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Reopening u/s 147 Invalid Without Failure to Disclose Material Facts – ITAT Deletes Addition u/s 69B for Alleged Undisclosed Investment | Sunil Aggarwal v. ITO (ITAT Delhi)
Facts of the CaseThe assessee, Sunil Aggarwal, filed his return of income
declaring total income of ₹13,14,870. The return was processed under Section
143(1) of the Income Tax Act, 1961. Subsequently, the Assessing O...
ITAT Delhi: Relief to Assessee Where Additions Were Made Without Proper Evidence – Deepak Kumar vs ITO (Section 68 of Income Tax Act)
Facts of the CaseThe assessee, Shri Deepak Kumar, filed his return of income
declaring the income for the relevant assessment year. The case was selected
for scrutiny and assessment proceedings were initiated by the As...
Reassessment Invalid Without Mandatory Notice u/s 143(2): ITAT Deletes Addition u/s 69 for Alleged Unexplained Investment – Deepak Kumar vs CIT(A) NFAC
Facts of the CaseThe assessee filed his return of income declaring income of
₹6,46,010. Subsequently, the case was reopened by the Assessing Officer on the
basis of information that the assessee had purchased an immo...
Labvantage Solutions Inc vs DCIT – ITAT on Taxability of Software / Technical Services Income in India under the Income-tax Act & DTAA
Facts of the CaseThe assessee, Labvantage Solutions Inc, a non-resident
company, was engaged in providing specialized software solutions and related
services to customers in India. The assessee received payments from I...
Labvantage Solutions Inc vs DCIT – ITAT on Taxability of Software / Technical Services Income in India under the Income-tax Act & DTAA
Facts of the CaseThe assessee, Labvantage Solutions Inc, a non-resident
company, was engaged in providing specialized software solutions and related
services to customers in India. The assessee received payments from I...
ITAT Delhi: Assessment under Section 153C Cannot Survive Without Valid Incriminating Material – DCIT vs Apple Commodities Ltd.
Facts of the CaseA search action was conducted in the case of the Apple Group
of companies, during which certain documents were seized. Based on the seized
material, the Assessing Officer initiated proceedings against ...
DCIT vs Gynia Holding Ltd. (ITAT Delhi) – Invalidity of Assessment u/s 153C for Absence of Separate Satisfaction Note and Mandatory Draft Assessment Order u/s 144C | AY 2006-07 to 2011-12
Facts of the CaseA search and seizure operation was conducted on 22.03.2012
under Section 132 of the Income Tax Act, 1961 in the case of the Focus Energy
Group. During the course of the search, certain documents allege...
Initiation of Proceedings u/s 153C Invalid Where Assessment Years Fall Beyond Permissible Six-Year Period – DCIT vs Wickwood Development Ltd (ITAT Delhi)
Facts of the CaseA search and seizure action under Section 132 of the Income
Tax Act was conducted on 22.03.2012. During the search proceedings, certain
documents were allegedly found relating to Wickwood Development L...
ITAT Delhi: Proceedings under Section 153C Invalid Without Proper Satisfaction Note – DCIT vs Rolland Enterprises Ltd.
Facts of the CaseA search and seizure operation under Section 132 of the Income
Tax Act, 1961 was conducted on 22.03.2012 in relation to certain entities.
During the course of the search, certain documents and material...
Twylight Infrastructure Pvt Ltd vs Income Tax Officer (Delhi High Court) – Reassessment Notice Quashed for Lack of Sanction by Correct Specified Authority under Section 151(ii)
Facts of the CaseThe petitioners filed their income-tax returns for Assessment Years 2016-17 and 2017-18, which
were processed under Section 143(1) of
the Income Tax Act, 1961.Later, the Income Tax Department initiated...