2026 (1) TMI 613

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....s. Harpreet Kaur Hansra, Sr. DR. ORDER PER SUDHIR KUMAR, JM: This appeal by the assessee is directed against the order of Commissioner of Income Tax (Appeals)-31 New Delhi, [hereinafter referred to as "CIT(A)"], vide order dated 27.10.2020 pertaining to A.Y. 2006-07 arising out of the assessment order dated 28-03-2014 passed by the Assessing Officer under Section 147/143(3) of the Income ....

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....ssioner of Income Tax Appeals) while sustaining the addition of Rs. 80,80,000/- have failed to appreciate the fact that the reasons have been recorded by the learned Assessing officer only on the basis of information received from Investigation Wing without any independent application of mind and that the approval have also been given by the Addl. CIT range -8 new Delhi in a mechanical manner." ....

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....ly on the basis of information received from Investigating wing without any independent application of mind and the approval was also granted by the Addl. CIT,. Range -8 New Delhi in a mechanical manner. Reliance is placed on the following decisions: (i) In the case of ITO vs. Virat Credit & Holdings Pvt. Ltd. ITA no. 89/Del/2012 the co-ordinate bench in para no 12 held that "App....

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....tels Pvt. Ltd. v. ITO 338 ITR 0051 (Delhi) (iv) Chiranjiv Lal vs. ITO 54 ITR (Trib) -349 (Amritsar) (v) Sh. Kishan Chand Madan v. Income Tax officer ward-68(1) New Delhi ITA NO 2900/Del/2023 7. Ld. Authorized Representative of the Revenue relied upon the orders of the below authorities. She submitted that the approval was granted in a prescribed manner after perusing the mater....