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Documents citing Sumati Dayal vs Commissioner Of Income-Tax, Bangalore on 28 March, 1995

Income Tax Officer, Jaipur vs Kedia Builders And Colonizers Private ... on 11 March, 2025

Established judicial precedents emphasizing the importance of substance over form in determining the genuineness of transactions. Judicial principles laid down in landmark rulings such as NRA Iron & Steel Pvt. Ltd. v. PCIT [(2019) 416 ITR 135 (SC)], Sumati Dayal v. CIT [(1995) 214 ITR 801 145 ITA No. 872 & others/JP/2024 Kedia Builders and Colonizers Pvt. Ltd., Jaipur (SC)], and CIT v. Nova Promoters and Finlease Pvt. Ltd. [(2012) 342 ITR 169 (Del.)] uniformly support the additions made by the AO in cases involving shell companies, accommodation entries, and tax evasion.
Income Tax Appellate Tribunal - Jaipur Cites 117 - Cited by 0 - Full Document

Income Tax Officer, Jaipur vs Kedia Builders And Colonizers Private ... on 11 March, 2025

Established judicial precedents emphasizing the importance of substance over form in determining the genuineness of transactions. Judicial principles laid down in landmark rulings such as NRA Iron & Steel Pvt. Ltd. v. PCIT [(2019) 416 ITR 135 (SC)], Sumati Dayal v. CIT [(1995) 214 ITR 801 145 ITA No. 872 & others/JP/2024 Kedia Builders and Colonizers Pvt. Ltd., Jaipur (SC)], and CIT v. Nova Promoters and Finlease Pvt. Ltd. [(2012) 342 ITR 169 (Del.)] uniformly support the additions made by the AO in cases involving shell companies, accommodation entries, and tax evasion.
Income Tax Appellate Tribunal - Jaipur Cites 117 - Cited by 0 - Full Document

Income Tax Officer (Gopal Lal ... vs Kedia Builders And Colonizers Private ... on 11 March, 2025

Established judicial precedents emphasizing the importance of substance over form in determining the genuineness of transactions. Judicial principles laid down in landmark rulings such as NRA Iron & Steel Pvt. Ltd. v. PCIT [(2019) 416 ITR 135 (SC)], Sumati Dayal v. CIT [(1995) 214 ITR 801 145 ITA No. 872 & others/JP/2024 Kedia Builders and Colonizers Pvt. Ltd., Jaipur (SC)], and CIT v. Nova Promoters and Finlease Pvt. Ltd. [(2012) 342 ITR 169 (Del.)] uniformly support the additions made by the AO in cases involving shell companies, accommodation entries, and tax evasion.
Income Tax Appellate Tribunal - Jaipur Cites 117 - Cited by 0 - Full Document

Income Tax Officer, Jaipur vs Kedia Builders And Colonizers Private ... on 11 March, 2025

Established judicial precedents emphasizing the importance of substance over form in determining the genuineness of transactions. Judicial principles laid down in landmark rulings such as NRA Iron & Steel Pvt. Ltd. v. PCIT [(2019) 416 ITR 135 (SC)], Sumati Dayal v. CIT [(1995) 214 ITR 801 145 ITA No. 872 & others/JP/2024 Kedia Builders and Colonizers Pvt. Ltd., Jaipur (SC)], and CIT v. Nova Promoters and Finlease Pvt. Ltd. [(2012) 342 ITR 169 (Del.)] uniformly support the additions made by the AO in cases involving shell companies, accommodation entries, and tax evasion.
Income Tax Appellate Tribunal - Jaipur Cites 117 - Cited by 0 - Full Document

Income Tax Officer, Jaipur vs Kedia Builders And Colonizers Private ... on 11 March, 2025

