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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
C.N. PRASAD, Judicial Member, M. BALAGANESH, Accountant Member
Shayam Gupta – Appellant
Versus
DCIT – Respondent
| Table of Content |
|---|
| 1. assessee appeals against cit(a) orders for ay 2018-19 to 2021-22. (Para 1 , 2) |
| 2. satisfaction note under s.153c lacks bearing on total income determination. (Para 3 , 4 , 5 , 6 , 9 , 10) |
| 3. revenue defends satisfaction note as properly recording unaccounted transactions. (Para 7 , 8) |
| 4. invalid s.153c satisfaction quashes assessments following precedents. (Para 11 , 12) |
| 5. assessments quashed for all years; appeals partly allowed. (Para 13 , 14 , 15) |
ORDER
PER C.N. PRASAD, JM,
These appeals are filed by the assessee against different orders of the Ld.Commissioner of Income Tax (Appeals)-30, New Delhi for the A.Y’s 2018-19 to 2021-22.
2. We first take the appeal for the A.Y. 2018-19 and the grounds of appeal are as under :-
1. On the facts and circumstances of the case and in law, the notice u/s 153C issued by the assessing officer is bad- in-law, barred by limitation and without jurisdiction and, therefore, the said notice along with the assessment order passed on the foundation of such notice are liable to be quashed and CIT(A) erred in not holding so.
2.On the facts and circumstances of the case and in law, the notice u/s 153C issued by the assessing officer is illegal
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