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1,161 results for “reassessment u/s 147”+ Section 45(3)clear

Sorted by relevance

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Key Topics

Section 147155Section 148108Section 143(3)76Addition to Income58Section 153A46Reassessment43Section 6840Section 153C39Search & Seizure

MAHESH KUMAR,DELHI vs. ITO,WARD-68(6), DELHI

In the result, Ground no. 3 as raised by the assessee deserves to be allowed and the impugned addition cannot be sustained

ITA 2650/DEL/2024[2012-13]Status: DisposedITAT Delhi06 Aug 2025AY 2012-13

Bench: Justice (Retd.) C.V. Bhadang(), Shri Mahavir Singh & Shri Brajesh Kumar Singh[Assessment Year: 2012-13] Mahesh Kumar, Vs Ito, 6/305/1A, Doonger Ward-68(6), Mohalla, Delhi-110032. Delhi. Pan-Aoopk6335A Appellant Respondent Appellant By Shri Neeraj Mangla, Ca Respondent By Shri Krishna K. Ramawat, Sr. Dr Date Of Hearing 06.08.2025 Date Of Pronouncement 06.08.2025

Section 10(38)Section 143(3)Section 147Section 148Section 68

reassessment proceedings is not acceptable because no such proposition was laid down in the decisions of Hon'ble Bombay High Court in the case of CIT vs Jet Airways (I) Ltd. (supra) and of Hon'ble Delhi High Court in the case of Ranbaxy Laboratories Ltd. vs CIT (supra).” 16. In my considered view, once the learned Accountant Member

Showing 1–20 of 1,161 · Page 1 of 59

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30
Reopening of Assessment29
Section 13225
Section 143(2)22

INCOME TAX OFFICER, WARD 3(1), DELHI, DELHI vs. ARTISTIC FINANCE PRIVATE LIMITED, DELHI

In the result, Ground no. 3 as raised by the assessee deserves to be allowed and the impugned addition cannot be sustained

ITA 2650/DEL/2023[2014-15]Status: DisposedITAT Delhi08 May 2025AY 2014-15

Bench: Justice (Retd.) C.V. Bhadang(), Shri Mahavir Singh & Shri Brajesh Kumar Singh[Assessment Year: 2012-13] Mahesh Kumar, Vs Ito, 6/305/1A, Doonger Ward-68(6), Mohalla, Delhi-110032. Delhi. Pan-Aoopk6335A Appellant Respondent Appellant By Shri Neeraj Mangla, Ca Respondent By Shri Krishna K. Ramawat, Sr. Dr Date Of Hearing 06.08.2025 Date Of Pronouncement 06.08.2025

Section 10(38)Section 143(3)Section 147Section 148Section 68

reassessment proceedings is not acceptable because no such proposition was laid down in the decisions of Hon'ble Bombay High Court in the case of CIT vs Jet Airways (I) Ltd. (supra) and of Hon'ble Delhi High Court in the case of Ranbaxy Laboratories Ltd. vs CIT (supra).” 16. In my considered view, once the learned Accountant Member

M/S. DHARAMPAL SATYAPAL LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 5581/DEL/2013[2004-05]Status: DisposedITAT Delhi08 Jan 2016AY 2004-05

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

For Appellant: Shri R.S. Singhvi, CA and Shri Satyajeet Goel, CAFor Respondent: Ms. Nandita Kanchan, CIT DR
Section 115JSection 132Section 143(3)Section 14ASection 264Section 80I

section 147 to 151 are not satisfied. 2. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in reopening the impugned assessment U/S 147, more so when the appellant was searched u/s 132 of Income Tax Act, 1961. 3. That

DCIT, NEW DELHI vs. M/S. DHARAMPAL SATYAPAL LTD., DELHI

In the result, the appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 5611/DEL/2013[2004-05]Status: DisposedITAT Delhi08 Jan 2016AY 2004-05

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

For Appellant: Shri R.S. Singhvi, CA and Shri Satyajeet Goel, CAFor Respondent: Ms. Nandita Kanchan, CIT DR
Section 115JSection 132Section 143(3)Section 14ASection 264Section 80I

section 147 to 151 are not satisfied. 2. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in reopening the impugned assessment U/S 147, more so when the appellant was searched u/s 132 of Income Tax Act, 1961. 3. That

