decision of Hon'ble Supreme Court
in the case of Mak Data Pvt. Ltd. Vs. CIT reported in 358 ITR 593
is applicable. Referring ... rejoinder submitted
that the decision in the case of Mak Data (P) Ltd. (Supra) is
distinguishable and not applicable to the facts of the present
Supreme Court in
the case of MAK Data (P) Ltd. Vs. CIT (2013) 358 ITR 593
(SC) for the proposition that the surrender made ... also made to distinguish the facts of
the case of MAK Data (P) Ltd. (supra) from the facts of the
present case.
9. We have
Apex Court in the case of MAK Data
Page 1 of 10
HC-NIC Page 1 of 10 Created ... relied upon the decision of the Supreme Court in case of
MAK Data (P) Ltd. v. CIT , reported in 358 ITR 593. He
also relied
decision of Hon'ble
Supreme Court in the case of MAK Data (P) Ltd. v. CIT [2013] 38
taxmann.com 448 (SC) and submitted ... relied on by the ld. D.R. in the case of MAK Data (P) Ltd (supra). and
Virender K Mehta(supra). The ld. Counsel
Suprme Court in the case of MAK Data (P) Ltd. Vs. CIT 358
ITR 593 (SC) wherein it was held that satisfaction is not required ... Supreme Court in the case of MAK Data (supra) and held that in the
absence of initiation of penalty proceedings in the order of assessment
Suprme Court in the case of MAK Data (P) Ltd. Vs. CIT 358
ITR 593 (SC) wherein it was held that satisfaction is not required ... Supreme
Court in the case of MAK Data (supra) and held that in the absence of initiation of
ITA Nos.1320,1321/K/2011
Supreme Court in the case of Mak Data P. Ltd. vs. CIT (2013) 358 ITR 593
(SC); Union of India vs. Dharmendra Textile Processors ... facts under consideration are
concerned. In Mak Data P. Ltd. (supra), there was a survey conducted in
case of that assessee's sister concern
ratio
laid down by the Hon'ble Supreme Court in MAK Data P. Ltd. Vs. CIT in Civil
Appeal No.9772 of 2013, judgment ... crores. He further stated that the facts in MAK Data P. Ltd. Vs. CIT (supra) were
different, where additional income was detected but no declaration
Supreme
Court in the case of MAK Data Pvt. Ltd. vs. CIT as reported in 358 ITR
593. It has been held ... Supreme Court decision in the case of MAK Data Pvt. Ltd. vs. CIT (2013)
358 ITR 593 (SC). The surrender of income in the revised
this
contention, the ld. DR placed following case laws.
(i) Mak Data P Ltd. vs. CIT, 358 ITR 539 (SC)
( ii) Badri Prasad Om Prakash ... Counsel for the assessee submitted that the case
of Mak Data P Ltd. vs. CIT , 358 ITR 539 (SC) may help the assessee