w w w . L a w y e r S e r v i c e s . i n



J.S.P. Constructions, New Delhi v/s Asstt. Commissioner of Income Tax, Circle-62(1), New Delhi


Company & Directors' Information:- C & C CONSTRUCTIONS LIMITED [Active] CIN = L45201DL1996PLC080401

Company & Directors' Information:- U G CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400TN2010PTC074921

Company & Directors' Information:- A G R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200TG1997PTC028180

Company & Directors' Information:- N J R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45209TG2009PTC065101

Company & Directors' Information:- C P R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200TG2008PTC057937

Company & Directors' Information:- S T CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201DL2004PTC127181

Company & Directors' Information:- J P G CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201DL2004PTC124763

Company & Directors' Information:- B O CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U00000DL2000PTC103440

Company & Directors' Information:- V R G CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45208TN2013PTC090378

Company & Directors' Information:- G N R CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U70200KA2004PTC034839

Company & Directors' Information:- E C CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201DL1998PTC092928

Company & Directors' Information:- I P CONSTRUCTIONS PVT LTD [Active] CIN = U45201DL2005PTC141372

Company & Directors' Information:- A R R S CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45202TZ2008PTC014926

Company & Directors' Information:- S K CONSTRUCTIONS LIMITED [Amalgamated] CIN = U45200DL1972PLC006224

Company & Directors' Information:- D N R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200TG2011PTC074563

Company & Directors' Information:- D A P CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201WB1997PTC086056

Company & Directors' Information:- M R CONSTRUCTIONS PVT LTD [Active] CIN = U45202WB1987PTC041958

Company & Directors' Information:- E AND A CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200TG2007PTC052569

Company & Directors' Information:- J N C CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U74899DL1998PTC093071

Company & Directors' Information:- P R D CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201DL2005PTC132422

Company & Directors' Information:- R A CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U74120DL1999PTC101132

Company & Directors' Information:- S V P CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U15100KA2013PTC072347

Company & Directors' Information:- V G V CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201TZ2003PTC010825

Company & Directors' Information:- C K CONSTRUCTIONS INDIA PRIVATE LIMITED [Active] CIN = U45309DL2021PTC382589

Company & Directors' Information:- C L S CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U74899DL1995PTC074067

Company & Directors' Information:- R M CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201DL2005PTC136640

Company & Directors' Information:- R K CONSTRUCTIONS (INDIA) PRIVATE LIMITED [Active] CIN = U45400UP2009PTC039089

Company & Directors' Information:- H M R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U27209WB1944PTC011901

Company & Directors' Information:- H A M CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201DL2005PTC140214

Company & Directors' Information:- B M R C CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201DL2004PTC126958

Company & Directors' Information:- A V A CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200DL2006PTC154123

Company & Directors' Information:- N B CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U70109DL2006PTC153179

Company & Directors' Information:- V P V CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45202TZ2002PTC010021

Company & Directors' Information:- P K CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45202WB1990PTC048623

Company & Directors' Information:- D B S CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201BR1990PTC003954

Company & Directors' Information:- P R P CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201TN1995PTC032833

Company & Directors' Information:- N S CONSTRUCTIONS (INDIA) LIMITED [Active] CIN = U70101DL1997PLC088867

Company & Directors' Information:- B B CONSTRUCTIONS LTD [Active] CIN = U70101WB1988PLC045084

Company & Directors' Information:- S V P CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45203KA2013PTC072347

Company & Directors' Information:- S. C. CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400AS2012PTC010876

Company & Directors' Information:- K & R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201AS2011PTC010822

Company & Directors' Information:- M CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200MH2004PTC148776

Company & Directors' Information:- V Y CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201UP2014PTC062964

Company & Directors' Information:- G V B CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U70100TG1998PTC028935

Company & Directors' Information:- P K D CONSTRUCTIONS PVT LTD [Strike Off] CIN = U74999WB1980PTC032820

Company & Directors' Information:- H K P CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45202OR2001PTC006458

Company & Directors' Information:- G S S CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201TZ1992PTC003665

Company & Directors' Information:- C AND M CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201DL2004PTC130723

Company & Directors' Information:- A G P CONSTRUCTIONS COMPANY PRIVATE LIMITED [Active] CIN = U45201AN2006PTC000078

