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Shorya Trading Company Pvt. Ltd. vs. ACIT

Case No: ITA No.1365/Del/2022
Court: INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH ‘G’: NEW DELHI
Date: 2/21/2025

Parties Involved

appellantShorya Trading Company Pvt. Ltd.
respondentACIT, Central Circle, Karnal

Facts Summary

The assessee, Shorya Trading Company Pvt. Ltd., filed its return of income for Assessment Year 2017-18 declaring a total income of Rs. 870/-. Subsequently, proceedings under section 153A were initiated by the department, and an assessment was completed on 31.12.2019 under section 143(3) read with section 153A(1)(b) of the Act, adding Rs. 8,10,000/- as unexplained cash credits under section 68. The assessee appealed this order before the Ld. Commissioner of Income Tax (Appeals)-3, Gurgaon, which was dismissed. The assessee then filed the present appeal before the tribunal, contending that no search under section 132 was conducted, and only a survey under section 133A was carried out, hence no proceedings under section 153A could be initiated.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether a search under section 132 was conducted on the assessee to justify proceedings under section 153A.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

16 precedents cited in this judgement.

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Shorya Trading Company Pvt. Ltd. vs. ACIT | ITA No.1365/Del/2022 | 2025 | Opakhya