TaxTMI 
TaxTMI 
2026 (6) TMI 282
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..../s 250 of the Income Tax Act, 1961 (hereinafter referred to as "the Act") for A.Y. 2018-19 and 2019-20, respectively. 2. The Revenue has raised following grounds of appeal: ITA No. 9072/Del/2025 "1. On the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the addition of Rs. 95,00,000/- made under section 69C of the Income Tax Act, 1961 by not appreciating the fact that there is a specific information with the Department that assessee has entered into transaction (accommodation entry) with M/s Mahavir Prasad Suresh Kumar, who used to indulge in providing accommodation entries in the form of bogus sales or purchases. 2. On the facts and circumstances of the case and in law, the....
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.... the eye of law and on facts. 2. (i) On the facts and circumstances of the case, NFAC has erred both on facts and in law in confirming the order passed by the A.O. despite the fact that there is no proper sanction for initiation of proceedings under section 148 of the Act, as provided under section 151 of the act. (ii) That the sanction has been stated to be taken from Pr. CIT, despite the fact that the reopening has been initiated after a period of three years from the end of relevant assessment year, therefore the same should have been taken from Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General, as provided under clause (ii) of section 151 of the Act." A.Y. 2018-19 (....
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....te Limited v. ACIT CC22(2), Delhi & Anr. -W.P.(C) 14237/2022 - Delhi High Court 2. Ajay Duggal v. ITO, Ward-72 (1), Delhi ITA No. 5612/Del/2024 - Delhi ITAT 3. Niraj Versus ITO, Ward- 2 (3) (1), Delhi ITA No. 3308/Del/2025 - Delhi ITAT 4. Saif Ali Mansoor Ali Khan Pataudi v. ACIT, Circle-16 (1), Mumbai ITA No. 2131/MUM/2025 - Mumbai ITAT 5. M/s RS Construction v. ITO Ward 41(3)(3), Mumbai ITA No. 4918/Mum/2025 - Mumbai ITAT 4.2 On the other hand, ld. DR has strongly relied on the orders of the lower authorities. 5. We have heard the rival submissions and perused the material placed on record. From the copies of order u/s 148A(d) and notice u/s 148 filed by the assessee, it is apparent that the sanct....
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....mmencement of the Finance Act, 2021:" (emphasis supplied) 46. The ingredients of the proviso could be broken down for analysis as follows: (i) no notice under Section 148 of the new regime can be issued at any time for an assessment year beginning on or before 1 April 2021; (ii) if it is barred at the time when the notice is sought to be issued because of the "time limits specified under the provisions of" 149(1)(b) of the old regime. Thus, a notice could be issued under Section 148 of the new regime for assessment year 2021-2022 and before only if the time limit for issuance of such notice continued to exist under Section 149(1)(b) of the old regime." 5.1 In view of above factual and legal position, we hold that the....
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.... also a beneficiary of bogus transactions with the entities of Sh. Ashok Kumar Gupta viz. M/s Mahavir Prasad Suresh Kumar and M/s Madan Lal Madhav Prasad. 7.1 On the other hand, ld. AR has argued that all the requisite documentary evidences to establish the genuineness of impugned transactions had been filed, based on which ld. CIT(A) has rightly allowed relief to the assessee. 8. We have heard the rival submissions and perused the material placed on record including the supporting evidences regarding purchase and transaction of goods from the entities in question. We further note that based on the documentary evidences filed by the assessee, ld. CIT(A) has allowed relief by passing a speaking and reasoned order. Relevant portion of h....