2014 (10) TMI 320 - ITAT HYDERABAD
Ms. S. Madhavi, Hyderabad Versus The Asst. CIT Circle-8(1), Hyderabad
Validity of proceedings initiated u/s 153C – Addition of STCG – Held that:- The seized material on the basis of which the AO has initiated the proceedings u/s 153C - A reference to the seized material indicates that the same is an account relating to ......
2014 (10) TMI 216 - ITAT DELHI
DCIT, Central Circle- 21, New Delhi Versus M/s. Devi Dayal Petro Chemicals Pvt. Ltd.
Search and Seizure u/s 132 – order u/s 153C r.w. section 153A - Held that:- The matter is set aside and restored to the file of the AO for re-examination of the issue in the light of the decision of Honble Jurisdictional High Court in SSP AVIATION L ......
2014 (9) TMI 625 - ITAT BANGALORE
Prithvi Developers & Builders Versus The Deputy Commissioner of Income Tax
Validity of assessment u/s 153C r.w.s. 143(3) – Estimation of business income on higher side – Assessment made on assumptions – Held that:- The mandatory conditions of recording satisfaction not complied with to invoke the jurisdiction u/s 153C of th ......
2014 (9) TMI 310 - ITAT AHMEDABAD
Pravinbhai Keshavbhai Patel Versus Dy. Commissioner of Income Tax
Invocation of proceedings u/s 153C – assessment made on the basis of material found during seizure - Whether the seized material found from Shri Vikas A. Shah belongs to the assessee and assessment made on the basis of material is in confirmation of ......
2014 (9) TMI 274 - ITAT HYDERABAD
Ms. Ch. Madhavi, Smt. K. Vijayalakshmi Versus ACIT, Circle 8 (1), Hyderabad
Initiation of proceedings u/s 153C r.w. section 153A – Seized material has no reference to the assessee - Held that:- As decided in Sri Pulla Gangadhar Rao, Hyderabad vs. ACIT, Cir.8(1), Hyderabad [2014 (9) TMI 212 - ITAT HYDERABAD] - the documents, ......
2014 (9) TMI 260 - ITAT HYDERABAD
Smt. K. Rajani Kumari, Versus Asst. Commissioner of Income-tax Circle 1, Hyderabad
Amount mentioned in seized diary, part of consideration or not - Assessment u/s 153C - Whether the amount represented, as per the entry in the seized diary, by a pronote, forms part of the consideration for the sale of the property – Held that:- The ......
2014 (9) TMI 212 - ITAT HYDERABAD
Sri Pulla Gangadhar Rao Versus ACIT, Cir-8(1), Hyderabad
Validity of assessment proceedings initiated u/s 153C – Proceedings initiated on seized material – Seized documents belonging to assessee or not - Held that:- The AO could not have initiated proceedings u/s 153C of the Act solely on the basis of the ......
2014 (8) TMI 898 - DELHI HIGH COURT
Pepsico India Holdings Private Limited Versus Assistant Commissioner of Income Tax & Another
Notice u/s 153C – Search and seizure u/s 132(1) – Satisfaction note - Whether the AO of the searched person (the Jaipuria Group) could be said to have arrived at a satisfaction that the documents mentioned above belonged to the petitioners – Held tha ......
2014 (8) TMI 519 - ITAT DELHI
Assistant CIT, Central Circle 17, New Delhi Versus M/s. Pushpanjali Commercial Pvt. Ltd.
Admission of additional evidence – assessment u/s 153C - Unexplained credit - Held that:- CIT(A) has dealt with the issue in detail and after discussing the case of the assessee for admission of the additional evidence has allowed the application of ......
2014 (8) TMI 425 - DELHI HIGH COURT
Pepsi Foods Pvt. Ltd. Versus. Assistant Commissioner of Income Tax
Validity of Notice u/s 153C - issuance of a notice by an AO of a person who has not been searched, on the basis of a satisfaction note prepared by the AO of a searched person - Basic ingredient - satisfaction – Held that:- Assessee rightly contended ......
2014 (7) TMI 638 - ITAT HYDERABAD
M/s SHETTYS PHARMACEUTICALS & BIOLOGICALS LTD Versus DEPUTY COMMISSIONER OF INCOME TAX
Validity of proceedings u/s 153C of the Act – Assessment of income of any other person - Held that:- The provisions contained u/s. 153C of the Act can only be invoked where there was satisfaction by the AO having jurisdiction over the person searche ......
2014 (7) TMI 214 - ITAT BANGALORE
The Himalaya Drug Company, Makali Versus DCIT, Central Circle 1(1), Bangalore
Issuance of notice passed u/s 153C of the Act - Whether the DRP was justified in issuing its directions beyond the time limit specified u/s 144C (12) of the Act and whether the final assessment order passed by the AO u/s 153C of the Act based on the ......
2014 (7) TMI 94 - BOMBAY HIGH COURT
The Commissioner of Income Tax-1 Versus Bharati Vidyapeeth Medical Foundation
Interpretation and construction of section 153C - assessment of another Assessee – search and seizure action was carried out in the case of one Shri Ramchandra Dada Shinde, working as Accounts Officer - Held that:- There is no general rule laid down, ......
2014 (7) TMI 8 - BOMBAY HIGH COURT
The Commissioner of Income Tax-III Versus M/s. Kumar Company
Interpretation of section 153C - power of AO to assess the income of any other person – Transferable development rights - post search and seizure assessment - Held that:- a casual resort to section 153C of the Act is impermissible. There must be som ......
2014 (6) TMI 807 - ITAT COCHIN
The Dy. CIT, Cent. Cir. 2, Ernakulam Versus Shri KP. Varghese
Estimation of profit in real estate business – proceedings u/s 153BC - search and seizure operations - Held that:- the satisfaction of the assessing officer has to emerge from the material found during the course of search operation. - During the cou ......