Company & Directors' Information:- S I A CONSTRUCTIONS PVT LTD [Active] CIN = U45202WB1993PTC061189

Company & Directors' Information:- P H CONSTRUCTIONS PRIVATE LIMITED [Under Process of Striking Off] CIN = U45201DL2004PTC125388

Company & Directors' Information:- G G CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U74899DL1987PTC028772

Company & Directors' Information:- N S V CONSTRUCTIONS PRIVATE LIMITED [Converted to LLP and Dissolved] CIN = U70101WB1997PTC084753

Company & Directors' Information:- S M C CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201MH2000PTC123619

Company & Directors' Information:- T AND P CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45309PN2020PTC191603

Company & Directors' Information:- R K CONSTRUCTIONS PVT LTD [Strike Off] CIN = U24248UP1984PTC006613

Company & Directors' Information:- H V CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400MH2008PTC183930

Company & Directors' Information:- K M S CONSTRUCTIONS PVT LTD [Active] CIN = U26931TG1983PTC004119

Company & Directors' Information:- M S R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201TG2000PTC035352

Company & Directors' Information:- K P C CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45204DL2012PTC233771

Company & Directors' Information:- A G M CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45202KL2002PTC015340

Company & Directors' Information:- A N CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400UP2008PTC035171

Company & Directors' Information:- D N CONSTRUCTIONS PVT LTD [Active] CIN = U45203AS1983PTC002024

Company & Directors' Information:- P S V CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45209TG2009PTC064768

Company & Directors' Information:- K B C CONSTRUCTIONS LIMITED [Strike Off] CIN = U45209CH2011PLC032890

Company & Directors' Information:- T T S CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45403KL2020PTC064299

Company & Directors' Information:- V B R CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45200TG1997PTC027406

Company & Directors' Information:- M R Y CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400DL2008PTC172953

Company & Directors' Information:- V S CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201KA1980PTC003939

Company & Directors' Information:- J B CONSTRUCTIONS LTD [Strike Off] CIN = U45201WB1981PLC034263

Company & Directors' Information:- S D R CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201OR2010PTC012083

Company & Directors' Information:- M. G. B. CONSTRUCTIONS PRIVATE LIMITED [Under Process of Striking Off] CIN = U45400DL2015PTC281859

Company & Directors' Information:- V N CONSTRUCTIONS (INDIA) PRIVATE LIMITED [Active] CIN = U45200KA2015PTC083425

Company & Directors' Information:- R D S CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45202PN2001PTC016041

Company & Directors' Information:- T R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400DL2007PTC161605

Company & Directors' Information:- J B J CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201DL2004PTC130303

Company & Directors' Information:- A I B CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45309KA2021PTC146378

Company & Directors' Information:- A AND V CONSTRUCTIONS PVT LTD [Strike Off] CIN = U65992TG1987PTC007890

Company & Directors' Information:- M R G CONSTRUCTIONS PVT LTD [Strike Off] CIN = U45201MP1994PTC008620

Company & Directors' Information:- P D R CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U72100KA1986PTC007383

Company & Directors' Information:- A P CONSTRUCTIONS PVT LTD [Strike Off] CIN = U74210WB1979PTC032397

Company & Directors' Information:- J N D CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201DL1997PTC088802

Company & Directors' Information:- P. R. CONSTRUCTIONS PVT LTD [Strike Off] CIN = U45202MP1982PTC002078

Company & Directors' Information:- M AND M CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201DL1992PTC051503

Company & Directors' Information:- J AND T CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45200TG1999PTC031067

Company & Directors' Information:- CONSTRUCTIONS CO OF INDIA PRIVATE LIMITED [Strike Off] CIN = U29248UP1946PTC001471

Company & Directors' Information:- K S CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U29248UP1982PTC005640

Company & Directors' Information:- J. P. CONSTRUCTIONS PRIVATE LIMITED [Under Process of Striking Off] CIN = U45202CT2007PTC020304

Company & Directors' Information:- I M CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201DL2003PTC122889

Company & Directors' Information:- J V R INDIA CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201DL2004PTC129898

Company & Directors' Information:- S J M CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U70101KA1997PTC023146

Company & Directors' Information:- L S CONSTRUCTIONS INDIA PRIVATE LIMITED [Active] CIN = U45202KA2012PTC063895

