ADDL. CIT, SPECIAL RANGE- 7, NEW DELHI vs. PRAYAG POLYTECH PVT. LTD., NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumarassessment Year: 2014-15

272 (vii) CIT vs PithampurConzima (P) Ltd. (2000) 244 ITR 442 (MP High Court (viii) TolaramDaga's case [1966] 59 ITR 632 (Assam) 11. In reply the Ld. DR placed reliance on the order passed by the AO and the Ld. CIT(A). It was submitted that the assessee has failed to discharge its onus under section 68

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S. SHRISH ENTERPRISES PRIVATE LIMITED, DELHI

Bench: Ms. Madhumita Roy & Shri Naveen Chandradcit, Room No. 225E, Cr Vs. M/S Shrish Enterprise Building, 2Nd Floor, Private Limited, Hall No. Ip Estate, 3 & 4, M-27/2, Badli New Delhi - 110002 Industrial Estate, Badli, Delhi – 110042 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aafcs0684N Appellant .. Respondent

Section 68. One must not lose Sight of the fact that it is the Revenue which has all the power and wherewithal to trace any person. Moreover, it is settled law that the assessee need not to prove the source of source." P a g e | 12 DCIT Vs. M/s Shrish Enterprise

ITO, NEW DELHI vs. M/S. BILLET PROCON PVT. LTD., DELHI

In the result, appeal of the Revenue is dismissed

Bench: Shri Challa Nagendra Prasad\Nand\Nshri S Rifaur Rahman\N\Nita No. 1382/Del/2017\Nनिर्धारणवर्ष/Assessment Year: 2012-13\N\Nito,\Nward-5(1), Room No.379,\N3Rd Floor, C.R. Building, I.P. Estate,\Nnew Delhi.\Npan No.Aalfb8236G\Nअपीलार्थी Appellant\N\Nassessee By\Ndr. Kapil Goel, Adv.\N\Nrevenue By\Nshri Ajay Kumar Arora, Sr. Dr\N\Nसुनवाईकीतारीख / Date Of Hearing:\N27.05.2025\Nउद्घोषणाकीतारीख /Pronouncement On 25.06.2025\N\Nआदेश /Order\N\Nper C.N. Prasad, J.M.\N\Nthis Appeal Is Filed By The Revenue Against The Order Of The Ld. Cit(Appeals)-2, New Delhi Dated 30.11.2016 For The Ay 2012-13.\Nrevenue In Its Appeal Raised The Following Grounds: -\N\N1. “Whether On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Deleting The Addition Of Rs.3,52,00,000/- Made By Ao U/S 68 Of The I.T. Act On Account Of Unexplained Credits In The Form Of Share Capital/Share Premium During The Year.\N\N2. Whether On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Holding That The Assessee Has Discharged The Onus Of Proving The Identify & Creditworthiness Of The Share Subscribers & The Genuineness Of The Subscription.\"\N\N2. Ld. Counsel For The Assessee, At The Outset, Submitted That The Assessee Filed Petition Under Rule 27 Of Itat Rules As A Defense Plea To Support Ld. Cit(Appeals) Order On Legal & Jurisdictional Grounds Raised Before The Ld. Cit(Appeals) But Was Rejected Vide Para 3.

68 is rejected.\"\n\n7. The assessee filed petition under Rule 27 of ITAT Rules to support the Ld. CIT(Appeals) order on legal ground which was rejected by the Ld. CIT(Appeals) as stated above.\n\n8. We observed that whether the petition filed by the Assessee under Rule 27 of ITAT Rules supporting the order

DY. COMMISSIONER OF INCOME TAX, NOIDA vs. STAR LANDCRAFT PRIVATE LIMITED, GHAZIABAD

In the result, appeal of the Revenue in ITA No

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

section 68 stood fulfilled.( Refer Page No. 103-104 of the CIT(A) order of M/s Allure Developers Pvt Ltd. for AY 2020-21). In this regard reliance is being placed upon the following judicial pronouncements:- i. Principal Commissioner Of Income Tax-4 Vs. Hi-Tech Residency (P.) Ltd. [2018] 96 Taxmann.Com 403 (Sc)/[2018] 257 Taxman

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1 NOIDA, NOIDA vs. M/S ALLURE DEVELOPERS PVT. LTD, NEW DELHI

