9911796707
TMI Blog2024 (11) TMI 1271X X X X Extracts X X X X X X X X Extracts X X X X ..... uted statutory appeals, the details of which are extracted below, before the Commissioner of Income Tax (Appeals). They would also confirm that they have raised all necessary grounds in those appeals, including on the aspect of assumption of jurisdiction We see no reasons to entertain these writ appeals as the appellants are seen to be riding two horses, which is impermissible. Hence, these writ appeals are dismissed. It is made clear that none of the observations made by the learned Judge in order dated 18.01.2024 will stand in the way of the appellant in the adjudication of the appeals, that shall be decided in accordance with law. Addition of amount of unexplained income to the accounts of both the directors - appellants is primarily agg ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... als have been filed. 3.Both learned counsel would bring to the notice of the Court that post institution of the writ appeals, the appellants have instituted statutory appeals, the details of which are extracted below, before the Commissioner of Income Tax (Appeals). They would also confirm that they have raised all necessary grounds in those appeals, including on the aspect of assumption of jurisdiction. Sl. No. WA.No. WP.No. AY Impugned order passed under section 153C of the I.T.Act Appeal No. before CIT (Appeals)-20, Chennai CIT(Appeal) filed on MANEESH PARMAR 1 WA.No.3328/2024 WP.No.13117/2023 AY 2018-19 Assessment order passed under section 153C of the I.T.Act in ITBA/AST/S/153C/2022-23/1051782000 (1) dated 31.03.2023 CIT (Appeals) Chen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... der section 143(3) r.w.s. 153C of the I.T. Act in ITBA/AST/M/153C/2022-23/1051819382 (1) dated 31.03.2023 CIT (Appeals) Chennai-20/10099/2017-18 11.05.2024 4 WA.No.1315/2024 WP.No.14387/2023 AY 2020-21 Assessment order passed under section 143(3) r.w.s. 153C of the I.T. Act in ITBA/AST/M/153C/2022-23/1051819631 (1) dated 31.03.2023 CIT (Appeals) Chennai-20/10118/2019-20 11.05.2024 5 WA.No.1339/2024 WP.No.14391/2023 AY 2021-22 Assessment order passed under section 143(3) r.w.s. 153C of the I.T. Act in ITBA/AST/M/153C/2022-23/1051819746 (1) dated 31.03.2023 CIT (Appeals) Chennai-20/10094/2020-21 11.05.2024 G.RAJENDRAN 1 WA.No.1274/2024 WP.No.12688/2023 AY 2019-20 Assessment order passed under section 143(3) r.w.s. 153C of the I.T. Act in ITBA ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... .05.2024 5 WA.No.1384/2024 WP.No.13443/2023 AY 2021-22 Assessment order passed under section 143(3) r.w.s. 153C of the I.T. Act in ITBA/AST/M/153C/2022-23/1051814982 (1) dated 31.03.2023 CIT (Appeals) Chennai-20/10092/2020-21 11.05.2024 ORIGINAL KERALA JEWELLERS 1 WA.No.1379/2024 WP.No.13609/2023 AY 2018-19 Assessment order passed under section 153C of the I.T. Act in DIN Order No. ITBA/AST/S/153C/2022-23/1051724039 (1) dated 31.03.2023 CIT (Appeals) Chennai-20/10098/2017-18 11.05.2024 2 WA.No.1452/2024 WP.No.13619/2023 AY 2020-21 Assessment order passed under section 153C r.w.s 143(3) of the I.T.Act in DIN Order No.ITBA/AST/M/153C/2022-23/1051728053(1) dated 31.03.2023 CIT (Appeals) Chennai-20/10116/2019-20 11.05.2024 3 WA.No.1454/2024 WP. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... .From reading the tables, the amount of unexplained income for the Assessment year 2019-2020, 2020-2021 and 2021-2022 has been added to the accounts of both the directors of M/s.KLP Projects Private Limited, i.e., Manish Parmar and Mr. Sunil Khetpalia. 115.Therefore, the Impugned Orders in W.P. 13119, 13125, 13129, 16431, 12018, 12021 of 2023 are liable to be quashed and cases are remanded back to the respondents to redo the exercise by adding the unexplained income under Section 69A of the Income Tax Act, 1961 to the income of the Petitioner. 116.Therefore, to the extent of the impugned orders dated 31.03.2023, in the case of the respective assessment order under Section 153C read with Section 143(3) of the Income Tax Act, 1961 of the abov ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
