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1 - 7 of 7 (0.18 seconds)Section 151 in The Income Tax Act, 1961 [Entire Act]
Section 147 in The Income Tax Act, 1961 [Entire Act]
Pr. Commissioner Of Income Tax, ... vs Foryu Overseas (P) Ltd. on 25 November, 2016
13. The Id. AR subm itted that facts on record clearly show that the AO has acted
on suspicion only and not on any credible input available to him through DDIT
(investigation) information or otherwise on the basis of any exercise or application
of mind by himself. Therefore, the reassessm ent proceedings and all consequent
orders are not sustainable and bad in law. Reiterating his earlier arguments, the Id.
AR vehem ently pointed out that the approval/sanction given in para 12 of the
proforma is not a valid sanction as per ratio of the various decisions including
decision of Hon'ble High Court of Madhya Pradesh in the case of S. Goyanka Lime
and chem icals Ltd. (supra), which has been upheld by H on'ble Suprem e Court by
dismissing SLP of the Revenue reported in 237 Taxm an 378 (SC) and therefore,
initiation of reassessm ent proceedings u/s. 147 of the Act, notice u/s. 148 of the
Act, reassessm ent proceedings and all consequent orders may kindly be quashed.
The decisions relied by the Ld. Sr. DR are distinguished on peculiar facts as those
are on prima face belief.
Section 68 in The Income Tax Act, 1961 [Entire Act]
Pr. Commissioner Of Income Tax-4 vs G & G Pharma India Ltd on 8 October, 2015
2) Pr. CIT vs. G & G Pharma India Ltd 384 ITR 147 (Del)
Pr. Commissioner Of Income Tax vs M/S Rmg Polyvinyl (I) Ltd on 2 July, 2018
3) Pr. CIT vs. RMG Polyvinyl (I) (2017) Ltd 396 ITR 5 (Del)
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ITA NO.1221/DEL/2018
Assessment Year: 2008-09
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