BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE-18, DELHI

In the result, the appeals of the revenue in ITA No

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

147, for the very same year is nothing but rowing and fishing enquiries, which is impermissible. 7. That on the facts & circumstances of the case and in law, the CIT(A) did not appreciate that the information based on which order u/s. 153A/143(3) of the Act was concluded, was already available with the Income-tax Department. Inter-alia, Assessing

COMMISSIONER OF INCOME TAX, DELHI VIII vs. INDIAN FARMERS FERTILIZERS CO-OP. LTD.

The appeal stands disposed of accordingly

1) and (6) of Section 80-I. Subsequently, though the assessment was revised under Section 147 since the A.O. had reason to believe that the assessee’s income chargeable to tax had escaped assessment, the assessee having claimed deduction under Section 80-I without excluding certain income which had not at all been derived from the eligible industrial undertaking

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

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

section 34/147." In the same order the Hon'ble court has further held that it not furnish a reasonable ground for the Income tax Officer to believe that on account of the failure - indeed not a mere failure but a positive design to mislead of the assessee to disclose all material facts, fully and truly, necessary for the assessment

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

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

section 34/147." In the same order the Hon'ble court has further held that it not furnish a reasonable ground for the Income tax Officer to believe that on account of the failure - indeed not a mere failure but a positive design to mislead of the assessee to disclose all material facts, fully and truly, necessary for the assessment

M/S. CHITRAKOOT MERCHANDISE PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, both the Appeals filed by the Assessee stand allowed

Bench: Shri H.S. Sidhu & Shri O.P. Kant

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person other than the person referred to in section 153A, then the books of account or documents or assets

M/S. CHITRAKOOT MERCHANDISE PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, both the Appeals filed by the Assessee stand allowed

Bench: Shri H.S. Sidhu & Shri O.P. Kant

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person other than the person referred to in section 153A, then the books of account or documents or assets

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

Section 153C read with Section 153A of the Act. 97. Proceeding then to List II, we find that the petitions placed in that list pertain to cases where the hand over occurred in FYs 2022-23 and 2023-24. Consequently, the relevant AYs' would be AY 2023-24 and AY 2024-25 respectively. In light of the principles enunciated

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

Section 153C read with Section 153A of the Act. 97. Proceeding then to List II, we find that the petitions placed in that list pertain to cases where the hand over occurred in FYs 2022-23 and 2023-24. Consequently, the relevant AYs' would be AY 2023-24 and AY 2024-25 respectively. In light of the principles enunciated

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

Section 153C read with Section 153A of the Act. 97. Proceeding then to List II, we find that the petitions placed in that list pertain to cases where the hand over occurred in FYs 2022-23 and 2023-24. Consequently, the relevant AYs' would be AY 2023-24 and AY 2024-25 respectively. In light of the principles enunciated

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

Section 153C read with Section 153A of the Act. 97. Proceeding then to List II, we find that the petitions placed in that list pertain to cases where the hand over occurred in FYs 2022-23 and 2023-24. Consequently, the relevant AYs' would be AY 2023-24 and AY 2024-25 respectively. In light of the principles enunciated

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

Section 153C read with Section 153A of the Act. 97. Proceeding then to List II, we find that the petitions placed in that list pertain to cases where the hand over occurred in FYs 2022-23 and 2023-24. Consequently, the relevant AYs' would be AY 2023-24 and AY 2024-25 respectively. In light of the principles enunciated

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-I, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

Section 153C read with Section 153A of the Act. 97. Proceeding then to List II, we find that the petitions placed in that list pertain to cases where the hand over occurred in FYs 2022-23 and 2023-24. Consequently, the relevant AYs' would be AY 2023-24 and AY 2024-25 respectively. In light of the principles enunciated

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

Section 153C read with Section 153A of the Act. 97. Proceeding then to List II, we find that the petitions placed in that list pertain to cases where the hand over occurred in FYs 2022-23 and 2023-24. Consequently, the relevant AYs' would be AY 2023-24 and AY 2024-25 respectively. In light of the principles enunciated

ACIT, NEW DELHI vs. M/S SPLENDOR LANDBASE LTD.,, NEW DELHI

In the result, the Appeal filed by the Revenue stand dismissed

Bench: Shri H.S. Sidhu & Shri O.P. Kanti.T.A. No.2461/Del/2016 A.Y. : 2010-11 Assistant Commissioner M/S Splendor Landbase Of Income, Central Vs. Limited, Circle-3, F-38/2, Splendor House, New Delhi Okhla Industrial Area, Phase-Ii, New Delhi (Pan: Aaeca3986E) (Appellant) (Respondent) & C.O. No. 215/Del/2016 In I.T.A. No. 2461/Del/2016 A.Y. : 2010-11 M/S Splendor Landbase Assistant Commissioner Limited, Vs. Of Income, Central Circle- F-38/2, Splendor House, 3, Okhla Industrial Area, New Delhi Phase-Ii, New Delhi (Pan: Aaeca3986E) (Appellant) (Respondent)

reassessment was in consequence of return filed in response to notice u/s 153A, which statutorily being a return u/s 139(1) provisions of s. 80 of the Act do not apply and the assessee is eligible to carry forward of the loss. I do not agree with the contentions of the appellant since sub-section (3) of s. 139 very

PR. COMMISSIONER OF INCOME TAX-19 vs. SHRI NEERAJ JINDAL

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE NAJMI WAZIRI

72,799/- on 30.12.2005. A search and seizure operation under Section 132(4) of the Act was carried out on 11.01.2007 in the premises of the assessee's group companies and directors of the company. A disclosure of `16 crores was made by the group under Section 132(4) of the Act on behalf of different directors and relatives

PR. COMMISSIONER OF INCOME TAX-19 vs. SHRI ANKUR AGGARWAL

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE NAJMI WAZIRI

72,799/- on 30.12.2005. A search and seizure operation under Section 132(4) of the Act was carried out on 11.01.2007 in the premises of the assessee's group companies and directors of the company. A disclosure of `16 crores was made by the group under Section 132(4) of the Act on behalf of different directors and relatives

PR. COMMISSIONER OF INCOME TAX-19 vs. SHRI ANKUR AGGARWAL

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE NAJMI WAZIRI

72,799/- on 30.12.2005. A search and seizure operation under Section 132(4) of the Act was carried out on 11.01.2007 in the premises of the assessee's group companies and directors of the company. A disclosure of `16 crores was made by the group under Section 132(4) of the Act on behalf of different directors and relatives

SUSHIL BANSAL,NEW DELHI vs. ACIT, CIRCLE- 57(1), NEW DELHI

In the result, the appeal is dismissed

Bench: : Shri Amit Shukla & Shri L.P. Sahuassessment Year: 2013-14

reassessment proceedings, even when intimation under section 143(1) has been issued. [Para 18]” [emphasis supplied. ] Thus, when the return was processed under sec. 143(1) and there was no assessment under sec. 143(3), what is to be seen is whether the A.O. had prima-facie reasons to believe that income has escaped assessment, for issue of notice under

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)

72. Reliance in this regard may be made to the decision of the Mumbai Bench of the Tribunal in the case of Vodafone India Limited v DCIT: ITA No. 1835/Mum/2018. In that case, share capital was received by the assessee from its existing Mauritius based shareholders on subscription to right issue of shares. The assessing officer added the said capital