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Jun 24 2003

Amarjit Singh Bakshi (Huf) Vs. Assistant Commissioner of Income

Court : Income Tax Appellate Tribunal ITAT Delhi

Decided on : Jun-24-2003

Subject : Direct Taxation

Reported in : (2003)263ITR75(Delhi)

The effective hearing in both these cases were started on 5th Oct., 2000 and finally they were completed on 1st June, 2001.Detailed arguments were put … assessment under Section 143(3) has already been completed and an addition of Rs. 6,83,50,000 have been made under Section 69B of the IT Act. It was further noticed by the AO that this addition was made on protective … a further opportunity was given to the assessee.A copy of Annexure A-3 was given to the assessee. Some informations were received from the bank. An extract of those informations were also given to the assessee for filing

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Jan 17 2001

Paramount Enterprises Ltd. Vs. Deputy Commissioner of Income Tax

Court : Income Tax Appellate Tribunal ITAT Delhi

Decided on : Jan-17-2001

Subject : Direct Taxation

account seized and as such there was no undisclosed income.13. It was further submitted that there was no information available to establish or allege that the transactions of purchases of shares of M/s HDC Ltd. resulting into … same was deleted by the Tribunal vide its order dt. 26th July, 2000, which according to him established beyond doubt that the shares were genuinely … asst. yr. 1995-96 and another ground for the addition of Rs. 65,609 made by invoking the provisions of Section 69B of the IT Act for the asst. yr. 1996-97. The last ground taken by the assessee is against

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Nov 22 2005

G.G. Diamond International Vs. Deputy Commissioner of Income Tax

Court : Income Tax Appellate Tribunal ITAT Mumbai

Decided on : Nov-22-2005

Subject : Direct Taxation

Reported in : (2006)104TTJ(Mum.)809

Investigation Wing of the Department at Surat.Investigation revealed that none of the parties are in existence. No local information was available regarding these parties. AO further noted from the bank accounts of these parties that there were … sales in the earlier year. Assessee-firm came into existence on 7th Jan., 2000 and this is the second year of assessee's business.3. AO held, in … as your unexplained investment within the meaning of the provisions of Sections 69B and 69C of IT Act, 1961. You are, therefore, requested to file … appellant. 6. The CIT(A) has erred in confirming the disallowance of Rs. 1,29,77,912 under Section 40A(3) of the Act being 20 per cent of alleged cash purchase of Rs. 6,45,88,956 and also adding the said amount to

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Dec 21 2004

S. Bangarappa (Huf) Vs. Deputy Commissioner of Income Tax

Court : Income Tax Appellate Tribunal ITAT

Decided on : Dec-21-2004

Subject : Land Acquisition

Reported in : (2005)96TTJ(Bang.)662

in cost of construction of the residential house of the assessee at Shimoga by invoking the provisions of Section 69B of the IT Act, 1961 (hereinafter referred to as "the Act"). It was submitted that the assessee had … of construction at Rs. 9,66,516. The AO, relying on the report, made an addition of Rs. 4,16,516. On first appeal, CIT(A) granted pertial relief to the assessee by order dt. 27th Nov., 2002, directing the AO to

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Aug 27 2007

Amit Estate Organizer Vs. Income Tax Officer

Court : Income Tax Appellate Tribunal ITAT Ahmedabad

Decided on : Aug-27-2007

Subject : Direct Taxation

Reported in : (2008)113TTJ(Ahd.)1018

2003 (for asst. yrs. 1995-96, 1996-97 and 1998-99) and on 28th Jan., 2000 for asst. yr. 1997-98. (ii) The second issue is with respect to … that proceedings under Section 147 of the Act. for asst. yr. 1997-98 were initiated without there being any information/material with the Revenue which could make the AO to have reasons to believe that a particular income had … (4) For the proposition that if regular books of accounts are maintained, no addition can be made under Section 69B/69C only on the basis of the report of the DVO. (i) Nishant Housing Development (P) Ltd. v. Asstt.

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Jul 15 2005

Assistant Commissioner of Income Vs. Nalanda Housing Development Ltd.

