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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
SHRI ANUBHAV SHARMA, J, SHRI MANISH AGARWAL, ACJ
M/s. Ace Mega Structures Pvt. Ltd. – Appellant
Versus
DCIT – Respondent
| Table of Content |
|---|
| 1. cross-appeals are linked due to common issues. (Para 1 , 2) |
| 2. revenue's reliance on past statements is inadequate without corroboration. (Para 4 , 5 , 19) |
| 3. assessment conclusions must be based on verified evidence. (Para 6 , 7 , 30) |
| 4. assessor's procedural adherence is crucial for validity of findings. (Para 12 , 28) |
| 5. strong evidentiary basis is needed for tax assessments. (Para 20 , 21) |
ORDER
PER MANISH AGARWAL, AM:
The captioned cross-appeal filed by the Revenue and assessee are arising from order dated 15.04.2025 of the Ld. Commissioner of Income Tax (Appeals)-3, Noida [“Ld. CIT(A)”] passed under s. 250 of the Income Tax Act, 1961 [the Act] emanating from the assessment orders dated 31.03.2024 passed u/s 147 r.w.s. 143(3) of the Act by the Assessing Officer [“AO”] pertaining to AY 2019-20.
2. As the captioned cross-appeals filed by the Revenue and the assessee are having common issues of addition made u/s 68 of the Act, wherein in all the entries of loans received from one company M/s Hallow Securities Pvt Ltd. was doubted and addition was made thus, the issues involved in both appeals are inter-linked, inter-connected. This fact has been admitted by both the
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