ACIT CC-3(2),, KOLKATA vs. SRI ARJUN LAL AGARWAL , KOLKATA

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

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Girish Agrawal

seizure action taken after this date. [Clauses 89, 95, 96] [ Emphasis provided] 6.1. Since section 271AAB was introduced in place of 271AAA for searches conducted after 01.07.2012, relevant extracts from from Explanatory Memo to Finance Bill, 2007 vide which section 271 AAA was introduced, are reproduced as under : “It is also proposed to insert a new section

ACIT CC-3(2) , KOLKATA vs. SMT. KALAWATI DEVI AGARWAL, BILASPUR

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

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Girish Agrawal

seizure action taken after this date. [Clauses 89, 95, 96] [ Emphasis provided] 6.1. Since section 271AAB was introduced in place of 271AAA for searches conducted after 01.07.2012, relevant extracts from from Explanatory Memo to Finance Bill, 2007 vide which section 271 AAA was introduced, are reproduced as under : “It is also proposed to insert a new section

ACITCC-3(2), KOLKATA vs. SMT. SAVITRI DEVI AGARWAL, BILASPUR

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

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

seizure action taken after this date. [Clauses 89, 95, 96] [ Emphasis provided] 6.1. Since section 271AAB was introduced in place of 271AAA for searches conducted after 01.07.2012, relevant extracts from from Explanatory Memo to Finance Bill, 2007 vide which section 271 AAA was introduced, are reproduced as under : “It is also proposed to insert a new section

M/S. INDIAN ROADWAYS CORPORATION LTD., ,KOLKATA vs. PRINCIPAL CIT, CENTRAL - 1, KOLKATA , KOLKATA

In the result, the appeal filed by the assessee, is allowed

Bench: Shri A.T.Varkey, Jm & Dr. A.L. Saini, Am Vs. Principal Commissioner Of M/S Indian Roadways Corporation Ltd. Income Tax, Central-I, Irc House, 1, Sunyat Sen Street, Kolkata, Aayakar Bhawan Kolkata-700012. Poorva, 110, Shantipally, Kolkata-700107. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaaci 7333 K (अपीलाथ" /Appellant) (""यथ" / Respondent) ..

68,447/- and for other two balances of Rs. 1,27,033/- and Rs. 4,200/-, nature of ‘sundry balances written off’, were available before the assessing officer when he was making assessment under section 143 (3) of the Act on 27.12.2011. Therefore, during the search and seizure

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

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 action u/s 132 of the Act, offered a summary discloser

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

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 action u/s 132 of the Act, offered a summary discloser

M/S. BMS SALES PVT. LTD., ,PURULIA vs. DCIT, CENTRAL CIRCLE 3(1), , KOLKATA

In the result, the appeal of the assessee is allowed

seizure operation u/s 132 of the Act, 1961 was conducted on\nAgarwal Group and its associates by the Directorate of Investigation,\nKolkata on 17.09.2021 and on subsequent dates. Being one of the\nassociate members of the above group, the assessee was also\ncovered in search by executing a warrant. Pursuant to the search &\nseizure operation, the case of the assessee

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. GOLDEN GOENKA CREDIT PRIVATE LIMITED , KOLKATA

In the result, the appeal of the revenue is dismissed

Bench: Shri Rajesh Kumar (Accountant Member), Shri Pradip Kumar Choubey (Judicial Member)

search & seizure action it was observed that the assessee, during the period of ASSESSMENT YEAR 2022-23, had received unsecured loan from various lenders. Accepting of such unsecured loans & paying of interest on that behalf was also affirmed by the assessee and details of which are as under:- 3 Golden Goenka Credit Pvt. Ltd Name of the loan creditor Amount

DCIT,CC-1(3),KOLKATA, KOLKATA vs. SAMRIDDHI METALS PVT. LTD., KOLKATA

In the result, all the captioned appeals of the revenue are dismissed and the Cross Objection of the assessee is allowed

Bench: Shri Sanjay Garg & Shri Rakesh Mishra

seizure action was carried out u/s. 132 of the Act on 07.12.2020 in S M Group of cases and the assessee was also covered in the said search action. Pursuant to the said search action, the assessee filed its return of income u/s. 153A of the Act on 09.03.2022. The assessment was carried out u/s. 153A

DCIT, CC-1(3), KOLKATA, KOLKATA vs. DISHA REALCON PVT. LTD., KOLKATA

In the result, all the captioned appeals of the revenue are dismissed and the Cross Objection of the assessee is allowed

Bench: Shri Sanjay Garg & Shri Rakesh Mishra

seizure action was carried out u/s. 132 of the Act on 07.12.2020 in S M Group of cases and the assessee was also covered in the said search action. Pursuant to the said search action, the assessee filed its return of income u/s. 153A of the Act on 09.03.2022. The assessment was carried out u/s. 153A

