PR. COMMISSIONER OF INCOME TAX -CENTRAL LUDHIANA vs M/S. GARG ACRYLICS LTD

Judgment text excerpt

* IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgement delivered on: 22.05.2025 + ITA 178/2023 PR. COMMISSIONER OF INCOME TAX -CENTRAL LUDHIANA .....Appellant versus M/S. GARG ACRYLICS LTD .....Respondent. Advocates who appeared in this case For the Appellant : Mr.Debesh Panda, SSC. For the Respondent : Mr.Rohit Jain, Advocate. CORAM: HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TEJAS KARIA JUDGMENT VIBHU BAKHRU, J. 1. The Revenue has preferred the present appeal under Section 260A of the Income Tax Act, 1961 [the Act], inter alia, impugning an order dated 27.10.2020 [impugned order] passed by the learned Income Tax Appellate Tribunal [ITAT] in ITA No.6834/Del/2014, in respect of Assessment Year [AY] 2011-12. 2. The impugned order is a common order in respect of ITA No.6834/Del/2014 as well as ITA No.4713/Del/2015 in respect of AY 2011- Signature Not Verified Digitally Signed By:RAM ITA 178/2023 Page 1 of 16 KUMAR Signing Date:23.05.2025 12:01:25 12 and AY 2012-13, respectively. However, the present appeal is confined to the impugned order insofar as it relates to ITA No.6834/Del/2014 for AY 2011-12. 3. The Revenue had filed the aforementioned appeal against the order dated 30.09.2014 passed by the Commissioner of Income Tax (Appeals)- XV, New Delhi [CIT(A)], whereby the respondent’s [Assessee] appeal against the assessment order dated 31.03.2014 passed by the Assessing Officer [AO] under Section 143(3) of the Act, was allowed. And, the additions made by the AO – ₹20,17,00,000/- under Section 68 of the Act and ₹20,24,39,341/- on account of income from undisclosed sources – were deleted. 4. As stated above, the Revenue appealed the said decision of the CIT(A), which was rejected by the impugned order. QUESTION OF LAW 5. The present appeal was admitted on 15.02.202