SUNITA BHARDWAJ,NEW DELHI vs. ITO WARD 61(1), NEW DELHI

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2012-13] Sunita Bhardwaj, Vs Acit, 1/2, Taj Apartments, Circle-63(1), R.K.Puram, Sector-12, Delhi Delhi-110022. Pan-Ahfpb1928E Appellant Respondent

section 1 28.12.2019 CIT(A), NFAC, 144 r.w.s. 147 of the [Assessment Year 2012-13] Delhi order dated Income Tax Act, 30.01.2024 1961. 2. 30.03.2022 CIT(A), NFAC, 147 r.w.s. 144B of [Assessment Year 2013-14] Delhi order dated the Income Tax Act, 30.01.2024 1961. 3. 30.03.2022 CIT(A), NFAC, 147 r.w.s. 144B of [Assessment Year 2014-15] Delhi order

SUNITA BHARDWAJ,NEW DELHI vs. ITO WARD 61(1), NEW DELHI

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2012-13] Sunita Bhardwaj, Vs Acit, 1/2, Taj Apartments, Circle-63(1), R.K.Puram, Sector-12, Delhi Delhi-110022. Pan-Ahfpb1928E Appellant Respondent

section 1 28.12.2019 CIT(A), NFAC, 144 r.w.s. 147 of the [Assessment Year 2012-13] Delhi order dated Income Tax Act, 30.01.2024 1961. 2. 30.03.2022 CIT(A), NFAC, 147 r.w.s. 144B of [Assessment Year 2013-14] Delhi order dated the Income Tax Act, 30.01.2024 1961. 3. 30.03.2022 CIT(A), NFAC, 147 r.w.s. 144B of [Assessment Year 2014-15] Delhi order

SUMAN KISHORE,NEW DELHI vs. ITO, NEW DELHI

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2012-13] Sunita Bhardwaj, Vs Acit, 1/2, Taj Apartments, Circle-63(1), R.K.Puram, Sector-12, Delhi Delhi-110022. Pan-Ahfpb1928E Appellant Respondent

section 1 28.12.2019 CIT(A), NFAC, 144 r.w.s. 147 of the [Assessment Year 2012-13] Delhi order dated Income Tax Act, 30.01.2024 1961. 2. 30.03.2022 CIT(A), NFAC, 147 r.w.s. 144B of [Assessment Year 2013-14] Delhi order dated the Income Tax Act, 30.01.2024 1961. 3. 30.03.2022 CIT(A), NFAC, 147 r.w.s. 144B of [Assessment Year 2014-15] Delhi order

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, NEW DELHI

reassessment cases\ncarrying serious civil consequences are framed only after due, conscious, and\nindependent application of mind by the approving authority.\nFacts Demonstrating Mechanical Approval\n4. In the present case, the approval under Section 148B of the Act was granted in a\nroutine, perfunctory, and mechanical manner, as is evident from the following\nundisputed chronology:\nFor

SUNITA BHARDWAJ,NEW DELHI vs. ITO WARD 61(1), NEW DELHI

section\n1 | ITA No.1435/Del/2024\n[Assessment Year 2012-13]\nCIT(A), NFAC,\nDelhi order dated\n30.01.2024\n28.12.2019\n144 r.w.s.147 of the\nIncome Tax Act,\n1961.\n2. | ITA No.1434/Del/2024\n[Assessment Year 2013-14]\nCIT(A), NFAC,\nDelhi order dated\n30.01.2024\n30.03.2022\n147 r.w.s.144B of\nthe Income Tax Act,\n1961.\n3. | ITA No.1433/Del/2024\n[Assessment Year 2014-15]\nCIT(A), NFAC

THE COMMISSIONER OF INCOME TAX – VI vs. THREE DEE EXIM PVT. LTD.

91,550/-, which was assessed under Section 143 of the Income Tax Act (for short “the Act”). Thereafter information was received from DIT (Inv) that the assessee had received accommodation entries from M/s.Parivartan Financial Services Pvt. Ltd. and Victoria Advertising Pvt. Ltd. On this information, a notice dated 27.03.2006 under Section 148 of the Act was issued by the Assessing

THE COMMISSIONER OF INCOME TAX – VI vs. THREE DEE EXIM PVT. LTD.

91,550/-, which was assessed under Section 143 of the Income Tax Act (for short “the Act”). Thereafter information was received from DIT (Inv) that the assessee had received accommodation entries from M/s.Parivartan Financial Services Pvt. Ltd. and Victoria Advertising Pvt. Ltd. On this information, a notice dated 27.03.2006 under Section 148 of the Act was issued by the Assessing

SAGE INTERNATIONAL INC.,USA vs. ACIT, CIRCLE INT. TAXATION 3(1)(2), DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri G.S.Pannu & Shri Kul Bharat[Assessment Year : 2018-19] Sage International Inc., Vs Acit, 105, Townline Road, 2 Pmb 332, Circle 3(1)(2), Vernon Hills, Foreign United International States, Usa. Taxation, Delhi. Pan-Aaycs9212R Appellant Respondent Appellant By Shri Pradeep Dinodia, Ca Respondent By Shri Bhuvnesh Kulshrestha, Cit Dr Date Of Hearing 28.02.2023 Date Of Pronouncement 10.04.2023 Order Per Kul Bharat: The Present Appeal Filed By The Assessee Is Directed Against The Order Of Assessing Officer Passed U/S 143(3) R.W.S 144C(13) Of The Income Tax Act, 1961 (“The Act”) Dated 15.07.2022 For The Assessment Year (“Ay”) 2018-19 .

section 91 applies to the cases where there is no agreement 'exist between the countries. When the POEM rule provides the benefit of FTC with the countries with no agreement, it cannot provide for the denial of FTC credit for the countries with which there exists an agreement. This is not the intention of law it is respectfully submitted. However

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, 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

91,433/- as against the income assessed at Rs. 88,63,835/- after appeal effect\nand thus offered additional income of INR 36,27,600/ on account of service charges\nearned from various clients for facilitating, supervising and overseeing the work\noutsourced by them to outside vendors/contractors which was inadvertently missed\nwhile filing original return of income and due taxes

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

PUSHPA DEVI BAJAJ,DELHI vs. DCIT, CC-32 , DELHI

In the result the appeal of the assessee in ITA No

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

91,640/-. As per provisions of section 143(2) of the Act, notice should have been served on or before 30.09.2014 to take return for scrutiny assessment. Since notice period is barred by limitation and since no notice was served upon the assessee it can be safely concluded that the returned income has been accepted and the assessment is concluded

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

reassess the total income of such other person, (the assessee in this case)in the manner provided in section 153A of the Act. So in this case before us, since the AO of the searched person as well as that of the other/third party/assessee foundation are the same, he/AO of assessee can issue notice u/s 153C of the Act only

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

reassess the total income of such other person, (the assessee in this case)in the manner provided in section 153A of the Act. So in this case before us, since the AO of the searched person as well as that of the other/third party/assessee foundation are the same, he/AO of assessee can issue notice u/s 153C of the Act only

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

reassess the total income of such other person, (the assessee in this case)in the manner provided in section 153A of the Act. So in this case before us, since the AO of the searched person as well as that of the other/third party/assessee foundation are the same, he/AO of assessee can issue notice u/s 153C of the Act only

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

reassess the total income of such other person, (the assessee in this case)in the manner provided in section 153A of the Act. So in this case before us, since the AO of the searched person as well as that of the other/third party/assessee foundation are the same, he/AO of assessee can issue notice u/s 153C of the Act only