has been made accepting the application." 22. As is evident from a reading of Section 270A(1), a person would be liable to be considered to have under reported its income if the contingencies spoken of in clauses

CHANDRA VIDYA INVESTMENT & FINANCE PVT. LTD.,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -28, DELHI, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

CHANDRA VIDYA INVESTMENT & FINANCE PVT. LTD.,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -28, DELHI, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

CHANDRA VIDYA INVESTMENT & FINANCE PVT. LTD.,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -28, DELHI, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

SAKSHI AGARWAL,NEW DELHI vs. DCIT CENTRAL CIRCLE-28, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

ALANKIT FOREX INDIA LIMITED,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

ALANKIT FOREX INDIA LIMITED,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

ALKA AGARWAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

ALANKIT FOREX INDIA LIMITED,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

SAKSHI AGARWAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

ALANKIT FOREX INDIA LIMITED,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28 , NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

SAKSHI AGARWAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE- 28, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

SAKSHI AGARWAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

SAKSHI AGARWAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28, DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

SAKSHI AGARWAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

ALKA AGARWAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

SAKSHI AGARWAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain