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1 - 10 of 32 (0.68 seconds)Section 263 in The Income Tax Act, 1961 [Entire Act]
Section 68 in The Companies Act, 1956 [Entire Act]
Section 133 in The Companies Act, 1956 [Entire Act]
M/S. Pee Aar Securities Ltd., New Delhi vs Dcit, New Delhi on 23 August, 2018
Therefore, it is respectfully be submitted
here that the ratio of the case of Hon'ble
ITAT, New Delhi (A Bench) in the case of
M/s Pee Aar Securities Ltd. Vs. DCIT-
Prabhatam Investment Pvt. Ltd., Delhi vs Acit, New Delhi on 17 April, 2017
- Prabhatam Investment P. Ltd. vs ACIT. (2017) 49 CCH 299
(Del. Trib.).
Section 133 in The Income Tax Act, 1961 [Entire Act]
Commissioner Of Income-Tax, New ... vs East West Import & Export (P) Ltd.,(Now ... on 8 February, 1989
13. In backdrop of aforesaid observations of the Ld CIT(A) in the
present case, it is evident that Ld AO has squirely failed in substantiating
that how the onus cast upon the assessee was not discharges u/s 68 of
the act. AO further erred by neither making any specific comments nor
have demonstrated the reasons for adverse conclusions about the share
subscribers which could be supported with the documents or borne out
from the records. Ld AO also misplaced in her observations by not
distinguishing that how the facts of the present case are different on which
binding judgments in the case of Lovely Exports (supra) and Venkteshwar
Ispat (supra), relied upon by the assessee, are not applicable.
Asst Cit 24(2), Mumbai vs Lovely Fragrances, Mumbai on 7 December, 2018
Under such
facts and circumstances, respectfully following the ratio of law laid down
by Hon'ble Supreme Court in the case of CIT Vs. Lovely Exports(supra)
and was adopted by Hon'ble Jurisdictional High Court of Chhattisgarh in
the Case of M/s Venkateshwar Ispat (supra), we concur with the decision
of the order of Ld CIT(A) having no infirmity, in absence of any divergent
argument advanced by the revenue apart from the contentions raised and
considered herein above, or without any cogent material or decision
having different binding consequence on the instant case, we do not have
any distinct opinion other than that of the opinion of Ld CIT(A), thus, we
order to sustain the same. Resultantly grounds raised in the present
appeal by revenue are dismissed.
Rajmandir Estates Private Limited, ... vs Acit, Central Circle-1(1), Kolkata, ... on 17 August, 2021
• Further in that case, Assessing
Officer did not hold requisite
investigation except for calling for
records, he also did not interrogate
persons behind assessee company
and persons behind subscribing
companies which was essential to
unearth truth
• Further, in that case, the decision of
Calcutta High Court was only in
respect of whether commissioner
was justified in treating assessment
order erroneous and prejudicial to
interest of revenue, against which
SLP was dismissed by the Apex
Court. However there is no decision
as far as genuineness of share-