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S.N. Arora/Sapra, New Delhi vs Ito, Ward- 23(2), New Delhi on 30 January, 2020

9.5. The crux of the above Judgments had been that, in case, incorrect, wrong and non-existing reasons are recorded by the A.O. for reopening of the assessment and that A.O. failed to verify the information received from Investigation Wing, the reopening of the assessment would be unjustified and is liable to be quashed. The ITAT, F- Bench, New Delhi in the case of Shri Pankaj Sapra, New Delhi vs., ITO, Ward-23(2), New Delhi (supra) in para-9 held as under :
Income Tax Appellate Tribunal - Delhi Cites 18 - Cited by 1 - Full Document

M/S Shri Shyam Sunder Infrastructure ... vs Ito, New Delhi on 19 May, 2021

7.4. The crux of the above Judgments had been that, in case, incorrect, wrong and non-existing reasons are recorded by the A.O. for reopening of the assessment and that A.O. failed to verify the information received from Investigation Wing, the reopening of the assessment would be unjustified and is liable to be quashed. The ITAT, F- Bench, New Delhi in the case of Shri Pankaj Sapra, New Delhi vs., ITO, Ward-23(2), New Delhi in ITA.No.5747/ Del./2018 vide Order Dated 22.11.2009 on identical facts 20 ITA.No.2106/Del./2013 Shri Shyam Sunder Infrastructure (P) Ltd., [Formerly known as M/s. Shalom Exim (P) Ltd., and then as Mamram Developers P. Ltd.,] Delhi.
Income Tax Appellate Tribunal - Delhi Cites 37 - Cited by 1 - Full Document

Daya Sapra, New Delhi vs Ito Ward- 23(2), New Delhi on 27 February, 2023

7.2.1 The Hon'ble Coordinate Bench of the Tribunal in the case of Pankaj Sapra Vs. ITO {ITA no. 5747/Del/2018 for A.Y. 2008-09} also considered the said facts to the effects that in the case of Shri S.N. Sapra, husband of the Assessee, the AO vide order dated 19.3.2014 passed u/s 143(3)/147 of the act, also made addition of Rs. 46,00,000/- with respect to the same property no. 1481 C.R. Park, New Delhi which was purchased by Shri S.N. Sapra vide agreement dated 13.09.2005 from Shri Nilambar Rudra Pal and ultimately vide its order dated 22.11.2019, quashed the Assessment order by holding that reasons given by the AO in notice u/s 148 of the Act are merely mechanical and the AO have not given any concrete reasons as to why the reopening is justified, therefore was not right in reopening the assessment.
Income Tax Appellate Tribunal - Delhi Cites 10 - Cited by 0 - Full Document

Pankaj Saha & Co., Kolkata vs I.T.O.,Ward-26(4), Kolkata on 12 February, 2020

2. The assessee's only grievance canvassed in the instant appeal seeks to reverse both the lower authorities' action disallowing its labour payments of ₹3,05,878/- out of ₹94,56,753/- expenditure after noticing discrepancies in muster roll preparation and other ancillary issues. I notice during the course of hearing that neither the assessee has been able to prove the impugned payments by way of cogent evidence nor it is the Revenue's case that the same involved any abnormal element of expenditure ITA No.2513/Kol/2019 A.Y. 2015-16 Pankaj Saha & Co. Vs. ITO Wd-26(4),Kol. Page 2 compared to earlier and latter assessment years. I therefore deem it appropriate to restrict the impugned disallowance of ₹3,05,878/- to lump sum figure of ₹50,000/- with a rider that the same shall not be treated as a precedent in any other assessment year. The assessee gets part relief. Necessary consequential computation to follow as per law.
Income Tax Appellate Tribunal - Kolkata Cites 2 - Cited by 0 - Full Document
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