ACIT CIRCLE-59(1), NEW DELHI vs. NEERAJ KUMAR SINGHAL, NEW DELHI

In the result, the appeal of the Revenue is dismissed

ITA 283/DEL/2021[2009-10]Status: DisposedITAT Delhi13 Sept 2023AY 2009-10

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kedia

For Appellant: Shri Shri Amit Goel, CAFor Respondent: Ms. Smita Singh, Sr.DR
Section 139Section 143(3)Section 147Section 148Section 151(1)

45,83,190/- for the Assessment Year 2009-10 in question. The return filed was subjected to scrutiny assessment under Section 143(3) of the Act vide order dated 27.12.2011. Thereafter, notice under Section 148 of the Act dated 31.03.2016 was issued upon the assessee seeking to reopen the completed assessment. The re-assessment order was accordingly finalized after making

DCIT, CC-15, NEW DELHI vs. BDR BUILDERS & DEVELOPERS P. LTD., NEW DELHI

In the result, the appeal of the Revenue is dismissed

ITA 1177/DEL/2021[2012-13]Status: DisposedITAT Delhi16 Mar 2023AY 2012-13

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usasstt. Year: 2012-13 Dcit, Vs. Bdr Builders & Developers P. Ltd,B- Central Circle-15, 393, Zakir Nagar So, South East Delhi, New Delhi New Delhi-1100025 (Appellant) (Respondent) Pan No. Assessee By : Dr. Rakesh Gupta, Adv. Revenue By : Sh. Kanv Bali, Sr. Dr Date Of Hearing: 28.02.2023 Date Of Pronouncement: 16.03.2023

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Sh. Kanv Bali, Sr. DR
Section 139(1)Section 143(3)Section 147Section 148Section 153ASection 68

147 r.w.s 143(3) in Dec., 2019 on the basis of transactions in his bank account, 10.2.5 It appears from the assessment order of Sh. Roop Kishore madan for AY 2012-13 that the information forwarded by the investigation wing had already been taken into consideration in his assessment u/s 143(3) completed on 27.3.2015. There is no finding

BSES YAMUNA POWER LTD,DELHI vs. ACIT, CIRCLE-5(1), NEW DEL;HI

The appeal of the assessee is allowed on legal issues

ITA 4853/DEL/2017[2008-09]Status: DisposedITAT Delhi16 Apr 2025AY 2008-09

Bench: Shri Anubhav Sharma & Shri Manish Agarwalbses Rajdhani Power Ltd., Dy. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd., Asst. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Yamuna Power Dy. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd. & Ors Vs. Acit Bses Yamuna Power Asst. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv., Sh. Deepesh Jain, Adv. & Sh. Shivam Gupta, Ca Department By Mr. Javed Akhtar, Cit-Dr Date Of Hearing 20/02/2025 Date Of Pronouncement 16/04/2025 O R D E R

Section 143(3)Section 147Section 148Section 154Section 250

u/s 148 which are as under: GOA No. 3 to 3.4-Validity of re-assessment proceedings 24. In the present case, reassessment proceedings under section 147/148 of the Act were initiated by the assessing officer vide notice dated 31.03.2014, ie, much beyond the period of 4 years and almost at the fag-end of the overall limitation period

BSES YAMUNA POWER LTD.,NEW DELHI vs. DCIT, CIRCLE- 5(1), NEW DELHI

The appeal of the assessee is allowed on legal issues

ITA 4852/DEL/2017[2007-08]Status: DisposedITAT Delhi16 Apr 2025AY 2007-08

Bench: Shri Anubhav Sharma & Shri Manish Agarwalbses Rajdhani Power Ltd., Dy. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd., Asst. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Yamuna Power Dy. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd. & Ors Vs. Acit Bses Yamuna Power Asst. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv., Sh. Deepesh Jain, Adv. & Sh. Shivam Gupta, Ca Department By Mr. Javed Akhtar, Cit-Dr Date Of Hearing 20/02/2025 Date Of Pronouncement 16/04/2025 O R D E R

