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Documents citing Smt. Mridula Agarwal, Kanpur vs Deputy Commissioner Of Income Tax, ... on 5 April, 2022

Acit, Meerut vs Sh. Ramesh Dhingra, Meerut on 30 September, 2022

in the case of Smt Lalita Rani Gupta Vs ACIT as well as the decision of Delhi ITAT in the case of Manoj Agarwal Vs Dy.CIT (2008) 117 TTJ (Del) (SB) 145 which were rightly relied upon by the respondent and approved by CIT(A) while allowing the appeal of the respondent, therefore, the respondent fully rely upon the appellate order of CIT(A) & support the order.
Income Tax Appellate Tribunal - Delhi Cites 32 - Cited by 0 - Full Document

T. Vijayakumar (Indl). , Trichy vs Department Of Income Tax

19. The issue with regard to recording of satisfaction in the notice under s. 158BD has also been considered by the Page 16 of 18 I.T.SS.A. No. 13 & 14/Mds/2010 Tribunal Special Bench in case of Manoj Aggarwal vs. Dy. CIT (supra) wherein it was held that for initiating action under s. 158BD, first and foremost requirement is that the AO making block assessment of a person searched, has to be satisfied that undisclosed income detected belongs to some other person other than the person searched and, thus, section itself contemplates satisfaction on the part of the AO making assessment in case of person searched; recording of satisfaction is mandatory and imperative before assuming of jurisdiction under s. 158BD. It was further observed that note of satisfaction must contain positive finding by the AO making assessment under s. 158BC indicating therein undisclosed income found as a result of his examination of seized material and the person to whom searched income belongs.
Income Tax Appellate Tribunal - Chennai Cites 15 - Cited by 0 - Full Document

Shri Harkishan Narottamdas Chokshi, ... vs The Pr. Cit Jamnagar, Jamnagar on 4 June, 2024

6. The Ld.DR, on the other hand, vehemently relied upon the order of the Ld.PCIT and also supported the section 69 of the Act r.w.s.115BBE of the Act. The Ld.DR further submitted that before the survey authorities, the assessee's submission was that there is difference between weight of the goods and value of the goods. The Ld.DR also submitted that the additional stock should not be assessed as "business income" of the assessee. The Ld.DR has relied upon the decision of ITAT Delhi Bench "A" in the case of Manoj Aggarwal vs. Deputy Commissioner of Income Tax in IT(SS)A No.404/Del/2003, for block period 1991- 92 to 20/08/2000, dated 25/07/2008, wherein it has held as under:-
Income Tax Appellate Tribunal - Rajkot Cites 18 - Cited by 0 - Full Document
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