GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

70,55,196/- 9. That Sir, in view of 1 Proviso to Sec. 153C the date of Search is to be construed when it is received by AO of such third person. In this case we are the person covered by such law. In our case AO has issued Notice to us u/s 153C on 21/01/2022

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. ACIT, CENTRAL CIRCLE-1, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

70,55,196/- 9. That Sir, in view of 1 Proviso to Sec. 153C the date of Search is to be construed when it is received by AO of such third person. In this case we are the person covered by such law. In our case AO has issued Notice to us u/s 153C on 21/01/2022

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

70,55,196/- 9. That Sir, in view of 1 Proviso to Sec. 153C the date of Search is to be construed when it is received by AO of such third person. In this case we are the person covered by such law. In our case AO has issued Notice to us u/s 153C on 21/01/2022

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

70,55,196/- 9. That Sir, in view of 1 Proviso to Sec. 153C the date of Search is to be construed when it is received by AO of such third person. In this case we are the person covered by such law. In our case AO has issued Notice to us u/s 153C on 21/01/2022

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

70,55,196/- 9. That Sir, in view of 1 Proviso to Sec. 153C the date of Search is to be construed when it is received by AO of such third person. In this case we are the person covered by such law. In our case AO has issued Notice to us u/s 153C on 21/01/2022

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

70,55,196/- 9. That Sir, in view of 1 Proviso to Sec. 153C the date of Search is to be construed when it is received by AO of such third person. In this case we are the person covered by such law. In our case AO has issued Notice to us u/s 153C on 21/01/2022

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

70,55,196/- 9. That Sir, in view of 1 Proviso to Sec. 153C the date of Search is to be construed when it is received by AO of such third person. In this case we are the person covered by such law. In our case AO has issued Notice to us u/s 153C on 21/01/2022

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

70,55,196/- 9. That Sir, in view of 1 Proviso to Sec. 153C the date of Search is to be construed when it is received by AO of such third person. In this case we are the person covered by such law. In our case AO has issued Notice to us u/s 153C on 21/01/2022

RI-BHOI ISPAT & ROLLING MILLS,BYRNIHAT vs. ITO, WARD- BYRNIHAT, BYRNIHAT

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

section 70." Since tax invoice as per Rule 27 and Rule 29 "cannot be said to be proving the actual physical movement of the good"; However, Hon'ble Supreme Court adds that while the tax invoice and cheque can be said to be proving one of I.T.A. No.: 241/GTY/2024 Assessment Year: 2018-19 RI-BHOI Ispat & Rolling Mills. the documents

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 2, DIBRUGARH vs. T & T PROJECTS LTD., GUWAHATI

In the result and for the reasons discussed above, we find no merit in this appeal

Bench: Shri A. T. Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.208/Gau/2017 ("नधा"रणवष" / Assessment Year:2010-11)

section 147 of the Act, had been held in the following cases: i) Corporation Bank Ltd (2002) 254 ITR 791 (SC) ii) Arthus Anerson& Co v AClT (2010) 324 ITR 240 (Bom) 9. We note that when there is no failure on the part of the assessee to disclose material facts and when income is reassessed based on same sets

AGRIM INFRAPROJECT PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3, GUWAHATI

In the result, this appeal of the assessee i

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

70,00,000/- from typical Kolkata-based jamakharchi companies. In his opinion, these transactions are bogus and, therefore, he made addition of this amount under section 68 of the Income Tax Act. 12. On appeal, ld. 1st Appellate Authority has reproduced the assessment order and thereafter observed that the assessee was supposed to give fresh written submission because its first

AGRIM INFRAPROJECT PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3, GUWAHATI

In the result, this appeal of the assessee i

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

70,00,000/- from typical Kolkata-based jamakharchi companies. In his opinion, these transactions are bogus and, therefore, he made addition of this amount under section 68 of the Income Tax Act. 12. On appeal, ld. 1st Appellate Authority has reproduced the assessment order and thereafter observed that the assessee was supposed to give fresh written submission because its first

AGRIM INFRAPROJECT PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3, GUWAHATI

In the result, this appeal of the assessee i

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

70,00,000/- from typical Kolkata-based jamakharchi companies. In his opinion, these transactions are bogus and, therefore, he made addition of this amount under section 68 of the Income Tax Act. 12. On appeal, ld. 1st Appellate Authority has reproduced the assessment order and thereafter observed that the assessee was supposed to give fresh written submission because its first

SHRI ABHIJIT RABHA,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-BONGAIGAON, BONGAIGAON

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Sri Rajpal Yadav(Kz) & Dr. Manish Borad

70 of the impugned order and reads as follows: “In view of the above discussion, the impugned addition of Rs. 40,92,502/-made by the Ld. AO is, hereby, confirmed. It is further directed that the so called expenses amounting to Rs. 7,26,607/- purportedly incurred by the Appellant in earning the gross agricultural income

SHRI ABHIJIT RABHA,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-BONGAIGAON, BONGAIGAON

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Sri Rajpal Yadav(Kz) & Dr. Manish Borad

70 of the impugned order and reads as follows: “In view of the above discussion, the impugned addition of Rs. 40,92,502/-made by the Ld. AO is, hereby, confirmed. It is further directed that the so called expenses amounting to Rs. 7,26,607/- purportedly incurred by the Appellant in earning the gross agricultural income

ASHA CHOUDHURY,IMPHAL vs. INCOME TAX WARD 1 IMPHAL, IMPHAL

Bench: the date of hearing.”

70 (SC)] which needed be read in conjunction with the case of Ashish Agarwal [138 taxmann.com 64 (SC)], the notice u/s 148 issued under the new regime was barred by limitation. 2.1 The Ld. DR stated that such ground was not raised before the Ld. CIT(A) or even the Ld. AO and hence the same should not be entertained

ASHA CHOUDHURY,IMPHAL vs. INCOME TAX OFFICER WARD 1 IMPHAL, IMPHAL

Bench: the date of hearing.”

70 (SC)] which needed be read in conjunction with the case of Ashish Agarwal [138 taxmann.com 64 (SC)], the notice u/s 148 issued under the new regime was barred by limitation. 2.1 The Ld. DR stated that such ground was not raised before the Ld. CIT(A) or even the Ld. AO and hence the same should not be entertained

RESHMI JAIN,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, GUWAHATI

In the result, the all the appeals of the assessees are allowed

Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the [Principal Commissioner or] Commissioner under sub-section (12) of section 144BA. The Tribunal while quashing the assessment order had relied upon its earlier decision in Navin Jain and Others (Supra) wherein a detailed discussion has been made with