White Orchid Hospitality (P) Ltd. vs. DCIT

Parties Involved

Facts Summary

The case involves an appeal by White Orchid Hospitality (P) Ltd. against the order of the Commissioner of Income-tax (Appeals)-30, New Delhi, which upheld an assessment order by the Assessing Officer (AO) for the Assessment Year 2021-22. The AO had made an addition of Rs. 2 crore under section 69 of the Income Tax Act, 1961, based on an agreement to sell found during a search and seizure action. The assessee argued that the satisfaction notes recorded by the AO were void ab initio and that the assessment order was illegal as it did not follow the proper procedure under section 153C of the Act.…

Legal Issues

• 1. Whether the assessment order passed by the AO under section 153C read with section 143(3) is bad in law.
• 2. Whether the satisfaction notes recorded by the AO were void ab initio.
• 3. Whether the AO erred in not recording separate satisfaction notes for each assessment year.
• 4. Whether the assessment order violated the principles of natural justice by not allowing cross-examination.
• 5. Whether the addition of Rs. 2 crore under section 69A was justified.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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