DCIT,CC-1(3),KOLKATA, KOLKATA vs. SAMRIDDHI METALS PVT. LTD., KOLKATA

In the result, all the captioned appeals of the revenue are dismissed and the Cross Objection of the assessee is allowed

Bench: Shri Sanjay Garg & Shri Rakesh Mishra

seizure action was carried out u/s. 132 of the Act on 07.12.2020 in S M Group of cases and the assessee was also covered in the said search action. Pursuant to the said search action, the assessee filed its return of income u/s. 153A of the Act on 09.03.2022. The assessment was carried out u/s. 153A

DCIT,CC-1(3),KOLKATA, KOLKATA vs. SUMANGAL DEALMARK PVT. LTD., KOLKATA

In the result, all the captioned appeals of the revenue are dismissed and the Cross Objection of the assessee is allowed

Bench: Shri Sanjay Garg & Shri Rakesh Mishra

seizure action was carried out u/s. 132 of the Act on 07.12.2020 in S M Group of cases and the assessee was also covered in the said search action. Pursuant to the said search action, the assessee filed its return of income u/s. 153A of the Act on 09.03.2022. The assessment was carried out u/s. 153A

DCIT, CC-1(3), KOLKATA vs. PRAFUL ENTERPRISES PVT. LTD., KOLKATA

In the result, all the captioned appeals of the revenue are dismissed and the Cross Objection of the assessee is allowed

Bench: Shri Sanjay Garg & Shri Rakesh Mishra

seizure action was carried out u/s. 132 of the Act on 07.12.2020 in S M Group of cases and the assessee was also covered in the said search action. Pursuant to the said search action, the assessee filed its return of income u/s. 153A of the Act on 09.03.2022. The assessment was carried out u/s. 153A

DCIT,CC-1(3),KOLKATA, KOLKATA vs. SAMRIDDHI METALS PVT. LTD., KOLKATA

In the result, all the captioned appeals of the revenue are dismissed and the Cross Objection of the assessee is allowed

Bench: Shri Sanjay Garg & Shri Rakesh Mishra

seizure action was carried out u/s. 132 of the Act on 07.12.2020 in S M Group of cases and the assessee was also covered in the said search action. Pursuant to the said search action, the assessee filed its return of income u/s. 153A of the Act on 09.03.2022. The assessment was carried out u/s. 153A

DCIT,CC-1(3),KOLKATA, KOLKATA vs. SUMANGAL DEALMARK PVT. LTD., KOLKATA

In the result, all the captioned appeals of the revenue are dismissed and the Cross Objection of the assessee is allowed

Bench: Shri Sanjay Garg & Shri Rakesh Mishra

seizure action was carried out u/s. 132 of the Act on 07.12.2020 in S M Group of cases and the assessee was also covered in the said search action. Pursuant to the said search action, the assessee filed its return of income u/s. 153A of the Act on 09.03.2022. The assessment was carried out u/s. 153A

DCIT,CC-1(3),KOLKATA, KOLKATA vs. SUMANGAL DEALMARK PVT. LTD., KOLKATA

In the result, all the captioned appeals of the revenue are dismissed and the Cross Objection of the assessee is allowed

Bench: Shri Sanjay Garg & Shri Rakesh Mishra

seizure action was carried out u/s. 132 of the Act on 07.12.2020 in S M Group of cases and the assessee was also covered in the said search action. Pursuant to the said search action, the assessee filed its return of income u/s. 153A of the Act on 09.03.2022. The assessment was carried out u/s. 153A

DCIT, CC-1(3), KOLKATA, KOLKATA vs. SUMANGAL DEALMARK PVT. LTD., KOLKATA

In the result, all the captioned appeals of the revenue are dismissed and the Cross Objection of the assessee is allowed

Bench: Shri Sanjay Garg & Shri Rakesh Mishra

seizure action was carried out u/s. 132 of the Act on 07.12.2020 in S M Group of cases and the assessee was also covered in the said search action. Pursuant to the said search action, the assessee filed its return of income u/s. 153A of the Act on 09.03.2022. The assessment was carried out u/s. 153A

DCIT, CC-1(3), KOLKATA, KOLKATA vs. SUMANGAL DEALMARK PVT. LTD., KOLKATA

In the result, all the captioned appeals of the revenue are dismissed and the Cross Objection of the assessee is allowed

Bench: Shri Sanjay Garg & Shri Rakesh Mishra

seizure action was carried out u/s. 132 of the Act on 07.12.2020 in S M Group of cases and the assessee was also covered in the said search action. Pursuant to the said search action, the assessee filed its return of income u/s. 153A of the Act on 09.03.2022. The assessment was carried out u/s. 153A