COMMISSIONER OF WEALTH TAX vs. S.S. AHLUWALIA

37 (Calcutta), a single Judge of the said High Court struck down the notice issued by the Revenue authority at Delhi as there was no transfer under Section 127 of the Act. The petitioner was all along assessed at Kolkata. In the present case, we have noticed that the respondent was assessed in Delhi and also had properties in Delhi

EBRO INDIA PVT.LTD. ,DELHI vs. ACIT CIRCLE-7(1), DELHI

In the result, the ground no 4 raised by the assessee is allowed

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

section 1448 of IT Act, the case was duly transferred to the jurisdiction AO, who has no previous idea about the assessment proceedings in the case. However it is pointed out, that, even during the DRP stage and even after providing opportunity by AO, the assessee could not submit any evidence with respect to bank statement of assessee and also

DHARAMVIR KHOSLA ,. vs. DCIT CC-5, NEW DELHI , .

The appeals are allowed for statistical purposes and ld

37,186/-.\nThus, here again AO did not apply his own mind and simply followed\nintimation u/s 143(1) of the Act and Rs.8,35,000/- was shortly allowed. The\nreason given in the intimation at Page 22 by referring to 3 TAN Numbers as\nalso mentioned at page No. S of the paper-book i.e. computation of Income\nwhere

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. CCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

DCIT-CENTRAL CIRCLE-2, FARIDABAD vs. A2Z INFRA ENGINEERS LTD., GURGAON

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

A2Z MAINTENANCE & ENGINEERING SERVICES LTD.,GURGAON vs. DCIT, CENTRAL CIRCLE-II, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

DCIT CC-2 , FARIDABAD vs. A2Z MAINTENANCE AND ENGINEERING SERVICES LTD., GURGAON

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT CC-2 , FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

INFRA ENGINEERS LTD.,GURGAON vs. DCIT, CC-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

reassessment proceedings.\n8. In light of the above, it is respectfully submitted that the consolidated approval\ngranted by the Additional Commissioner of Income Tax for AYs 2012-13 to 2020-\n21 and AY 2023-24 is illegal, invalid, and bad in law.\nJudicial Precedents against Consolidated/Mechanical Approval under Section\n153D of the Act.\n9\nIn this regard, reliance is placed

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, DELHI

In the result, all the appeals for

reassessment proceedings.\n8. In light of the above, it is respectfully submitted that the consolidated approval\ngranted by the Additional Commissioner of Income Tax for AYs 2012-13 to 2020-\n21 and AY 2023-24 is illegal, invalid, and bad in law.\nJudicial Precedents against Consolidated/Mechanical Approval under Section\n153D of the Act.\n9. In this regard, reliance is placed

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

In the result, all the appeals for

reassessment proceedings.\n8. In light of the above, it is respectfully submitted that the consolidated approval\ngranted by the Additional Commissioner of Income Tax for AYs 2012-13 to 2020-\n21 and AY 2023-24 is illegal, invalid, and bad in law.\nJudicial Precedents against Consolidated/Mechanical Approval under Section\n153D of the Act.\n9. In this regard, reliance is placed

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

reassessment proceedings.\n8. In light of the above, it is respectfully submitted that the consolidated approval\ngranted by the Additional Commissioner of Income Tax for AYs 2012-13 to 2020-\n21 and AY 2023-24 is illegal, invalid, and bad in law.\nJudicial Precedents against Consolidated/Mechanical Approval under Section\n153D of the Act.\n9. In this regard, reliance is placed

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

In the result, all the appeals for

reassessment proceedings.\n8.\nIn light of the above, it is respectfully submitted that the consolidated approval\ngranted by the Additional Commissioner of Income Tax for AYs 2012-13 to 2020-\n21 and AY 2023-24 is illegal, invalid, and bad in law.\nJudicial Precedents against Consolidated/Mechanical Approval under Section\n153D of the Act.\n9\nIn this regard, reliance is placed

KULDIP KUMAR GOEL,DELHI vs. ACIT(1)(1), DELHI

In the result, the appeal of the assessee is partly allowed in above\nterms for statistical purposes

reassessment proceedings\nunder section 147 of the ITA. I therefore hold that the action of Ld. JAO\nforming belief for reopening was based on correct understanding of law\nand all ingredients were present for such action. Thus, ground of appeal\nis dismissed.\nGround of Appeal Eightis regarding jurisdictional objections not\nbeing addressed by the AO\nThe jurisdiction

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