TMI Blog2019 (12) TMI 90X X X X Extracts X X X X X X X X Extracts X X X X ..... an Agreement to Sell was unearthed wherein the Respondent assessee was the seller and Dinesh Kaushal was the purchaser. The Assessing Officer assumed jurisdiction on the premise that the said document belonged to the assessee. On this aspect, the position of law is covered against the Revenue by the decision in Pepsico India Holding Pvt. Ltd v. Assistant Commissioner of Income Tax and Anr. [ 20 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ail the common order dated 05.01.2018 passed by the Income Tax Appellate Tribunal, Delhi Bench C‟, New Delhi in a batch of ITAs. 2. The present appeals relates to the assessment years 2005-06 and 2006-07. The Tribunal has dismissed the appeal preferred by the Revenue against the order of the CIT (A) to delete the additions sought to be made by the Assessing Officer after issuance o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ITR 295 Del. On this short ground, the impugned order passed by the Tribunal is liable to be sustained. Even otherwise, we find that the Assessing Officer did not make any additions on the basis of the agreement dated 05.09.2006 attributed to the assessee. The Assessing Officer proceeded to make additions dehors the said agreement, which in any event, was not justified. 4. We, therefor ..... X X X X Extracts X X X X X X X X Extracts X X X X
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