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 ......
2014 (6) TMI 442 - ITAT COCHIN
DEPUTY COMMISSIONER OF INCOME TAX Versus M/s DAMAC HOLDINGS PVT LTD
Validity of assessment u/s 153C of the Act – wrong description of the designation in the notice - Held that:- The search was conducted in the premises of Mohiyuddin is none other than the director of both the companies - Shri Mohiyuddin was describe ......
2014 (5) TMI 362 - GUJARAT HIGH COURT
Rajhans Builders Versus Dy. Commissioner of Income Tax & 1
Validity of petition u/s 153C of the Act - Validity of Reference made to DVO – Valuation of immovable properties – Held that:- At this stage no interference is called for - Section 153C of the Act pertains to assessment of income of persons other tha ......
2014 (5) TMI 355 - ITAT MUMBAI
Mrs. Savia J. Purohit Versus Asstt. Commissioner of Income Tax
Addition made u/s 68 of the Act – Unexplained cash credits – Loans received from various persons – Admission of additional evidences - Held that:- The assessee has received loans from 47 persons in cash during the financial year – the cash loans aggr ......
2014 (5) TMI 199 - BOMBAY HIGH COURT
Commissioner of Income Tax-III, Pune Versus M/s. Kumar Company
Substantial question of law - Sale of Transferable Development Rights (TDRs) - Jurisdiction of the AO to issue notice u/s 153C of the Act - Quantification of profit on sale of TDR - Proper sale rate per sq.ft of TDR – Held that:- The Tribunal has cor ......
2014 (5) TMI 158 - ALLAHABAD HIGH COURT
Commissioner of Income Tax (Central) Versus M/s. Gopi Apartment
Block Assessment - Requirement to record the satisfaction – Proceeding u/s 153A & 153C versus 158BC, 158BD - Notice to be issued u/s 158BD of the Act - Notice for undisclosed income of any other person - At what stage of the proceedings under Chapter ......
2014 (5) TMI 109 - ITAT DELHI
ASSTT COMMISSIONER OF INCOME TAX AND DEPUTY COMMISSIONER OF INCOME TAX Versus M/s SARAYA INDUSTRIES LTD
Validity of assessment u/s 153C r.w. section 153A of the Act – Incriminating documents - Held that:- The common satisfaction was recorded by the AO for initiation of proceedings u/s 153C of the Act in respect of the 19 parties - action u/s 133A of th ......
2014 (4) TMI 966 - ITAT DELHI
ACIT, Central Circle4, New Delhi Versus M/s. Prithvi Sound Products Co. Pvt. Ltd.
Deletion of disallowance u/s 24 of the Act – Expenses of interest on borrowed capital – Whether the addition cane be made u/s 153A/153C of the Act without any incriminating documents - Held that:- CIT(A)’s order is quite elaborate and he has clearly ......
2014 (4) TMI 933 - ITAT AGRA
Smt. Nirmala Devi Keshwani and others Versus DCIT., Central Circle Agra
Validity of proceedings u/s 153C of the Act – Income from house property and income from capital gain – Held that:- The decision in Hardevi Keshwani Versus A. CIT, Central Circle, Agra [2013 (8) TMI 105 - ITAT AGRA] followed - No satisfaction note ha ......