In the result, appeal of the Revenue in ITA No

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

section 68 stood fulfilled.( Refer Page No. 103-104 of the CIT(A) order of M/s Allure Developers Pvt Ltd. for AY 2020-21). In this regard reliance is being placed upon the following judicial pronouncements:- i. Principal Commissioner Of Income Tax-4 Vs. Hi-Tech Residency (P.) Ltd. [2018] 96 Taxmann.Com 403 (Sc)/[2018] 257 Taxman

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1 NOIDA, NOIDA vs. M/S ACE RESIDENCY PVT. LTD, GHAZIABAD

In the result, appeal of the Revenue in ITA No

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

section 68 stood fulfilled.( Refer Page No. 103-104 of the CIT(A) order of M/s Allure Developers Pvt Ltd. for AY 2020-21). In this regard reliance is being placed upon the following judicial pronouncements:- i. Principal Commissioner Of Income Tax-4 Vs. Hi-Tech Residency (P.) Ltd. [2018] 96 Taxmann.Com 403 (Sc)/[2018] 257 Taxman

DY COMMISSIONER OF INCOME TAX, NOIDA vs. M/S ALLURE DEVELOPERS PRIVATE LIMITED, DELHI

In the result, appeal of the Revenue in ITA No

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

section 68 stood fulfilled.( Refer Page No. 103-104 of the CIT(A) order of M/s Allure Developers Pvt Ltd. for AY 2020-21). In this regard reliance is being placed upon the following judicial pronouncements:- i. Principal Commissioner Of Income Tax-4 Vs. Hi-Tech Residency (P.) Ltd. [2018] 96 Taxmann.Com 403 (Sc)/[2018] 257 Taxman

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1 NOIDA, NOIA vs. M/S AJAY REALCON PVT. LTD., NOIDA

In the result, appeal of the Revenue in ITA No

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

section 68 stood fulfilled.( Refer Page No. 103-104 of the CIT(A) order of M/s Allure Developers Pvt Ltd. for AY 2020-21). In this regard reliance is being placed upon the following judicial pronouncements:- i. Principal Commissioner Of Income Tax-4 Vs. Hi-Tech Residency (P.) Ltd. [2018] 96 Taxmann.Com 403 (Sc)/[2018] 257 Taxman

DY. COMMISSIONER OF INCOME TAX, NOIDA vs. STAR LANDCRAFT PRIVATE LIMITED, GHAZIABAD

In the result, appeal of the Revenue in ITA No

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

section 68 stood fulfilled.( Refer Page No. 103-104 of the CIT(A) order of M/s Allure Developers Pvt Ltd. for AY 2020-21). In this regard reliance is being placed upon the following judicial pronouncements:- i. Principal Commissioner Of Income Tax-4 Vs. Hi-Tech Residency (P.) Ltd. [2018] 96 Taxmann.Com 403 (Sc)/[2018] 257 Taxman

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1 NOIDA, NOIDA vs. M/S ALLURE DEVELOPERS PRIVATE LIMITED, NOIDA

In the result, appeal of the Revenue in ITA No

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

section 68 stood fulfilled.( Refer Page No. 103-104 of the CIT(A) order of M/s Allure Developers Pvt Ltd. for AY 2020-21). In this regard reliance is being placed upon the following judicial pronouncements:- i. Principal Commissioner Of Income Tax-4 Vs. Hi-Tech Residency (P.) Ltd. [2018] 96 Taxmann.Com 403 (Sc)/[2018] 257 Taxman

ACIT, CIRCLE-18(2), NEW DELHI vs. NIIT TECHNOLOGIES LTD., NEW DELHI

In the result, appeal of the Revenue in ITA No

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

section 68 stood fulfilled.( Refer Page No. 103-104 of the CIT(A) order of M/s Allure Developers Pvt Ltd. for AY 2020-21). In this regard reliance is being placed upon the following judicial pronouncements:- i. Principal Commissioner Of Income Tax-4 Vs. Hi-Tech Residency (P.) Ltd. [2018] 96 Taxmann.Com 403 (Sc)/[2018] 257 Taxman

