2024 (1) TMI 1512

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...., CA ORDER PER N. K. BILLAIYA, AM: ITA No.2677/Del/2023 and 2678/Del/2023 are two separate appeals by the revenue preferred against the common order of the CIT(A)-3, Gurgaon dated 21.07.2023 pertaining to A.Y. 2011-12 and 2012-13. 2. Since common ground have been taken in both the appeals they were heard together and are disposed of by this common order for the sake of convenience and ....

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....be incriminating material in view of facts had there been no search conducted, aforesaid information could not be passed on to the Department? 4 Whether the decision of Hon'ble Supreme Court in the case PCIT, Central-3 vs Abhisar Buildwell P. Ltd, and in the case of DCIT Vs U.K Paints (Overseas) Ltd., are applicable to this case in view of facts that both the additions are based upon ....

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....hts. After appreciating the submissions of the assessee the AO concluded that the difference between the DVO and as per the books of accounts of the assessee is the income of the assessee and made addition of Rs.2296343/- in A.Y. 2011-12 and Rs.1639995/- in A.Y. 2012-13. 6. Proceeding further the AO noticed that the assessee has received reimbursements from the M3M Group which were not being ro....

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.... time of search. The CIT(A) was convinced that transactions of TDR cannot be considered as incriminating as the same are part of regular books of accounts and income tax return. The CIT(A) further observed that the AO has made examination of transactions recorded in the books of account. 8. Drawing support from the decision of the Hon'ble High Court in the case of Kabul Chawla 61 taxmann.com 41....