Company & Directors' Information:- G D CONSTRUCTIONS PVT LTD [Strike Off] CIN = U45201WB1985PTC039687

Company & Directors' Information:- B G CONSTRUCTIONS PVT LTD [Active] CIN = U70109WB1989PTC046859

Company & Directors' Information:- J & J CONSTRUCTIONS PVT LTD [Not available for efiling] CIN = U70109WB1991PTC052664

Company & Directors' Information:- M C CONSTRUCTIONS PVT LTD [Strike Off] CIN = U70101WB1985PTC039150

Company & Directors' Information:- N C CONSTRUCTIONS PVT LTD [Strike Off] CIN = U70101WB1987PTC042382

Company & Directors' Information:- JSP CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U70101WB1999PTC089864

Company & Directors' Information:- M R B CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201CH1995PTC017071

Company & Directors' Information:- B A CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201PB2002PTC024960

Company & Directors' Information:- B AND W CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U17291DL2007PTC170930

Company & Directors' Information:- A S D CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201DL2004PTC125030

Company & Directors' Information:- P K CONSTRUCTIONS PVT LTD [Strike Off] CIN = U45200AP1987PTC008025

Company & Directors' Information:- G K CONSTRUCTIONS PVT LTD [Strike Off] CIN = U45201AS1988PTC003035

Company & Directors' Information:- H H CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200MH1980PTC022610

Company & Directors' Information:- S D C CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45209AP2011PTC074468

Company & Directors' Information:- C J CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U70101DL1996PTC082457

Company & Directors' Information:- R R CONSTRUCTIONS PVT LTD [Strike Off] CIN = U74210OR1989PTC002234

Company & Directors' Information:- N D F C CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201MH2004PTC144493

Company & Directors' Information:- J H CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200MH1998PTC115057

Company & Directors' Information:- S. CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U70101MH2003PTC139538

Company & Directors' Information:- L D F CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400UP2009PTC037275

Company & Directors' Information:- K P N R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200TG2014PTC092096

Company & Directors' Information:- J D CONSTRUCTIONS (INDIA) PRIVATE LIMITED [Active] CIN = U45209TG2010PTC071441

Company & Directors' Information:- R . C . S . CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U36911UP1999PTC024964

Company & Directors' Information:- U R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400WB2007PTC120032

Company & Directors' Information:- H M K CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45400WB2012PTC184485

Company & Directors' Information:- O P B K CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U74899DL1992PTC047760

Company & Directors' Information:- G A CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U74899DL2001PTC109333

Company & Directors' Information:- A J N CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U74899DL2005PTC142336

Company & Directors' Information:- J. N. CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45200BR2011PTC017019

Company & Directors' Information:- J. L. CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45500AP2016PTC104385

Company & Directors' Information:- U E CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201KA2002PTC030635

Company & Directors' Information:- U D CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201OR1990PTC002649

Company & Directors' Information:- C & A CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201TN1989PTC017300

Company & Directors' Information:- R S S CONSTRUCTIONS (INDIA) PRIVATE LIMITED [Strike Off] CIN = U45202JH1990PTC003927

Company & Directors' Information:- P AND P CONSTRUCTIONS PVT LTD [Strike Off] CIN = U45200TG1992PTC015113

Company & Directors' Information:- I. A. CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U70100TG1998PTC029569

Company & Directors' Information:- B J CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45200MH1972PTC015731

Company & Directors' Information:- S A K CONSTRUCTIONS (INDIA) PRIVATE LIMITED [Strike Off] CIN = U45400TG2007PTC055386

Company & Directors' Information:- L & I CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201UR2006PTC032334

Company & Directors' Information:- A.T. CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201UP1990PTC011951

Company & Directors' Information:- P B R CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201AP1998PTC028800

Company & Directors' Information:- I R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201DL1996PTC084160

Company & Directors' Information:- M A M CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201TZ2003PTC010667

Company & Directors' Information:- V. M. R. CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45202AP1996PTC023724

Company & Directors' Information:- Y P S CONSTRUCTIONS PVT LTD [Strike Off] CIN = U45201CH1993PTC013953

Company & Directors' Information:- A. W. CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200MP2009PTC022110

Company & Directors' Information:- S B R CONSTRUCTIONS PVT LTD [Active] CIN = U70100MH1982PTC027337

