Vinay Homes Pvt. Ltd. vs DCIT

Parties Involved

Facts Summary

The assessee, Vinay Homes Pvt. Ltd., filed an appeal against the order of the Ld. Commissioner of Income Tax (A)-24, New Delhi, which dismissed the assessee's appeal against the assessment order dated 28.12.2021. The assessment order made additions of INR 4,75,00,000/- towards unexplained credit u/s 68 of the Act and INR 14,25,000/- for unexplained expenditure. The assessee argued that the 'Satisfaction Note' recorded by the AO was defective and did not specifically pertain to the assessee, thus invalidating the jurisdiction assumed under section 153C of the Act.…

Legal Issues

• 1. Invalid assumption of jurisdiction under section 153C
• 2. Defects in the 'Satisfaction Note'
• 3. Reliance on external material

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

Similar Judgements

• Assistant Commissioner of Income Tax, CC-30, Room No.320, 3rd Floor, ARA Centre, Jhandewalan Extension, New Delhi-110055 Vs E-Homes Infrastructure Private Limited, DASNA Annexe I ECE House, 28A, Connaught Place, S.O. Central Delhi, New Delhi-110001

  Delhi Bench benchAY 2020-21Dismissed

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