TaxTMI 
TaxTMI 
TaxTMI 
2021 (2) TMI 1137
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.... Rs. 37,03,294/- 3806/Del/2016 Amit Gupta 2008-09 Rs. 31,51,191/- 3808/Del/2016 Amit Gupta 2011-12 Rs. 1,69,47,018/- 3809/Del/2016 Amit Gupta 2012-13 Rs. 57,40,046/- 3810/Del/2016 Vibha Gupta 2008-09 Rs. 31,77,787/- 3811/Del/2016 Vibha Gupta 2010-11 Rs. 32,03,202/- 3812/Del/2016 Vibha Gupta 2011-12 Rs. 1,60,40,127/- 3813/Del/2016 Vibha Gupta 2012-13 Rs. 50,42,588/- 3814/Del/2016 Uma Gupta 2008-09 Rs. 39,26,723/- 3815/Del/2016 Uma Gupta 2010-11 Rs. 28,92,688/- 3816/Del/2016 Uma Gupta 2011-12 Rs. 1,60,73,233/- 3817/Del/2016 Uma Gupta 2012-13 Rs. 51,71,869/- 3819/Del/2016 Ashish Gupta 2006-07 Rs. 12,39,128/- 3820/Del/2016 Ashish Gupta 2011-12 Rs. 15,90,613/- 3821/Del/2016 Ashish Gupta 2012-13 Rs. 4,97,527/- 3822/Del/2016 Devanshi Amit Gupta 2006-07 Rs. 12,22,824/- 3823/Del/2016 Devanshi Amit Gupta 2011-12 Rs. 14,72,083/- 3824/Del/2016 Devanshi Amit Gupta 2012-13 Rs. 6,85,623 /- 3825/Del/2016 Surender Gupta 2008-09 Rs. 33,28,096/- 3826/Del/2016 Surender Gupta 2010-11 Rs. 43,66,401/- 3827/Del/2016 Surender Gupta 2011-12 Rs. 1,57,98,589/- 3828/Del/2016 Surender Gupta 2012-13 Rs. 76,34,996/- 3.0 Aggrieved....
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....he expenditure was incurred by the appellant for the purchase of share capital. Moreover, no incriminating documents were found during the course of search and in respect of which no proceedings were abated. The addition was made purely on presumptive basis. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be reversed. 3. The learned CIT (A) erred in law and on facts in rejecting the ground of the appellant on non-applicability of provisions of Section 234B of the Income Tax Act despite the fact that said provisions are not applicable. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be reversed. The appellant craves the leave to add, substitute, modify, delete or amend all or any ground of appeal either before or at the time of hearing. Grounds of appeal in ITA No.3808/Del/2016 1. The learned CIT (A) erred in law and on facts in dismissing the appeal against the order of assessing officer without giving the adequate opportunity to the appellant. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be reversed. 2. The learned CIT (A) erred in law and on facts in dismissi....
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.... of appeal either before or at the time of hearing. Grounds of appeal in ITA No.3809/Del/2016 1. The learned CIT (A) erred in law and on facts in dismissing the appeal against the order of assessing officer without giving the adequate opportunity to the appellant. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be reversed. 2. The learned CIT (A) erred in law and on facts in dismissing the appeal against the order of assessing officer and confirming the addition of Rs. 48,00,000/- arbitrarily and on ad hoc which appellant is a director, is bogus. Further, Company and its directors are two different entities. Moreover, no incriminating documents were found during the course of search. The addition was made purely on presumptive basis. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be reversed. 3. The learned CIT (A) erred in law and on facts in rejecting the ground of the appellant on non-applicability of provisions of Section 234B of the Income Tax Act despite the fact that said provisions are not applicable. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be rev....
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....resumptive basis. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be reversed. 3. The learned CIT (A) erred in law and on facts in rejecting the ground of the appellant on non-applicability of provisions of Section 234B of the Income Tax Act despite the fact that said provisions are not applicable. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be reversed. 4. The appellant craves the leave to add, substitute, modify, delete or amend all or any ground of appeal either before or at the time of hearing. Grounds of appeal in ITA No.3812/Del/2016 1. The learned CIT (A) erred in law and on facts in dismissing the appeal against the order of assessing officer without giving the adequate opportunity to the appellant. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be reversed. 2. The learned CIT (A) erred in law and on facts in dismissing the appeal against the order of assessing officer and confirming the addition of Rs. 1,12,00,000/- arbitrarily and on ad hoc basis despite the fact that works was done by the Company in which appellant is a director. There was no evidenc....
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....ortunity to the appellant. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be reversed. 2. The learned CIT (A) erred in law and on facts in dismissing the appeal against the order of assessing officer and confirming the addition of Rs. 48,00,000/- arbitrarily and on ad hoc basis despite the fact that works was done by the Company in which appellant is a director. There was no evidence with the assessing officer about the transaction of the company, in which appellant is a director, is bogus. Further, Company and its directors are two different entities. Moreover, no incriminating documents were found during the course of search. The addition was made purely on presumptive basis. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be reversed. 3. The learned CIT (A) erred in law and on facts in rejecting the ground of the appellant on non-applicability of provisions of Section 234B of the Income Tax Act despite the fact that said provisions are not applicable. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be reversed. 4. The appellant craves the leave to add, substitute,....
