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Section 153C Fails for Want of Proper Satisfaction: Entire Search Assessment Quashed
Case Law Details
- Case Name
- Nirvaja Enterprises Private Limited Vs ACIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2017-18
- Courts
- All ITAT, ITAT Delhi
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Nirvaja Enterprises Private Limited Vs ACIT (ITAT Delhi)
Search action in Himanshu Verma group led AO to treat Assessee company as one of 200 alleged shell entities & initiate proceedings u/s 153C for AYs 2012-13 to 2018-19 on the basis of a single consolidated satisfaction note. AO made additions treating bank credits as accommodation entries & estimated commission income @4% plus further addition @1%, which were upheld by CIT(A).
ITAT quashed entire proceedings holding that mandatory jurisdictional conditions of section 153C were not satisfied. Tribunal noted that sa...
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