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M/S Luxmi Builders, Chandigarh vs Dcit, Chandigarh on 16 May, 2024

Further, reliance is placed upon the decision of Hon'ble Allahabad High Court in the case of SD Traders vs CIT, Income tax Appeal no. 159/2016 delivered on 3.9.2019 where it was held that the CIT (A) has power of enhancement u/s 251 of the Act to consider new source of income which was not dealt by the AO in the assessment order. It is further, mentioned here that power of the CIT (A) are co- terminus with the AO and it has been held by Hon'ble Supreme Court in the case of Kanpur Coal Syndicate 53 ITR 225 that the Appellate Assistant Commissioner has, therefore, plenary powers in disposing of an appeal, the scope of his power is conterminous with that of the income-tax Officer and he can do what the Income-tax Officer can do and also direct him to do what her has failed to do so. In view of these facts, it is held that there is no merit in the submission of the assessee firm filed in response to show cause notice issued to the assessee firm (supra) u/s 25 I of the Act.
Income Tax Appellate Tribunal - Chandigarh Cites 68 - Cited by 0 - Full Document

M/S Ganesh Builders, Panchkula vs Dcit, Cc-1, Chandigarh on 16 May, 2024

Further, reliance is placed upon the decision of Hon'ble Allahabad High Court in the case of SD Traders vs CIT, Income tax Appeal no. 159/2016 delivered on 3.9.2019 where it was held that the CIT (A) has power of enhancement u/s 251 of the Act to consider new source of income which was not dealt by the AO in the assessment order. It is further, mentioned here that power of the CIT (A) are co- terminus with the AO and it has been held by Hon'ble Supreme Court in the case of Kanpur Coal Syndicate 53 ITR 225 that the Appellate Assistant Commissioner has, therefore, plenary powers in disposing of an appeal, the scope of his power is conterminous with that of the income-tax Officer and he can do what the Income-tax Officer can do and also direct him to do what her has failed to do so. In view of these facts, it is held that there is no merit in the submission of the assessee firm filed in response to show cause notice issued to the assessee firm (supra) u/s 25 I of the Act.
Income Tax Appellate Tribunal - Chandigarh Cites 68 - Cited by 0 - Full Document

M/S Luxmi Builders, Chandigarh vs Dcit, Chandigarh on 16 May, 2024

Further, reliance is placed upon the decision of Hon'ble Allahabad High Court in the case of SD Traders vs CIT, Income tax Appeal no. 159/2016 delivered on 3.9.2019 where it was held that the CIT (A) has power of enhancement u/s 251 of the Act to consider new source of income which was not dealt by the AO in the assessment order. It is further, mentioned here that power of the CIT (A) are co- terminus with the AO and it has been held by Hon'ble Supreme Court in the case of Kanpur Coal Syndicate 53 ITR 225 that the Appellate Assistant Commissioner has, therefore, plenary powers in disposing of an appeal, the scope of his power is conterminous with that of the income-tax Officer and he can do what the Income-tax Officer can do and also direct him to do what her has failed to do so. In view of these facts, it is held that there is no merit in the submission of the assessee firm filed in response to show cause notice issued to the assessee firm (supra) u/s 25 I of the Act.
Income Tax Appellate Tribunal - Chandigarh Cites 68 - Cited by 0 - Full Document

M/S Ganesh Builders, Panchkula vs Dcit, Cc-1, Chandigarh on 16 May, 2024

Further, reliance is placed upon the decision of Hon'ble Allahabad High Court in the case of SD Traders vs CIT, Income tax Appeal no. 159/2016 delivered on 3.9.2019 where it was held that the CIT (A) has power of enhancement u/s 251 of the Act to consider new source of income which was not dealt by the AO in the assessment order. It is further, mentioned here that power of the CIT (A) are co- terminus with the AO and it has been held by Hon'ble Supreme Court in the case of Kanpur Coal Syndicate 53 ITR 225 that the Appellate Assistant Commissioner has, therefore, plenary powers in disposing of an appeal, the scope of his power is conterminous with that of the income-tax Officer and he can do what the Income-tax Officer can do and also direct him to do what her has failed to do so. In view of these facts, it is held that there is no merit in the submission of the assessee firm filed in response to show cause notice issued to the assessee firm (supra) u/s 25 I of the Act.
Income Tax Appellate Tribunal - Chandigarh Cites 68 - Cited by 0 - Full Document
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