Section 143(3)Section 147Section 148Section 154Section 250

u/s 148 which are as under: GOA No. 3 to 3.4-Validity of re-assessment proceedings 24. In the present case, reassessment proceedings under section 147/148 of the Act were initiated by the assessing officer vide notice dated 31.03.2014, ie, much beyond the period of 4 years and almost at the fag-end of the overall limitation period

ACIT, CIRCLE-26(2), NEW DELHI vs. VIKRAM ELECTRIC EQUIPMENT P.LTD, NEW DELHI

The appeal of the Revenue is dismissed as\ninfructuous

ITA 4651/DEL/2018[2009-10]Status: DisposedITAT Delhi22 Aug 2025AY 2009-10
Section 143(1)Section 143(3)Section 147Section 148Section 68

3, 1970. To the facts of the\ncase, section 147(b) of the Act applies. The two relevant\nprovisions are in sections 148 and 149 of the Act which\nprovide:\n\n\"148(1)--Before making the assessment, reassessment\norrecomputationunder section 147, the Income-tax Officer\nshall serve on the assessee notice containing all or any of the\nrequirements which

SUNRISE PORPBUILD PVT LTD,DELHI vs. ACIT, CENTRAL CIRCLE-2, FARIDABAD

In the result, Appeals in ITA

ITA 1257/DEL/2025[2011-12]Status: DisposedITAT Delhi26 Nov 2025AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ita No. 1258/Del/2025 (A.Y. 2012-13) M/S Sunrise Propbuild Pvt. Ltd. V Assistant Commissioner Of House No. B-4, 1St Floor, Shop S Income Tax, Central Circle-Ii, No. 25, Ashirward Complex, Faridabad, Village Pitampura, New Delhi- Haryana-121001 110034 Pan: Aapcs2201K Appellant Respondent Assessee By Sh. S. S. Nagar, Ca Revenue By Ms.Suman Malik, Cit Dr Date Of Hearing 08/09/2025 Date Of Pronouncement 26/11/2025

Section 143(2)Section 147Section 148Section 151Section 153C

reassessment Sunrise Propbuild Pvt. Ltd. Vs. ACIT proceedings u/s 147 of the Act was based on borrowed satisfaction and without application of mind. 6.2 That on the facts and in the circumstances of the case, the Ld. CIT-(A) has erred in upholding the order of Ld. A.O without considering the fact that the reasons u/s 148 were recorded merely

SUNRISE PROPBUILD PVT LTD.,DELHI vs. ACIT, CENTRAL CIRCLE-2, FARIDABAD

In the result, Appeals in ITA

ITA 1258/DEL/2025[2012-13]Status: DisposedITAT Delhi26 Nov 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ita No. 1258/Del/2025 (A.Y. 2012-13) M/S Sunrise Propbuild Pvt. Ltd. V Assistant Commissioner Of House No. B-4, 1St Floor, Shop S Income Tax, Central Circle-Ii, No. 25, Ashirward Complex, Faridabad, Village Pitampura, New Delhi- Haryana-121001 110034 Pan: Aapcs2201K Appellant Respondent Assessee By Sh. S. S. Nagar, Ca Revenue By Ms.Suman Malik, Cit Dr Date Of Hearing 08/09/2025 Date Of Pronouncement 26/11/2025

Section 143(2)Section 147Section 148Section 151Section 153C

reassessment Sunrise Propbuild Pvt. Ltd. Vs. ACIT proceedings u/s 147 of the Act was based on borrowed satisfaction and without application of mind. 6.2 That on the facts and in the circumstances of the case, the Ld. CIT-(A) has erred in upholding the order of Ld. A.O without considering the fact that the reasons u/s 148 were recorded merely

