(Now known as Sony India Limited)

Sections (1) and (2) to Section 92C are applicable to the assessed, as well as the Assessing Officer invoking power under Sub-Section (3) to Section 92C of the Act. As noted above, sub-section (2) to Section 92C stipulates that most appropriate method, out of the methods specified in sub-section (1

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

161\ntaxmann.com 160 (Delhi) confirming the aforesaid computation under the old law\nof Explanation-1 to section 153A of the Act. The assessee also relied upon\nsubsequent decision of Delhi High Court in the case of Dinesh Jindal v. AGIT: in\n469 ITR 32 and Delhi High Court KAD Housing P. Ltd. v. DCIT in 168\ntaxmann.com 470, where

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

161 taxmann.com 160/465 ITR\n101 (Delhi)\n11. In Ojjus Medicare Pvt. Limited (supra), the Court also explained the manner in\nwhich the period of six or ten years is required to be reckoned in respect of\nreopening of the assessment for a period prior to six years and/or before the expiry\nof ten years from the relevant assessment years

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

In the result, all the appeals for

161 taxmann.com 160/465 ITR\n101 (Delhi)\n11. In Ojjus Medicare Pvt. Limited (supra), the Court also explained the manner in\nwhich the period of six or ten years is required to be reckoned in respect of\nreopening of the assessment for a period prior to six years and/or before the expiry\nof ten years from the relevant assessment years

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

161 taxmann.com 160/465 ITR\n101 (Delhi)\n11. In Ojjus Medicare Pvt. Limited (supra), the Court also explained the manner in\nwhich the period of six or ten years is required to be reckoned in respect of\nreopening of the assessment for a period prior to six years and/or before the expiry\nof ten years from the relevant assessment years

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

In the result, all the appeals for

161 taxmann.com 160/465 ITR\n101 (Delhi)\n11. In Ojjus Medicare Pvt. Limited (supra), the Court also explained the manner in\nwhich the period of six or ten years is required to be reckoned in respect of\nreopening of the assessment for a period prior to six years and/or before the expiry\nof ten years from the relevant assessment years

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

In the result, all the appeals for

161 taxmann.com 160/465 ITR\n101 (Delhi)\n11. In Ojjus Medicare Pvt. Limited (supra), the Court also explained the manner in\nwhich the period of six or ten years is required to be reckoned in respect of\nreopening of the assessment for a period prior to six years and/or before the expiry\nof ten years from the relevant assessment years

GEETANJALI BHAYANA,DELHI vs. DCIT CENTRAL CIRCLE-32 DELHI, NEW DELHI

68 of the Act\n(instead of appreciating Appellant's objections for invoking Section\n28).\n13. That on the facts and circumstances of the present case, the Leaned\nauthorities below have made/confirmed the impugned addition\nwhile completely ignoring and without rebutting cogent evidence\nestablishing that the alleged recipient i.e. Appellant and payee both\nhave denied receipt and payment

KHOOBSOORAT FABRICS PVT LTD.,NEW DELHI vs. ITO WARD 14(3), NEW DELHI

Appeal are allowed

Bench: Shri Kul Bharat[Assessment Year: 2017-18

1-23 of paper book) 7 (II) EVIDENCES OF CASH WITHDRAWALS i) Copy of bank statement of following banks: a) Oriental bank of commerce A/c No. 50965015001957 for the period from 01.04.2016 to 31.03.2017 (Page 39-60 of paper book) b) Union Bank of India A/e No 532701010034398 for the period from 01.04.2016 to 31.03.2017 (Page 61-76 of paper

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

68 of the I.T. Act, 1961. 6. Against the aforesaid assessment order dated 27.12.2010, assessee preferred an appeal before the Ld. CIT(A), who vide impugned Order dated 04.10.2013 has dismissed the appeal of the asseseee. 7. Aggrieved with the order of the Ld. CIT(A), the Assessee is in appeal before the Tribunal. 8. Ld. Counsel of the assessee

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

68 of the I.T. Act, 1961. 6. Against the aforesaid assessment order dated 27.12.2010, assessee preferred an appeal before the Ld. CIT(A), who vide impugned Order dated 04.10.2013 has dismissed the appeal of the asseseee. 7. Aggrieved with the order of the Ld. CIT(A), the Assessee is in appeal before the Tribunal. 8. Ld. Counsel of the assessee

GEETANJALI BHAYANA,DELHI vs. DCIT CENTRAL CIRCLE-32 DELHI, NEW DELHI

In the result, appeals of the assessee for AY 2019-20 and AY\n2020-21 are allowed

68 of the Act\n(instead of appreciating Appellant's objections for invoking Section\n28).\n\n13. That on the facts and circumstances of the present case, the Leaned\nauthorities below have made/confirmed the impugned addition\nwhile completely ignoring and without rebutting cogent evidence\nestablishing that the alleged recipient i.e. Appellant and payee both\nhave denied receipt and payment

ACIT, HARIDWAR vs. M/S SANT STEEL & ALLOYS (P) LTD., KOTDWAR

In the result, appeals filed by Revenue in ITA No

Bench: Sh. I.C. Sudhir & Sh. O.P. Kant

161. In the light of these facts, Hon'ble High Court observed that since there is an admitted position that the assessee was carrying on the business of coal and lignite and purchases were made from time to time from GMDC, in that case, even if any addition is required to be made under section 69C, the entire expenditure

ACIT, HARIDWAR vs. M/S SANT STEEL & ALLOYS (P) LTD., KOTDWAR

In the result, appeals filed by Revenue in ITA No

Bench: Sh. I.C. Sudhir & Sh. O.P. Kant

161. In the light of these facts, Hon'ble High Court observed that since there is an admitted position that the assessee was carrying on the business of coal and lignite and purchases were made from time to time from GMDC, in that case, even if any addition is required to be made under section 69C, the entire expenditure

GEETANJALI BHAYANA,DELHI vs. DCIT CENTRAL CIRCLE-32 DELHI, NEW DELHI

In the result, appeals of the assessee for AY 2019-20 and AY\n2020-21 are allowed

68 of the Act\n(instead of appreciating Appellant's objections for invoking Section\n28).\n13.\nThat on the facts and circumstances of the present case, the Leaned\nauthorities below have made/confirmed the impugned addition\nwhile completely ignoring and without rebutting cogent evidence\nestablishing that the alleged recipient i.e. Appellant and payee both\nhave denied receipt and payment

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

161 ITR 505 (SC) "The expression used here for the recovery of the possession is "seizure". Seizure is again an expression which implies a forcible exaction or taking possession from either the owner or one who has the possession and who is unwilling to part with possession." Kind reference to Bafna Textiles [1975] 98 ITR 1 (Karnataka) 7 G.M. Agadi

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

161 ITR 505 (SC) "The expression used here for the recovery of the possession is "seizure". Seizure is again an expression which implies a forcible exaction or taking possession from either the owner or one who has the possession and who is unwilling to part with possession." Kind reference to Bafna Textiles [1975] 98 ITR 1 (Karnataka) 7 G.M. Agadi

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

161 ITR 505 (SC) "The expression used here for the recovery of the possession is "seizure". Seizure is again an expression which implies a forcible exaction or taking possession from either the owner or one who has the possession and who is unwilling to part with possession." Kind reference to Bafna Textiles [1975] 98 ITR 1 (Karnataka) 7 G.M. Agadi