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R.D. Foundation, Ghaziabad vs Ito (Exemption), Ward, Ghaziabad on 5 February, 2019

CIT vs. Shri Ram Narain Goel (1997) 224 ITR 0180 (P&H) 20 6.3 On the other hand, Ld. Sr. DR relied upon the assessment order and CIT(A)'s order and relied upon the decision of Hon'ble Delhi High Court in the case of DCIT vs. NDR Promoters P. Ltd. ITA No. 49/2018 dated 17.01.2019, 6.4 We have perused the entire material, which is before us and we find that assessee has brought sufficient material on record to prove that lenders have confirmed the amount of loans, which have been given through banking channel and the lenders were assessed to tax and that the loans have substantially been repaid back through banking channel. We would like to refer to various pages of the paper book relied upon by Ld. Counsel in the synopsis at page 8-9-10. We have gone through the various pages of the paper book as referred by Ld. Counsel and we are of the considered opinion that not only the identity and creditworthiness of the lenders stand proved but also the genuineness of the loans stands proved.
Income Tax Appellate Tribunal - Delhi Cites 23 - Cited by 1 - Full Document

M/S. Sudiva Spinners Private Limited,, ... vs Acit, Circle, Bhilwara on 18 January, 2024

 PCIT Vs. Nitin Spinners Ltd. (130 taxmann.com 40 2) (SC)  M/s B. R. Agrotech L td. Vs. ACIT in ITA No. 6244 to 6247/Del/2019, order dated 02.09.2021  DCIT Vs. Kashmir Steel Rolling Mills in ITA No. 130/Asr./2014, order dated 16.01.2015  M/s Nulux Engineers Vs. DCIT in ITA No. 2073/Mum/2017, order dated 05.10.2018  M/s Sudiva Spiners Pvt. Ltd. Vs. DCIT in ITA Nos. 65 & 66/Jo dh/2018
Income Tax Appellate Tribunal - Jodhpur Cites 15 - Cited by 0 - Full Document

Dcit Cc-1(3),Kolkata, Kolkata vs Rungta Mines Limited, Kolkata on 15 December, 2023

13. The contention of the department in most cases that when MAM is taken as CUP, we need not determine a tested party is erroneous in our humble submissions. The ICAI in Guidance note u/s. 94B of the Act has laid down that the tested party must be identified even when MAM is CUP. This proposition and reliance on the ICAI's Guidance Note that the tested party must be identified even when the MAM is CUP was given credence in the case of DCIT v. BalrampurChini Mills Ltd. (ITA No. 1672/ K/ 19) (A.Y. 2016-
Income Tax Appellate Tribunal - Kolkata Cites 43 - Cited by 0 - Full Document

Dcit, Kol. , Kolkata vs Rungta Mines Limited, Kolkata on 14 December, 2023

13. The contention of the department in most cases that when MAM is taken as CUP, we need not determine a tested party is erroneous in our humble submissions. The ICAI in Guidance note u/s. 94B of the Act has laid down that the tested party must be identified even when MAM is CUP. This proposition and reliance on the ICAI's Guidance Note that the tested party must be identified even when the MAM is CUP was given credence in the case of DCIT v. BalrampurChini Mills Ltd. (ITA No. 1672/ K/ 19) (A.Y. 2016-17), order dated 05.05.2021 & Star Paper Mills Ltd. v. DCIT (ITA No. 127/ K/ 21) (A.Y.: 2016-17), order dated 26.10.2021.
Income Tax Appellate Tribunal - Kolkata Cites 42 - Cited by 0 - Full Document

Dcit, Cc-1(3), Kolkata, Kolkata vs Rungta Mines Limited, Kolkata on 15 December, 2023

13. The contention of the department in most cases that when MAM is taken as CUP, we need not determine a tested party is erroneous in our humble submissions. The ICAI in Guidance note u/s. 94B of the Act has laid down that the tested party must be identified even when MAM is CUP. This proposition and reliance on the ICAI's Guidance Note that the tested party must be identified even when the MAM is CUP was given credence in the case of DCIT v. BalrampurChini Mills Ltd. (ITA No. 1672/ K/ 19) (A.Y. 2016-
Income Tax Appellate Tribunal - Kolkata Cites 43 - Cited by 0 - Full Document
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