SHRI VALMIK THAPAR,NEW DELHI vs. DCIT, NEW DELHI

Appeals are disposed of by this common order as indicated above

ITA 6346/DEL/2014[2010-11]Status: DisposedITAT Delhi11 Jun 2021AY 2010-11

Bench: Hon’Ble Justice P.P. Bhatt & Shri Prashant Maharishi(Through Video Conferencing) Shri Valmik Thapar, Vs. Acit, 19, Kautilya Marg, Circle-53(1), New Delhi New Delhi (Appellant) (Respondent) Shri Valmik Thapar, Vs. Dcit, M/S. R. N. Khanna & Company, Ca, Circle-32(1), 14-15F, Shivam House, Connaught New Delhi Place, New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Acit, Vs. Shri Valmik Thapar, Circle-53(1), 19, Kautilya Marg, New Delhi New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Assessee By : Shri Salil Agarwal, Senior Advocate Along With Shri Shailesh Gupta, Shri Mahur Agarwal, Advocates Revenue By: Shri H. K. Choudhary, Cit Dr Date Of Hearing 11/06/2021 (Last Hearing) Date Of Pronouncement 11/06/2021. O R D E R Per Prashant Maharishi, A. M. 1. These Are Three Appeals For Two Assessment Years Pertaining To One Assessee, Mr. Valmik Thapar, A Resident, Individual [Assessee]. Assessee Filed Ita Number

For Appellant: Shri Salil AgarwalFor Respondent: Shri H. K. Choudhary, CIT DR
Section 143Section 147Section 54Section 54E

45. In the present case, the assessee has filed his return of income for assessment year 2010 – 11 on 26th of July 2010. The notice u/s 148 of the act was issued on 1st March 2012 along with the reasons recorded. In the present case there is no assessment made u/s 143 (3) of the act. Therefore even

ACIT, NEW DELHI vs. SH. VALMIK THAPAR, NEW DELHI

Appeals are disposed of by this common order as indicated above

ITA 6726/DEL/2014[2010-11]Status: DisposedITAT Delhi11 Jun 2021AY 2010-11

Bench: Hon’Ble Justice P.P. Bhatt & Shri Prashant Maharishi(Through Video Conferencing) Shri Valmik Thapar, Vs. Acit, 19, Kautilya Marg, Circle-53(1), New Delhi New Delhi (Appellant) (Respondent) Shri Valmik Thapar, Vs. Dcit, M/S. R. N. Khanna & Company, Ca, Circle-32(1), 14-15F, Shivam House, Connaught New Delhi Place, New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Acit, Vs. Shri Valmik Thapar, Circle-53(1), 19, Kautilya Marg, New Delhi New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Assessee By : Shri Salil Agarwal, Senior Advocate Along With Shri Shailesh Gupta, Shri Mahur Agarwal, Advocates Revenue By: Shri H. K. Choudhary, Cit Dr Date Of Hearing 11/06/2021 (Last Hearing) Date Of Pronouncement 11/06/2021. O R D E R Per Prashant Maharishi, A. M. 1. These Are Three Appeals For Two Assessment Years Pertaining To One Assessee, Mr. Valmik Thapar, A Resident, Individual [Assessee]. Assessee Filed Ita Number

For Appellant: Shri Salil AgarwalFor Respondent: Shri H. K. Choudhary, CIT DR
Section 143Section 147Section 54Section 54E

45. In the present case, the assessee has filed his return of income for assessment year 2010 – 11 on 26th of July 2010. The notice u/s 148 of the act was issued on 1st March 2012 along with the reasons recorded. In the present case there is no assessment made u/s 143 (3) of the act. Therefore even

SH. VALMIK THAPAR,NEW DELHI vs. ACIT, NEW DELHI

Appeals are disposed of by this common order as indicated above

ITA 5767/DEL/2015[2007-08]Status: DisposedITAT Delhi11 Jun 2021AY 2007-08

Bench: Hon’Ble Justice P.P. Bhatt & Shri Prashant Maharishi(Through Video Conferencing) Shri Valmik Thapar, Vs. Acit, 19, Kautilya Marg, Circle-53(1), New Delhi New Delhi (Appellant) (Respondent) Shri Valmik Thapar, Vs. Dcit, M/S. R. N. Khanna & Company, Ca, Circle-32(1), 14-15F, Shivam House, Connaught New Delhi Place, New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Acit, Vs. Shri Valmik Thapar, Circle-53(1), 19, Kautilya Marg, New Delhi New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Assessee By : Shri Salil Agarwal, Senior Advocate Along With Shri Shailesh Gupta, Shri Mahur Agarwal, Advocates Revenue By: Shri H. K. Choudhary, Cit Dr Date Of Hearing 11/06/2021 (Last Hearing) Date Of Pronouncement 11/06/2021. O R D E R Per Prashant Maharishi, A. M. 1. These Are Three Appeals For Two Assessment Years Pertaining To One Assessee, Mr. Valmik Thapar, A Resident, Individual [Assessee]. Assessee Filed Ita Number

