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Mahavir Ashok Enterprises (P) Ltd., ... vs D.C.I.T. Central Cricle, Raipur on 29 August, 2022

7. In reply, the assessee assailed the very basis relying on which the A.O had inferred its undisclosed sales and the unaccounted income arising therefrom a/w. the addition towards initial unaccounted investment. It was the claim of the assessee that as the alleged torn pieces of computer printout that was claimed by the department to have been retrieved from a dustbin lying in its shop at Sadar Bazar, Raipur did not find place in the list of seized loose papers/documents that were inventorised during the course of search proceedings, therefore, it had not been able to obtain a photocopy of the same. Once again, the assessee requested for a copy of the seized document, if any, which was being relied upon by the department for inferring undisclosed sales etc. It was further the claim of the assessee that if there was no evidence of seizure of alleged torn papers from its premises, then,there was no justifiable basis for drawing of adverse inferences in its hands. Alternatively, it was submitted 19 DCIT, Central Circle Vs. Mahavir Ashok Enterprises Pvt. Ltd.
Income Tax Appellate Tribunal - Raipur Cites 65 - Cited by 3 - Full Document

Dcit, Cir-12(1), Kolkata, Kolkata vs M/S Bengal Ambuja Housing Development ... on 18 October, 2019

4.11 My conclusion in this regards is supported by the decision of the ITAT, Bangalore in the case of DCIT vs. Brigade Enterprises Pvt. ltd (28 SOT 7) which involved somewhat similar facts. In that case also the assessee executed a project called "B Millennium". The macro project consisted of several housing blocks, community hall, club etc as micro components. The micro project consisted of 5 residential blocks and the assessee obtained approval from the local authority for the entire macro project on a single day. The deduction u/s 80IB(10) was however claimed only in respect of housing blocks being M & C which according to the assessee individually fulfilled conditions prescribed in Sec 80IB(10). The assessee's claim in respect of only 2 residential blocks was rejected by the AO on the ground that the local authority had granted sanction for the entire micro project 4 I.T.A No.1514/Kol/2015 & ITA No. 1515/Kol/2015 A.Ys 2010-11 & 2011-12 M/s. Bengal Ambuja Housing Development Ltd.
Income Tax Appellate Tribunal - Kolkata Cites 44 - Cited by 0 - Full Document
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