M/S. SHAKAMBHARI ISPAT & POWER LTD., ,KOLKATA vs. DCIT, CENTRAL CIRCLE 3(3), , KOLKATA

section 133A was conducted upon the appellant and on\nphysical verification the Department had reported that excess stock\nwas found physically in comparison to the stock appearing in the\nBooks of Accounts/Stock Record. At the time of assessment, the\nAO assessed the entire value of excess stock found at the time of\nsurvey by way of undisclosed income

M/S. SHAKAMBHARI ISPAT & POWER LTD.,,KOLKATA vs. DCIT, CENTRAL CIRCLE 3(3), , KOLKATA

section 133A was conducted upon the appellant and on\nphysical verification the Department had reported that excess stock\nwas found physically in comparison to the stock appearing in the\nBooks of Accounts/Stock Record. At the time of assessment, the\nAO assessed the entire value of excess stock found at the time of\nsurvey by way of undisclosed income

D.C.I.T., CC - 3(1),, KOLKATA vs. SHAKAMBHARI ISPAT & POWER LIMITED, KOLKATA

section 133A was conducted upon the appellant and on\nphysical verification the Department had reported that excess stock\nwas found physically in comparison to the stock appearing in the\nBooks of Accounts/Stock Record. At the time of assessment, the\nAO assessed the entire value of excess stock found at the time of\nsurvey by way of undisclosed income

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3.1, KOLKATA vs. SHAKAMBHARI ISPAT & POWER LIMITED, KOLKATA

section 133A was conducted upon the appellant and on\nphysical verification the Department had reported that excess stock\nwas found physically in comparison to the stock appearing in the\nBooks of Accounts/Stock Record. At the time of assessment, the\nAO assessed the entire value of excess stock found at the time of\nsurvey by way of undisclosed income

DEPUTY COMMISSIONER OF INCOME TAX, KOLKATA vs. SHAKAMBHARI ISPAT & POWER LIMITED, KOLKATA

section 133A was conducted upon the appellant and on\nphysical verification the Department had reported that excess stock\nwas found physically in comparison to the stock appearing in the\nBooks of Accounts/Stock Record. At the time of assessment, the\nAO assessed the entire value of excess stock found at the time of\nsurvey by way of undisclosed income

M/S. SHAKAMBHARI ISPAT & POWER LTD., ,KOLKATA vs. DCIT, CENTRAL CIRCLE 3(3), KOLKATA

Appeals of the assessee are partly allowed and\nappeals of the revenue are dismissed

section 133A was conducted upon the appellant and on\nphysical verification the Department had reported that excess stock\nwas found physically in comparison to the stock appearing in the\nBooks of Accounts/Stock Record. At the time of assessment, the\nAO assessed the entire value of excess stock found at the time of\nsurvey by way of undisclosed income

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3(1),, KOLKATA vs. SHAKAMBHARI ISPAT & POWER LIMITED, KOLKATA

section 133A was conducted upon the appellant and on\nphysical verification the Department had reported that excess stock\nwas found physically in comparison to the stock appearing in the\nBooks of Accounts/Stock Record. At the time of assessment, the\nAO assessed the entire value of excess stock found at the time of\nsurvey by way of undisclosed income

M/S. SHAKAMBHARI ISPAT & POWER LTD.,,KOLKATA vs. DCIT, CENTRAL CIRCLE 3(3), , KOLKATA

section 133A was conducted upon the appellant and on\nphysical verification the Department had reported that excess stock\nwas found physically in comparison to the stock appearing in the\nBooks of Accounts/Stock Record. At the time of assessment, the\nAO assessed the entire value of excess stock found at the time of\nsurvey by way of undisclosed income

M/S. SHAKAMBHARI ISPAT & POWER LTD., ,KOLKATA vs. DCIT, CENTRAL CIRCLE 3(3), , KOLKATA

section 133A was conducted upon the appellant and on\nphysical verification the Department had reported that excess stock\nwas found physically in comparison to the stock appearing in the\nBooks of Accounts/Stock Record. At the time of assessment, the\nAO assessed the entire value of excess stock found at the time of\nsurvey by way of undisclosed income

DEPUTY COMMISSIONER OF INCOME TAX, KOLKATA vs. SHAKAMBHARI ISPAT & POWER LIMITED, KOLKATA

section 133A was conducted upon the appellant and on\nphysical verification the Department had reported that excess stock\nwas found physically in comparison to the stock appearing in the\nBooks of Accounts/Stock Record. At the time of assessment, the\nAO assessed the entire value of excess stock found at the time of\nsurvey by way of undisclosed income

DCIT, CENTRAL CIRCLE-1(4), KOLKATA, KOLKATA vs. MURLIDHAR RATANLAL EXPORTS LTD., KOLKATA

In the result, the appeals of the Revenue are dismissed and the\nCOs of the assessee are partly allowed

133A", "143(3)", "139(1)", "68", "133(6)", "271D", "271E", "69C" ], "issues": "The main issues involved are the validity of reopening of assessment under Section 147, and the deletion of additions made by the AO towards bogus unsecured loans, bogus purchases

M/S. K.R. TRADELINK PRIVATE LIMITED. ,HOWRAH vs. NE-AC, DELHI. , DELHI.

