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Delhi High Court - Orders

Pr. Commissioner Of Income Tax -7, Delhi vs Naveen Kumar Gupta on 2 November, 2022

Author: Manmohan

Bench: Manmohan, Manmeet Pritam Singh Arora

                              $~45
                              *      IN THE HIGH COURT OF DELHI AT NEW DELHI
                              +      ITA 401/2022, CAV 351/2022 & CM APPL. 44470/2022
                                     PR. COMMISSIONER OF INCOME
                                     TAX -7, DELHI                          ..... Appellant
                                                   Through: Mr. Puneet Rai, Senior Standing
                                                            Counsel for Revenue with Ms.
                                                            Adeeba Mujahid and Mr. Nikhil Jain,
                                                            Advocates.
                                                   versus

                                     NAVEEN KUMAR GUPTA                                   ..... Respondent
                                                          Through:     Mr. Kapil Goel, Advocate (through
                                                                       Video Conferencing).

                              CORAM:
                              HON'BLE MR. JUSTICE MANMOHAN
                              HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA
                                                          ORDER

% 02.11.2022 CAV 351/2022 Since appearance has been entered on behalf of the Respondent, the caveat stands discharged.

CM APPL. 44470/2022 (for exemption) Exemption allowed, subject to all just exceptions. Accordingly, the present application stands disposed of.

ITA 401/2022

Learned counsel for the Appellant states that the Income Tax Appellate Tribunal (ITAT) has erred in holding that Section 153C of the Income Tax Act, 1961 ('the Act') has an overriding effect on Section 147 of the Act.

Signature Not Verified Digitally Signed By:JASWANT SINGH RAWAT Signing Date:03.11.2022 18:24:50

He states that the ITAT has erred in holding that the amended Section 153C w.e.f. 01st June, 2015 has been overlooked by Assessing Officer. He submits that the amended Section 153C is not applicable in this case because the incriminating material seized did not belong to the Assessee but revealed his undisclosed income.

Issue notice. Mr. Kapil Goel, learned counsel for the Respondent, accepts notice. He prays for and is permitted to place on record the documents which formed a part of the Court record below. Let the needful be done before the next date of hearing.

List on 18th May, 2023.

MANMOHAN, J MANMEET PRITAM SINGH ARORA, J NOVEMBER 02, 2022/msh Signature Not Verified Digitally Signed By:JASWANT SINGH RAWAT Signing Date:03.11.2022 18:24:50