Manjinder Singh Sirsa vs DCIT

Parties Involved

Facts Summary

The assessee, Manjinder Singh Sirsa, filed a belated return of income for the Assessment Year 2014-15, declaring a total income of Rs. 5,78,69,041/-. The return was processed under section 143(1) of the Income Tax Act, 1961. The assessee, proprietor of MSR Real Estate, engaged in the business of real estate and builders. The total income comprised income from Capital Gains, Income from Business and Profession, and Income from Other Sources. The case was selected for scrutiny through CASS. Notices under sections 143(2) and 142 of the Act were issued, and the assessee attended the proceedings. An assessment order was passed on 30/12/2016. The assessee filed an appeal before the Commissioner of Income Tax (Appeals), which was dismissed on 26/03/2024.…

Legal Issues

• 1. The validity of the notice issued under section 143(2) of the Act.
• 2. The disallowance of business expenses of Rs 1,95,41,996/- under Section 37 of the Income Tax Act, 1961.
• 3. The order of the Commissioner of Income Tax (Appeals) being a non-speaking order.
• 4. The order of the Commissioner of Income Tax (Appeals) being against natural justice.

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

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