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

Bench: Shri Rajesh Kumar, Am& Shri Pradip Kumar Choubey]

133A of the Act made the addition by disallowing entire purchases by treating the same as bogus purchases after invoking the provisions of section

DEPUTY COMMISSIONER OF INCOME TAX, KOLKATA vs. DOLLAR HOLDING PVT. LTD., KOLKATA

In the result, both the appeals of the Revenue are dismissed

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

133A of the Act, but a retracted statement even under section 132(4) of the Act would require some corroborative material for the AO to proceed to make additions on the basis of such statement. 12.2 In the case of “Basant Bansal vs. ACIT” reported in (2015)63 taxmann.com 199 (Jaipur Trib.), the assessee therein, during the search and seizure

DEPUTY COMMISSOENR OF INCOME TAX, KOLKATA vs. DOLLAR HOLDING PVT. LTD., KOLKATA

In the result, both the appeals of the Revenue are dismissed

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

133A of the Act, but a retracted statement even under section 132(4) of the Act would require some corroborative material for the AO to proceed to make additions on the basis of such statement. 12.2 In the case of “Basant Bansal vs. ACIT” reported in (2015)63 taxmann.com 199 (Jaipur Trib.), the assessee therein, during the search and seizure

M/S. DIVINE ALLOYS & POWER CO. LIMITED ,KOLKATA vs. DCIT, CIRCLE-3(1), KOLKATA, KOLKATA

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

Bench: Shri Rajpal Yadav & Shri Girish Agrawalassessment Year: 2012-13 Divine Alloys & Power Co. Ltd. Deputy Commissioner Of Block-A-139, Regent Estate, Income - Tax, Circle-3(1), Vs. 176/14/139, Rajpur Road, Kolkata. Kolkata-700092. (Pan: Aaccd 1367 Q) (Appellant) (Respondent)

section 68 as undisclosed income of the appellant. 3. That the learned Commissioner of Income Tax (Appeals) has erred in holding that the appellant was unable to establish the genuineness of the subscribers to the share capital/share application money/ share premium and creditworthiness / sources of income of the investors could not be established satisfactorily. 4. That the learned Commissioner

DCIT, CIRCLE-3(1), KOLKATA, KOLKATA vs. M/S. DIVINE ALLOYS & POWER CO. LIMITED , KOLKATA

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

Bench: Shri Rajpal Yadav & Shri Girish Agrawalassessment Year: 2012-13 Divine Alloys & Power Co. Ltd. Deputy Commissioner Of Block-A-139, Regent Estate, Income - Tax, Circle-3(1), Vs. 176/14/139, Rajpur Road, Kolkata. Kolkata-700092. (Pan: Aaccd 1367 Q) (Appellant) (Respondent)

section 68 as undisclosed income of the appellant. 3. That the learned Commissioner of Income Tax (Appeals) has erred in holding that the appellant was unable to establish the genuineness of the subscribers to the share capital/share application money/ share premium and creditworthiness / sources of income of the investors could not be established satisfactorily. 4. That the learned Commissioner

DCIT CENTRAL CIRCLE 1 4 KOLKATA, KOLKATA vs. MURLIDHAR RATANLAL EXPORTS LIMITED, KOLKATA

In the result, the appeals of the Revenue are dismissed and the COs of the assessee are partly allowed

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

Section 147 of the Act were not satisfied by raising ground no.1, which is as under: - “1. That the Ld. CIT(A) was wrong in not allowing the assessee's objections regarding re-opening of assessment proceeding by issuing notice u/s 148 after elapse of four years from the end of the relevant assessment year as the assessee had already

DCIT, CENTRAL CIRCLE-1(4), KOLKATA, KOLKATA vs. MURLIDHAR RATANLAL EXPORTS LIMITED, KOLKATA

In the result, the appeals of the Revenue are dismissed and the COs of the assessee are partly allowed

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

Section 147 of the Act were not satisfied by raising ground no.1, which is as under: - “1. That the Ld. CIT(A) was wrong in not allowing the assessee's objections regarding re-opening of assessment proceeding by issuing notice u/s 148 after elapse of four years from the end of the relevant assessment year as the assessee had already