Court : Income Tax Appellate Tribunal ITAT Rajkot

Decided on : Jul-15-2005

Subject : Direct Taxation

Reported in : (2005)98TTJ(Rajkot.)518

what proportion of the total built-up area was constructed during the previous year. In the absence of this information comparison of consumption of various materials vis-a-vis the extent of construction is not possible, and the extent of … him. Section 69 is attracted when the investment is not at all reflected in the books of account. Section 69B applies where the AO finds that the amount expended on making investment exceeds the amount recorded in the … Solitary ground of appeal in the asst. yr. 1991-92 relates to CIT(A)'s action in deleting the addition of Rs. 25,51,227 made under Section 69C of

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Nov 14 2002

Babros Machinery Mfrs. (P) Ltd. Vs. Deputy Commissioner of Income Tax

Court : Income Tax Appellate Tribunal ITAT Ahmedabad

Decided on : Nov-14-2002

Subject : Direct Taxation

Reported in : (2003)84ITD91(Ahd.)

income for the block period, the provisions of Sections 68, 69, 69A, 69B and 69C may be applied but nowhere it is provided in this … is asst. yrs, 1986-87 to 1995-96 and 1st April, 1995 to 8th Sept., 1995.3. In respect of the first point of difference, the facts as noted by the AO are as under: "Undisclosed income for asst. yr. … the AO who is Dy. CIT(A) Special Range-2, Ahmedabad, under Section 158BD r/w Section 158BC(c) of the IT Act, 1961 for the Block Period asst. yrs. 1986-87 to 1995-96 and 1st April, 1995 to 8th Sept., 1995.2.

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Dec 20 2004

Niranjan Thakur Vs. Joint Commissioner of Income Tax

Court : Income Tax Appellate Tribunal ITAT Mumbai

Decided on : Dec-20-2004

Subject : Direct Taxation

Reported in : (2005)94TTJ(Mum.)253

in a block period, the Tribunal held that returns might be invalid being out of time, but the information contained therein was certainly a valid information given by the assessee to the AO long time before the … All the statements, copies were given to the assessee on 17th Nov., 2000 only and assessee was asked to submit further details or opportunities but … counsel also referred to deeming provisions contained in Sections 68, 69, 69A, 69B, 69C and 69D of the IT Act, 1961. It is submitted that … appeal of the assessee is directed against the order under Section 158BC r/w Section 254 of the IT Act, 1961 for the block period 1st April, 1986 to 12th Sept., 1996. The grounds taken in appeal are

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Jan 05 2004

Om Prakash Sharma Vs. Deputy Commissioner of

Court : Income Tax Appellate Tribunal ITAT Jaipur

Decided on : Jan-05-2004

Subject : Direct Taxation

Reported in : (2004)83TTJ(JP.)246

the agriculture income at very lower side. The learned AO has not considered all the important facts and information gathered by the two different inspectors in the spot inquiries conducted by them in respect of agriculture income. … income-tax computed in accordance with Section 113. But this First Schedule is subject to Section 2 of Finance Act, 2000. Section 2 of the Finance Act provides that the rates specified in Part I of the First Schedule are … for such investments. (e) In the cases falling under Sections 69, 69A, 69B and 69C, the phraseology used goes to show that before any addition

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Jan 25 2006

Parshuram D. Patil Vs. Assistant Commissioner of Income

Court : Income Tax Appellate Tribunal ITAT Mumbai

Decided on : Jan-25-2006

Subject : Direct Taxation

Reported in : (2006)103TTJ(Mum.)765

the undisclosed income of the block period, provisions of Sections 68, 69A, 69B and 69C shall so far as may be applied and reference to … of the architect's letter (written to the assessee) dt. 1st Dec, 1989 is extracted below- This is to inform you that as per our discussion, we have visited the site thoroughly, bearing Land Survey No. 165 (Part), … March, 2002 passed by Asstt. GIT, Central Circle-2, Thane, under Section 158BC(c) r/w Section 254 of the IT Act.2. IT(SS)A Nos. 222 and 223/Mum/2004-The following grounds of appeal (as concised) have been raised in these appeals- 1.

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