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1 - 8 of 8 (1.31 seconds)Section 153A in The Income Tax Act, 1961 [Entire Act]
The Income Tax Act, 1961
Commissioner Of Income Tax-07 vs M/S. Rrj Securities Ltd. on 23 September, 2016
3. One of the principal issues which appears to have been urged
for the consideration of the Tribunal was the commencement point
from which the block period of six years was to be computed. The
Tribunal bearing in mind the judgment rendered by this Court in CIT
vs RRJ Securities [2015 SCC OnLine Del 13085] and other
decisions, held that in the case of non-searched entities, it would be
the date of recordal of satisfaction and not the date of search which
would constitute the commencement point for reckoning the block
period of six years. The Tribunal on facts has further found that
insofar as AY 2012-13 is concerned, and to which alone the seized
material related and could be said to be incriminating, was sought to
ITA 230/2020 & 2/2021 Page 3 of 6
This is a digitally signed order.
Section 153D in The Income Tax Act, 1961 [Entire Act]
Deputy Commissioner Of Income Tax vs M/S Pepsi Foods Ltd. (Now Pepsico India ... on 6 April, 2021
IV. Whether the Hon'ble ITAT has not erred in applying the ratio in
the case of CIT Vs. RRJ Securities Ltd. and Pepsico India Holdings
Pvt. Ltd. and in holding that the conditions mandated u/s 153C of
the Act were not fulfilled in the case, without appreciating the
decision of the Hon'ble Respective High Courts in the cases of
Ganpati Fincap Services Pvt. Ltd. Vs. CIT [2017] 82
TAXMANN.COM 408 (Delhi) and PCIT Vs. Super Malls Pvt. Ltd.
[2016] 76 taxmann.com 267(Delhi)/[2017] 393 ITR 557
(Delhi)/[2017] 291 CTR 142 (Delhi)?
Ganpati Fincap Services Pvt. Ltd vs Commissioner Of Income Tax on 25 May, 2017
IV. Whether the Hon'ble ITAT has not erred in applying the ratio in
the case of CIT Vs. RRJ Securities Ltd. and Pepsico India Holdings
Pvt. Ltd. and in holding that the conditions mandated u/s 153C of
the Act were not fulfilled in the case, without appreciating the
decision of the Hon'ble Respective High Courts in the cases of
Ganpati Fincap Services Pvt. Ltd. Vs. CIT [2017] 82
TAXMANN.COM 408 (Delhi) and PCIT Vs. Super Malls Pvt. Ltd.
[2016] 76 taxmann.com 267(Delhi)/[2017] 393 ITR 557
(Delhi)/[2017] 291 CTR 142 (Delhi)?
Ashlar Commodities Private Limited vs Income Tax Officer Ward 3(1), Delhi And ... on 19 May, 2023
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paragraphs of the said decision read as follows:-
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