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....he Income Tax Act despite the fact that said provisions are not applicable. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be reversed. 4. The appellant craves the leave to add, substitute, modify, delete or amend all or any ground of appeal either before or at the time of hearing. Grounds of appeal in ITA No.3816/Del/2016 1. The learned CIT (A) erred in law and on facts in dismissing the appeal against the order of assessing officer without giving the adequate opportunity to the appellant. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be reversed. 2. The learned CIT (A) erred in law and on facts in dismissing the appeal against the order of assessing officer and confirming the addition of Rs. 1,12,00,000/- arbitrarily and on ad hoc basis despite the fact that works was done by the Company in which appellant is a director. There was no evidence with the assessing officer about the transaction of the company, in which appellant is a director, is bogus. Further, Company and its directors are two different entities. Moreover, no incriminating documents were found during the course of search. The additio....
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.... of Rs. 48,00,000/- arbitrarily and on ad hoc basis despite the fact that works was done by the Company in which appellant is a director. There was no evidence with the assessing officer about the transaction of the company, in which appellant is a director, is bogus. Further, Company and its directors are two different entities. Moreover, no incriminating documents were found during the course of search. The addition was made purely on presumptive basis. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be reversed. 3. The learned CIT (A) erred in law and on facts in rejecting the ground of the appellant on non-applicability of provisions of Section 234B of the Income Tax Act despite the fact that said provisions are not applicable. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be reversed. 4. The appellant craves the leave to add, substitute, modify, delete or amend all or any ground of appeal either before or at the time of hearing. Grounds of appeal in ITA No.3819/Del/2016 1. The learned CIT (A) erred in law and on facts in dismissing the appeal against the order of assessing officer without givin....
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....w and on facts in dismissing the appeal against the order of assessing officer without giving the adequate opportunity to the appellant. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be reversed. 2. The learned CIT (A) erred in law and on facts in dismissing the appeal against the order of assessing officer and confirming the addition of Rs. 44,120/- arbitrarily and on ad hoc basis despite the fact that services were provided by the Company in which appellant is a director. There was no evidence with the assessing officer about the transaction of the company, in which appellant is a director, is bogus. Further, Company and its directors are two different entities. Moreover, no incriminating documents were found during the course of search. The addition was made purely on presumptive basis. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be reversed. 3. The learned CIT (A) erred in law and on facts in rejecting the ground of the appellant on non-applicability of provisions of Section 234D of the Income Tax Act despite the fact that said provisions are not applicable. Thus, order of the learned CIT (A), p....
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....the fact that said provisions are not applicable. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be reversed. 4. The appellant craves the leave to add, substitute, modify of appeal either before or at the time of hearing. Grounds of appeal in ITA No.3824/Del/2016 1. The learned CIT (A) erred in law and on facts in dismissing the appeal against the order of assessing officer without giving the adequate opportunity to the appellant. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be reversed. 2. The learned CIT (A) erred in law and on facts in dismissing the appeal against the order of assessing officer and confirming the addition of Rs. 44,120/- arbitrarily and on ad hoc basis despite the fact that services were provided by the Company in which appellant is a director. There was no evidence with the assessing officer about the transaction of the company, in which appellant is a director, is bogus. Further, Company and its directors are two different entities. Moreover, no incriminating documents were found during the course of search. The addition was made purely on presumptive basis. Thus, order of t....
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....ssessing officer about the expenditure was incurred by the appellant for the purchase of share capital. Moreover, no incriminating documents were found during the course of search and in respect of which no proceedings were abated. The addition was made purely on presumptive basis. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be reversed. 3. The learned CIT (A) erred in law and on facts in rejecting the ground of the appellant on non-applicability of provisions of Section 234B of the Income Tax Act despite the fact that said provisions are not applicable. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be reversed. 4. The appellant craves the leave to add, substitute, modify, delete or amend all or any ground of appeal either before or at the time of hearing. Grounds of appeal in ITA No.3827/Del/2016 1. The learned CIT (A) erred in law and on facts in dismissing the appeal against the order of assessing officer without giving the adequate opportunity to the appellant. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be reversed. 2. The learned CIT (A) erred in l....
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....amend all or any ground of appeal either before or at the time of hearing. Grounds of appeal in ITA No.3828/Del/2016 1. The learned CIT (A) erred in law and on facts in dismissing the appeal against the order of assessing officer without giving the adequate opportunity to the appellant. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be reversed. 2. The learned CIT (A) erred in law and on facts in dismissing the appeal against the order of assessing officer and confirming the addition of Rs. 48,00,000/- arbitrarily and on ad hoc basis despite the fact that works was done by the Company in which appellant is a director. There was no evidence with the assessing officer about the transaction of the company, in which appellant is a director, is bogus. Further, Company and its directors are two different entities. Moreover, no incriminating documents were found during the course of search. The addition was made purely on presumptive basis. Thus, order of the learned CIT (A), passed merely on surmises and conjecture should be reversed. 3. The learned CIT (A) erred in law and on facts in dismissing the appeal against the order of assessing off....