Company & Directors' Information:- G V K CONSTRUCTIONS P LTD [Strike Off] CIN = U45201TN1985PTC011867

Company & Directors' Information:- G T CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U51101UP1980PTC004982

Company & Directors' Information:- I. N. CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400JK2013PTC003931

Company & Directors' Information:- B. R. B. CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U74899DL1990PTC039632

Company & Directors' Information:- N. M. CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U74899DL1995PTC067227

Company & Directors' Information:- B N CONSTRUCTIONS PVT LTD [Strike Off] CIN = U45201OR1981PTC001015

Company & Directors' Information:- D F CONSTRUCTIONS PVT LTD [Strike Off] CIN = U45201CH1991PTC011820

Company & Directors' Information:- J AND J CONSTRUCTIONS PVT LTD [Strike Off] CIN = U45201KL1980PTC003192

Company & Directors' Information:- L AND S CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400PB2009PTC032554

Company & Directors' Information:- M T M CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201TZ2005PTC011626

Company & Directors' Information:- I S K CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45202TN2006PTC059103

Company & Directors' Information:- K R V CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400TN2010PTC075836

Company & Directors' Information:- R S I CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45400TN2010PTC078562

Company & Directors' Information:- D & Y CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200PN2009PTC134889

Company & Directors' Information:- K & Y CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45200PN2014PTC150194

Company & Directors' Information:- L. K. M. CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201MH2006PTC164835

Company & Directors' Information:- K & H CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400MH2011PTC218327

Company & Directors' Information:- J J K CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400MH2013PTC244977

Company & Directors' Information:- M K CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45200MH2000PTC127425

Company & Directors' Information:- JSP CORPORATION PRIVATE LIMITED [Strike Off] CIN = U74999PN2014PTC151264

Company & Directors' Information:- S R R CONSTRUCTIONS PVT LTD [Active] CIN = U45202MH1982PTC027359

Company & Directors' Information:- 4 F CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45400TG2012PTC081501

Company & Directors' Information:- N N C CONSTRUCTIONS PRIVATE LIMITED [Under Process of Striking Off] CIN = U45400TG2015PTC099840

Company & Directors' Information:- J S J CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U74900TN2016PTC103860

Company & Directors' Information:- Q AND Q CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45200TG2004PTC043373

Company & Directors' Information:- V M N R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45209TG2013PTC087032

Company & Directors' Information:- S I CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45209CH2014PTC035188

Company & Directors' Information:- R S A CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45400DL2009PTC193200

Company & Directors' Information:- B B R L CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45400DL2011PTC217588

Company & Directors' Information:- M AND R CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45400DL2012PTC243738

Company & Directors' Information:- A M T CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45400DL2014PTC268935

Company & Directors' Information:- K. D. CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U74120DL2009PTC190268

Company & Directors' Information:- G T B CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U70100DL2009PTC193204

Company & Directors' Information:- G N D CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U70100DL2009PTC193472

Company & Directors' Information:- R P T CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200AP2007PTC055960

Company & Directors' Information:- M N R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200AP2014PTC094893

Company & Directors' Information:- C B N CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45400HR2010PTC040454

Company & Directors' Information:- Y & M CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45400HR2011PTC044664

Company & Directors' Information:- M P K CONSTRUCTIONS PRIVATE LIMITED [Under Process of Striking Off] CIN = U45201KA2001PTC029100

Company & Directors' Information:- H K G N CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U74210KA2003PTC032055

Company & Directors' Information:- M Y S CONSTRUCTIONS PVT LTD [Active] CIN = U45201KL1995PTC008623

Company & Directors' Information:- R B CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U70102AP1989PTC010527

Company & Directors' Information:- A P N CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201HP1995PTC017344

Company & Directors' Information:- M T J CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201KA1991PTC011684

Company & Directors' Information:- V N V CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U70101DL1992PTC050037

Company & Directors' Information:- U AND I CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U99999MH2000PTC129703

Company & Directors' Information:- H B CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U70100MH1974PTC017866

Company & Directors' Information:- D B CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45200TG2007PTC053917

Company & Directors' Information:- T V L S CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45200TG2008PTC057723

Company & Directors' Information:- N N CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201TG2006PTC050240

