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Documents citing Commissioner Of Income Tax vs Spl???S Siddhartha Ltd. on 14 September, 2011

Mirabelle International, New Delhi vs Department Of Income Tax on 8 August, 2016

7.1 In the background of the aforesaid discussions and respectfully following the precedent of the Hon'ble High Court of Delhi in the case of CIT vs. SPL's Siddartha ltd. (Supra), we are of the considered view that Ld. CIT(A) has passed a well reasoned order which does not need any interference on our part, hence, we uphold the finding of the Ld. CIT(A) in 12 ITA NO. 2213/DEL/2014 quashing the reassessment and dismiss the grounds raised by the Revenue.
Income Tax Appellate Tribunal - Delhi Cites 16 - Cited by 0 - Full Document

Dcit, New Delhi vs M/S. Sarvodaya Realtors, New Delhi on 21 March, 2017

15. On the basis of the above discussion respectfully following the decision of Hon'ble Bombay High Court in the case of Ghansyam K. Khabarani vs. CIT, reported in 346 ITR 443 and decision of Hon'ble Delhi High Court in the case of CIT vs. SPL Siddhant Ltd reported in 345 ITR 223, we hold that the notice of reopening cannot be held to be sustainable in law. Accordingly grounds raised by the revenue for both assessment years stands dismissed.
Income Tax Appellate Tribunal - Delhi Cites 2 - Cited by 0 - Full Document

Shri Ajaybhai Ishwarlal Gogia,, ... vs The Income Tax Officer, Ward-1 (2) (5), ... on 18 April, 2022

1) [1997] 227 ITR 802 (KER.) in which assessee stood as a guarantor for loan given by 'K' Financial Corporation to 'N' Ltd. and in pursuance of said position, assessee's property was mortgaged in favour of 'K' Financial Corporation. As 'N' Ltd. defaulted in making payment of loan, 'K' Financial Corporation sold property so mortgaged and appropriated sale proceeds towards loan taken by 'N'. The High Court held that since purchasers paid entire sale consideration directly to 'K' Financial Corporation and it was only thereafter mortgaged property was released, sale consideration was diverted to 'K' Financial Corporation by overriding title and, in such circumstances, no capital gains accrued to assessee. The assessee submitted that in the instant case, there was no deliberate default on part of the assessee to conceal income and relying on the case of CIT vs. Siddhartha Enterprise 322 ITR 80, the Ld. counsel for the assessee submitted that unless there is deliberate default on part of the assessee, penalty for concealment cannot be levied.
Income Tax Appellate Tribunal - Rajkot Cites 14 - Cited by 2 - Full Document

Srichand Changlani, Ulhasnagar vs Ito Wd 2(4), Mumbai on 16 November, 2018

Similar is the ratio of decision of Hon'ble Delhi High Court rendered in CIT Vs SPL'S Sidhhartha Ltd. [17 Taxmann.com 138]. 3.5 Respectfully following the wisdom of higher judicial authorities, we concur with the submissions of Ld. AR that the proceedings stood 8 ITA No.1843/Mum/2016 Srichand D. Changlani Assessment Year-2008-09 vitiated for want of proper satisfaction of appropriate authority as envisaged by law and therefore, the same had no legs to stand. By quashing the same, we allow ground number 1 & 3 of the appeal and therefore, ground number 2 does not survive.
Income Tax Appellate Tribunal - Mumbai Cites 12 - Cited by 0 - Full Document
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