Established judicial precedents emphasizing the importance of substance over form in determining the genuineness of transactions. Judicial principles laid down in landmark rulings such as NRA Iron & Steel Pvt. Ltd. v. PCIT [(2019) 416 ITR 135 (SC)], Sumati Dayal v. CIT [(1995) 214 ITR 801 145 ITA No. 872 & others/JP/2024 Kedia Builders and Colonizers Pvt. Ltd., Jaipur (SC)], and CIT v. Nova Promoters and Finlease Pvt. Ltd. [(2012) 342 ITR 169 (Del.)] uniformly support the additions made by the AO in cases involving shell companies, accommodation entries, and tax evasion.
Income Tax Appellate Tribunal - Jaipur Cites 117 - Cited by 0 - Full Document

Napar Drugs Pvt. Ltd. vs Dcit on 30 November, 2005

18. The learned Counsel argued that there was lot of overlapping in the questions framed by the Hon'ble Judicial Member. Those questions were more of academic interest than any real controversy arising on the facts and in the circumstances of the case. The allegations contained in those questions that the arguments of the learned DR had not been considered m the order made by the Hon'ble Accountant Member were not correct. In the order written by Hon'ble Accountant Member there were references to the arguments of the learned DR at various places. The Accountant Member had recorded, "The learned DR present in the proceedings admits that facts, circumstances and issues are identical and has not shown any new or distinguishing findings of the Assessing Officer." In other words the learned DR himself accepted that the facts of the case in the present appeal wee identical to appeals in various other cases already decided by the Tribunal and that there were no distinguishable facts. Thus, the assumption of the Hon'ble Accountant Member that this appeal was already covered by the earlier orders of the Tribunal was not rebutted by the learned DR. It was also not correct to say that the decisions relied upon by the Assessing Officer and the learned D.R., viz, CIT v. Durga Prasad More 82 ITR 540 (SC) and Sumati Dayal v. CIT 214 ITR 801 (SC) had not been considered by the Hon'ble Accountant Member. There was considerable discussion in relation to the reliance placed by the revenue on these two judgments. The Accountant Member rightly concluded that the assessee had discharged his initial onus and, therefore, it was revenue's burden to prove that the apparent state of affairs was not true. Reliance in this behalf was placed on the judgment of Hon'ble Supreme Court in the case of Daulat Ram Rawat Mull 87 ITR 349 (SC). That burden of revenue could not be discharged by merely citing the judgments in 82 ITR 540(SC) and 214 ITR 801(SC) where the facts were different. The Hon'ble Accountant Member had himself recorded that facts of those cases were distinguishable. The learned Counsel argued that in the present case there was no material to hold against the assessee. The revenue had made the assessment order entirely on suspicion. It was settled law that suspicion howsoever strong, cannot take place of evidence, 224 ITR 180 (P & H).
Income Tax Appellate Tribunal - Delhi Cites 93 - Cited by 13 - Full Document

Smt. Sabreen, Kanpur vs Income Tax Officer-3(4), Kanpur on 20 July, 2021

Similarly, the case of Sumati Dayal v. CIT (supra) too turns on its own specific facts. The above-stated cases, thus, are of no assistance to the case sought to be canvassed by the Revenue. 13. The learned ITAT, being the last fact-finding authority, on the basis of the evidence brought on record, has rightly come to the conclusion that the lower tax authorities are not able to sustain the addition without any cogent material on record. We thus find no perversity in the Impugned Order. 14. In this view of the matter, no question of law, much less a substantial question of law arises for our consideration. 15. Accordingly, the present appeals are dismissed."
Income Tax Appellate Tribunal - Lucknow Cites 28 - Cited by 1 - Full Document

Mewar Hospital Pvt. Ltd. , Udaipur vs Acit, Central Circle-2, Udaipur on 12 October, 2023

In support of the ground the ld. DR representing the Revenue submitted that possibility of human probability decided by the apex court in the case of Sumati Dayal vs. CIT (1995) 214 ITR 801 shall squarely covered the case of the assessee. The ld. DR submitted the detailed finding of the ld. AO recorded in the assessment order be confirmed. The ld. DR also submitted that the addition has been made based on the details submitted by the assessee and the same is not disputed. The ld. AO 58 ITA Nos.
Income Tax Appellate Tribunal - Jodhpur Cites 53 - Cited by 0 - Full Document
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