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Documents citing The Gita Education Society, Delhi vs Ito, Exemption Ward, Ghaziabad on 22 May, 2019

Lahoria Education Society, Hisar vs Ito (E), Rohtak on 31 March, 2023

9. We have heard the rival submissions and perused the material available on record. The issue in the present ground is with respect to the addition of Rs.1,46,000/-. It is the case of the revenue that from 292 students who were studying in class 9 th and 10th, Assessee had charged fees @ Rs.2500/- from each student but had accounted for the fees at Rs.2000/- from each student. To support the addition, AO had relied on the statement of Hema Dang, Accountant of the Society. We find that to support the assessee's contentions that the fee that has been charged to have been accounted for and there is no unaccounted fee, assessee had placed various details before the authorities but we find there is no finding of the authorities on the evidences furnished by the assessee to demonstrate the contention of the assessee being wrong. We find that the addition has been made on the basis of the statement of the accounted recorded u/s 133A of the Act. It is a settled law that statement recorded during the survey operation u/s 133A of the Act may be a relevant material ITA No.5228//Del/2019 Lahoria Education Society vs. ITO(E) 6 but in the absence of further materials to substantiate it, the statement recorded u/s 133A of the Act could not be the basis for making addition. Considering the totality of the aforesaid facts, we are of the view that the AO was not justified in making the addition. We therefore direct its deletion. Thus the ground of assessee is allowed.
Income Tax Appellate Tribunal - Delhi Cites 11 - Cited by 0 - Full Document

M/S Hardik Resort Pvt. Ltd, Niwari vs Pr. Cit, Gwalior on 14 June, 2021

COMMISSIONER OF INCOME TAX ITAT, PUNE TRIBUNAL (B),Shri Atul Gupta vs ACIT, Delhi - ITA No.3384/Del/2019Dev ITA No. 358/Agra/2019 10 Milk Foods (P) Ltd vs. Addl CIT, Delhi ITA No.6767/Del/2019, Shri Sitaram Swami vs. ITO, Ward 4(5), Jaipur ITA no.73/JP/2020,Shri H.N. Ravindra vs ITO ITA No.1065/Bang/2019 an Suresh Jugraj Mehta vs. Addl CIT, Range -3, Dhule ITA No.05/PUN/2016.
Income Tax Appellate Tribunal - Agra Cites 45 - Cited by 0 - Full Document

Assistant Commissioner Of Income Tax, ... vs Shri Bajrang Power And Ispat Ltd., ... on 29 May, 2024

In the case of Gita Education Society Vs. Income Tax Officer (2019) 56 CCH 0064 (Delhi Tribunal) it was held that " Wherever first proviso to section 147 is applicable, the reasons recorded should show in what manner the assessee had failed to make a full and true disclosure of all material facts necessary for the assessment. The failure to do so would not be more irregularity but it would render the reopening of assessment after four year invalid.
Income Tax Appellate Tribunal - Raipur Cites 56 - Cited by 0 - Full Document
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