For Appellant: Shri Salil AgarwalFor Respondent: Shri H. K. Choudhary, CIT DR
Section 143Section 147Section 54Section 54E

45. In the present case, the assessee has filed his return of income for assessment year 2010 – 11 on 26th of July 2010. The notice u/s 148 of the act was issued on 1st March 2012 along with the reasons recorded. In the present case there is no assessment made u/s 143 (3) of the act. Therefore even

RUBY SINGH,DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

ITA 2875/DEL/2022[2013-14]Status: DisposedITAT Delhi29 Sept 2023AY 2013-14

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

For Appellant: Shri Gautam Jain, Adv. &For Respondent: Shri Vivek Vardhan, Sr. DR
Section 147Section 148Section 151

section 68 of the Act and the Ld. CIT(A) was also correct in upholding the same after detailed logical analysis of documentary evidence, allegations of the AO and explanation of the assessee. Accordingly, we are unable to see any valid reason to interfere the findings affirmed by the Ld. CIT(A) while confirming the addition u/s

RUBY SINGH ,NEW DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

ITA 2876/DEL/2022[2014-15]Status: DisposedITAT Delhi29 Sept 2023AY 2014-15

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

For Appellant: Shri Gautam Jain, Adv. &For Respondent: Shri Vivek Vardhan, Sr. DR
Section 147Section 148Section 151

section 68 of the Act and the Ld. CIT(A) was also correct in upholding the same after detailed logical analysis of documentary evidence, allegations of the AO and explanation of the assessee. Accordingly, we are unable to see any valid reason to interfere the findings affirmed by the Ld. CIT(A) while confirming the addition u/s

RUBY SINGH,NEW DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

ITA 2877/DEL/2022[2015-16]Status: DisposedITAT Delhi29 Sept 2023AY 2015-16

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

For Appellant: Shri Gautam Jain, Adv. &For Respondent: Shri Vivek Vardhan, Sr. DR
Section 147Section 148Section 151

section 68 of the Act and the Ld. CIT(A) was also correct in upholding the same after detailed logical analysis of documentary evidence, allegations of the AO and explanation of the assessee. Accordingly, we are unable to see any valid reason to interfere the findings affirmed by the Ld. CIT(A) while confirming the addition u/s

RUBY SINGH,NEW DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

ITA 2880/DEL/2022[2018-19]Status: DisposedITAT Delhi29 Sept 2023AY 2018-19

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

For Appellant: Shri Gautam Jain, Adv. &For Respondent: Shri Vivek Vardhan, Sr. DR
Section 147Section 148Section 151

section 68 of the Act and the Ld. CIT(A) was also correct in upholding the same after detailed logical analysis of documentary evidence, allegations of the AO and explanation of the assessee. Accordingly, we are unable to see any valid reason to interfere the findings affirmed by the Ld. CIT(A) while confirming the addition u/s

RUBY SINGH ,NEW DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

ITA 2878/DEL/2022[2016-17]Status: DisposedITAT Delhi29 Sept 2023AY 2016-17

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

For Appellant: Shri Gautam Jain, Adv. &For Respondent: Shri Vivek Vardhan, Sr. DR
Section 147Section 148Section 151

section 68 of the Act and the Ld. CIT(A) was also correct in upholding the same after detailed logical analysis of documentary evidence, allegations of the AO and explanation of the assessee. Accordingly, we are unable to see any valid reason to interfere the findings affirmed by the Ld. CIT(A) while confirming the addition u/s

RUBY SINGH,NEW DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

ITA 2879/DEL/2022[2017-18]Status: DisposedITAT Delhi29 Sept 2023AY 2017-18

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

For Appellant: Shri Gautam Jain, Adv. &For Respondent: Shri Vivek Vardhan, Sr. DR
Section 147Section 148Section 151

section 68 of the Act and the Ld. CIT(A) was also correct in upholding the same after detailed logical analysis of documentary evidence, allegations of the AO and explanation of the assessee. Accordingly, we are unable to see any valid reason to interfere the findings affirmed by the Ld. CIT(A) while confirming the addition u/s