K K SPUN INDIA LIMITED,DELHI vs. DCIT, JHANDEWALAN DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

section 148 notices issued on 21st & 20th July, 2022, case-wise respectively. This is for the precise reason that the department already appears to have conceded the very issue of limitation aspect in Union of India Vs Rajiv Bansal (2024) 469 ITR 46 (SC) that the provision of Taxation and Other Laws [Relaxation and Amendment of Certain Provisions

K K SPUN INDIA LIMITED,DELHI vs. DCIT CENTRAL CIRCLE-2 NEW DELHI, JHANDEWALAN DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

section 148 notices issued on 21st & 20th July, 2022, case-wise respectively. This is for the precise reason that the department already appears to have conceded the very issue of limitation aspect in Union of India Vs Rajiv Bansal (2024) 469 ITR 46 (SC) that the provision of Taxation and Other Laws [Relaxation and Amendment of Certain Provisions

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 the income of the other person in accordance with the person for the relevant assessment year or years referred to in sub- section (1) of section 153A. This amendment will take effect from 1st October, 2014." 43. It was consequent to the passing of the aforesaid Act that Section 153C came to incorporate provisions relating to the AO being

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 the income of the other person in accordance with the person for the relevant assessment year or years referred to in sub- section (1) of section 153A. This amendment will take effect from 1st October, 2014." 43. It was consequent to the passing of the aforesaid Act that Section 153C came to incorporate provisions relating to the AO being

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 the income of the other person in accordance with the person for the relevant assessment year or years referred to in sub- section (1) of section 153A. This amendment will take effect from 1st October, 2014." 43. It was consequent to the passing of the aforesaid Act that Section 153C came to incorporate provisions relating to the AO being

ALANKIT FINSEC LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

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

Section 153A. The fact that any additions that may be ultimately made upon a culmination of assessment under Section 153A being indelibly founded on the material gathered in the course of the search is a separate issue all together. 44. The usage of the expression "have a bearing" would necessarily lead one to conclude that the mere discovery of books

PRATISHTHA IMAGES PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

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

Section 153A. The fact that any additions that may be ultimately made upon a culmination of assessment under Section 153A being indelibly founded on the material gathered in the course of the search is a separate issue all together. 44. The usage of the expression "have a bearing" would necessarily lead one to conclude that the mere discovery of books

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

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

Section 153A. The fact that any additions that may be ultimately made upon a culmination of assessment under Section 153A being indelibly founded on the material gathered in the course of the search is a separate issue all together. 44. The usage of the expression "have a bearing" would necessarily lead one to conclude that the mere discovery of books

PRATISHTHA IMAGES PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

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

Section 153A. The fact that any additions that may be ultimately made upon a culmination of assessment under Section 153A being indelibly founded on the material gathered in the course of the search is a separate issue all together. 44. The usage of the expression "have a bearing" would necessarily lead one to conclude that the mere discovery of books

ALANKIT FINSEC LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

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

Section 153A. The fact that any additions that may be ultimately made upon a culmination of assessment under Section 153A being indelibly founded on the material gathered in the course of the search is a separate issue all together. 44. The usage of the expression "have a bearing" would necessarily lead one to conclude that the mere discovery of books

ALANKIT FINSEC LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

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

Section 153A. The fact that any additions that may be ultimately made upon a culmination of assessment under Section 153A being indelibly founded on the material gathered in the course of the search is a separate issue all together. 44. The usage of the expression "have a bearing" would necessarily lead one to conclude that the mere discovery of books

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

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

Section 153A. The fact that any additions that may be ultimately made upon a culmination of assessment under Section 153A being indelibly founded on the material gathered in the course of the search is a separate issue all together. 44. The usage of the expression "have a bearing" would necessarily lead one to conclude that the mere discovery of books

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

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

Section 153A. The fact that any additions that may be ultimately made upon a culmination of assessment under Section 153A being indelibly founded on the material gathered in the course of the search is a separate issue all together. 44. The usage of the expression "have a bearing" would necessarily lead one to conclude that the mere discovery of books

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

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

Section 153A. The fact that any additions that may be ultimately made upon a culmination of assessment under Section 153A being indelibly founded on the material gathered in the course of the search is a separate issue all together. 44. The usage of the expression "have a bearing" would necessarily lead one to conclude that the mere discovery of books

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

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

Section 153A. The fact that any additions that may be ultimately made upon a culmination of assessment under Section 153A being indelibly founded on the material gathered in the course of the search is a separate issue all together. 44. The usage of the expression "have a bearing" would necessarily lead one to conclude that the mere discovery of books

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

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

Section 153A. The fact that any additions that may be ultimately made upon a culmination of assessment under Section 153A being indelibly founded on the material gathered in the course of the search is a separate issue all together. 44. The usage of the expression "have a bearing" would necessarily lead one to conclude that the mere discovery of books

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

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

Section 153A. The fact that any additions that may be ultimately made upon a culmination of assessment under Section 153A being indelibly founded on the material gathered in the course of the search is a separate issue all together. 44. The usage of the expression "have a bearing" would necessarily lead one to conclude that the mere discovery of books

ALANKIT FINSEC LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

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

Section 153A. The fact that any additions that may be ultimately made upon a culmination of assessment under Section 153A being indelibly founded on the material gathered in the course of the search is a separate issue all together. 44. The usage of the expression "have a bearing" would necessarily lead one to conclude that the mere discovery of books