TaxTMI 
TaxTMI 
2021 (2) TMI 1137
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.... Assessed Income 3807/Del/2016 Amit Gupta 2010-11 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 ....
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....e 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. 31,64,000/- arbitrarily and on ad hoc basis despite the fact that there was no evidence with the assessing 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. 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. ....
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....n 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. 6. 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.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 pr....
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.... 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. 31,64,000/- arbitrarily and on ad hoc basis despite the fact that there was no evidence with the assessing 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.3812/Del/2016 1. The learned CIT (A) e....
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....ecting 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. 6. 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.3813/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 ....
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.... appeal against the order of assessing officer and confirming the addition of Rs. 28,32,100/- arbitrarily and on ad hoc basis despite the fact that there was no evidence with the assessing 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.3816/Del/2016 1. The learned CIT (A) erred in law and on facts in dismissing the appeal against the order of as....
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....e 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. 6. 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.3817/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 cour....
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....ppellant 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 and 234D 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.3821/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 ....
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....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. 10,46,261/- 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 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 l....
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.... 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.3826/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. 28,32,100/- arbitrarily and on ad hoc basis despite the fact that there was no evidence with the assessing officer about the expenditure was incurred by the appellant for ....
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....er of the learned CIT (A), passed merely on surmises and conjecture should be reversed. 4. 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. 2,24,000/- 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. 5. 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. 6. The appellant craves the leave to add, substitute, ....