2025 (3) TMI 2059

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....s 'ld. CIT(A)', in short] in Appeal No. 0099/2013-14 dated 05.06.2015 against the order of assessment passed u/s 147/143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') dated 30.03.2013 by the Assessing Officer, DCIT, Circle-5(1), New Delhi (hereinafter referred to as 'ld. AO'). 2. The only issue raised by the assessee in its cross objection is that the reopening of assessment has been made by the ld AO without obtaining proper sanction u/s 151 of the Act from the competent authority. 3. We have heard the rival submissions and perused the material available on record. The ld DR at the time of hearing placed on record the relevant papers received from the ld AO in respect of approval obtained u/s 151 of the Act be....

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....d in the open court on 19/03/2025. ============= Document 1 FORM FOR RECORDING REASONS FOR INITIATING PROCEEDINGS U/S 147 AND FOR OBTAINING SANCTION OF COMMISSIONER OF INCOME TAX U/S 151 OF IT ACT.1961. 1. Name of the Assessee M/s. Kanodia Technoplast (P) Ltd. A-54,Wazirpur Industrial Area, Delhi - 110052 2. PAN AAACK3668F 3 Status Company 4. Circle Circle-5(1), New Delhi. 5. Assessment Year in respect of which it is proposed to issue notice u/s 148. 2005-06 6 The quantum of income which has escaped assessment. Under assessment of income of Rs.2,49,20,000/- 7. Whether the provisions of section 147(a) or 147(b) are applicable or both the sections are applicable. No 8 Whether the assessment is proposed to be made for the first ....

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.....2008. During the course of survey operation the transactions made by the assessee with M/s Super Plastic Coats Pvt Ltd were found to be regularly accounted for in the books of the assessee and no difference was noticed in the purchase transactions. 2. During the course of survey operation in the case of the assessee loose paper and computer hard disk were also impounded as per Annexure A which contained seven documents annexurised as annexure A-1 to A-7. On examination of annexure A-4 consisting of pages 1 to 58 it was revealed that the assessee company has raised share capital/share application money from the different entities during the Previous Years 2004-05 to 2007-08 relevant to A Y 2005-06 to 2008-09. Annexure A-3 which contained....