INTELLECTUAL SECURITES PVT. LTD.,DELHI vs. DCIT, CC, NOIDA

In the result, the appeal of the assessee is allowed

Bench: Sh. Amit Shukladr. B. R. R. Kumar(Through Video Conferencing)

272 in clause (v) has held that no addition could be made on presumption; suspicion however, strong, cannot take place of evidence. In view of the above, the appellants contend that the impugned addition made by the Assessing Officer under section 68

SANJAY GUPTA,PANIPAT vs. PR, CIT , ROHTAK

In the result, the appeal of the assessee in ITA No

Bench: Shri N.K. Billaiya & Shri Challa Nagendra Prasad

68, 69, 69A, 69B, 69C, or 69D if such income is not reflected in the return of income furnished under section 139 of the Act, income tax payable shall be @ 60% on income so referred in the said section. 16. Change which has been brought about in the provisions relates to income so referred to in the afore

MOTI ADHESIVES P.LTD,DELHI vs. ITO, WARD-17(2), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri H.S. Sidhuassessment Year: 2009-10

272 (Bombay) and the order of the Apex Court in case of Commissioner of Income Tax vs. Lovely Exports (P.) Ltd., reported in [2008] 216 CTR 195 (SC). 4] We have considered the submissions. 5] The Assessing Officer added Rs.95 lakhs as income under Section 68

INCOME TAX OFFICER, DELHI vs. MOHD RIZWAN, DELHI

In the result, addition of Rs

272/- as against purchases of Rs.13,78,38,452/-. If this purchase was forming part of closing stock either in full or in part, no addition was required to that extent as no expenditure could have been claimed by the appellant so as to reduce the profits in that case. Furthermore, the AO did not examine if this case

ALANICE COMPUTER SERVICES P.LTD,NEW DELHI vs. ITO, WARD-10(1), NEW DELHI

In the result, the appeal of the assessee is dismissed

Bench: Sh. Saktiit Deydr. B. R. R. Kumar

section 68 of Income Tax Act 1961 as no documents filed in support of receipt of share capital/share premium in the financial year 2008-09 relevant to assessment year 2009-10. 25. In this regards, it is hereby submitted that the aforesaid findings of the Id. A.O. are grossly baseless and based on surmise & conjectures. The assessee company

DURGESH AUTOFIN P.LTD,BIJNOR vs. PRCIT, MUZAFFARNAGAR

In the result, the appeal of the assessee is allowed

Bench: Sh. N. K. Saini, Am & Ms. Suchitra Kamble, Jm Ita No. 2539/Del/2018 : Asstt. Year : 2013-14 Durgesh Autofin P. Ltd., Vs Pr. Commissioner Of Income Tax, C/O Sh. Pankaj Kumar, Director, Muzaffarnagar-251002 S/O Late Sh. Tejpal Singh, Mandi Kotla, Near Nehru Murti, Chandpur, Bijnot, Bijnor, Uttar Pradesh (Appellant) (Respondent) Pan No. Aaccd0768P Assessee By : Sh. Vivek Bansal, Adv. Revenue By : Ms. Rachna Singh, Cit Dr Date Of Hearing : 29.08.2018 Date Of Pronouncement : 09.10.2018 Order Per N. K. Saini, Am: This Is An Appeal By The Assessee Against The Order Dated 13.03.2018 Of Ld. Pr. Cit, Muzaffarnagar U/S 263 Of The Income Tax Act, 1961 (Hereinafter Referred To As The Act).

68 of the Act, which would be 30% of the cash loans. It was also contended that even in the order of levying the penalty u/s 271D of the Act, it had been admitted by the Addl. CIT that evidences regarding each of the 177 persons were submitted to the AO during the course of assessment proceedings. It was stated

NIRANKARI SONS JEWELLERS PRIVATE LIMITED,DELHI vs. INCOME TAX OFFICER, WARD 18(3), DELHI, DELHI

In the result, the appeal of the assessee is allowed

Bench: Ms. Madhumita Roy & Sh. Naveen Chandra

Section 68 of the Act which was further confirmed by the Ld. CIT(A). 8. At the time of the hearing of the matter the Ld. Sr. Counsel Sh. Ajay Wadhwa appearing for the assessee while arguing in support of the case submitted that before the First Appellate Authority the sale invoices containing invoice No., date, party name, address