Company & Directors' Information:- R S CONSTRUCTIONS PVT LTD [Strike Off] CIN = U45201CT1983PTC002128

Company & Directors' Information:- A R H CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45200DL2006PTC155870

Company & Directors' Information:- E M CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45200DL2008PTC185365

Company & Directors' Information:- K V S CONSTRUCTIONS PVT LTD [Strike Off] CIN = U45201RJ1983PTC002720

    ITA No. 3234 of 2019

    Decided On, 01 March 2021

    At, Income Tax Appellate Tribunal Delhi

    By, THE HONOURABLE MR. AMIT SHUKLA
    By, JUDICIAL MEMBER & THE HONOURABLE DR. B.R.R. KUMAR
    By, ACCOUNTANT MEMBER

    For the Assessee: Kapil Goel, Advocate. For the Revenue: Ved Prakash Mishra, Sr. DR.



Judgment Text

Dr. B. R. R. Kumar, Accountant Member:1. The present appeal has been filed by the assessee against the order of the ld. CIT(A)-20, New Delhi dated 26.02.2019.2. Following grounds have been raised by the assessee:"The initiation of action u/s 148 is bad in law,(i) being based o n bald allegations;2. That the Ld. CIT(A) erred in not appreciating that the proceedings initiated u/s 147/148 by Ld.A.O. are invalid and illegal as the vague reasons recorded do not reflect any independent application of mind on the part of the assessing office r, so as to form a reason to believe that income has escaped assessment. Further corrobo rate from the fact that, JSP Constructions Firstly, no basis is available, as to how figure o f Rs. 1.10 Crore has been arrive d in the reasons mentioned, whereas assessment framed on Rs.1,24,84,178/-.Secondly, After reopening Ld. A.O. gathered the basic information of contracts awarded to the assessee during the tenure of Mr. Yadav Singh vide letter dated 19/12/2016 issued u/s 133(6) of I.T. Act just few days before the finalisation of assessment, Thirdly, Contents of statement of Ramendra Singh are nowhere described in the reasons mentioned.Fourthly, No evidence worth name to link the assessee with Ramendra Singh/ Yadav Singh has been describe d in the reasons mentioned.3. That the Ld. CIT (A) has erred in not appreciating that the proceedings initiated u/s 147/148 are invalid and illegal as the reasons recorded do not reflect any live nexus (cause and effect relationship between findings of search and seizure operation on Mr. Ramendra Singh and assessee herein) therefore, satisfaction of the Assessing Officer regarding escapement of income are based upon borrowed satisfaction of the Investigation Wing of the department.4. That orders passed by Ld AO and Ld CIT-A are bad in law as reasons stated in assessment order was never accompanied with any back material available with A.O. at the time of reasons re cording (even during assessment/ first appeal proceedings said material was never confronted to assessee), therefore, sans, confrontation of stated material accordingly, notice issue d u/s 14 8 and all subsequent proceedings including orders of ld. A.O. and Ld. CIT(A) are void-ab-initio. [refer Page 12 of CIT(A) order)]5. That ld. A.O. erred in assuming jurisdiction u/s 148 of the Act, where provision of section 153C could JSP Constructions have been invoked which override the provision of section 148 of the Act. Accordingly, notice u/s 148 and all proceedings subsequent thereto are liable to be cancelled without valid issue of notice u/s 145(2) after due application of mind, and accordingly, order passed by Ld. A.O. and CIT (A) is void-ab-initio.6. That Ld. A.O. erred in assuming jurisdiction u/s 143(2) of the Act without valid issue of notice u/s 143(2) after due application of mind, and accordingly, order passed by Ld. Assessing Officer. And CIT(A) is voi-ab-initio.7. That Ld. A.O. has erred in passing order u/s 147/148, without formally supplying the reasons recorded as per Supreme court decision in the case of GKN Driveshats (India) Ltd. vs. ITO 259 ITR19 (SC), before completion of assessment proceedings, even mandatory approval u/s 151 referred is never supplied to the assessee, assessment order dated 31/12/2016 is passed after time barring date (refer dispatch record), there fore orders passed by A.O./ CIT(A) are void-ab-initio.8. That on the facts and in the circumstances of the case and in law, Id CIT(A) erred in sustaining the action of AO in making addition of Rs.83,09,389/- without appreciating that no opportunity is given to the assessee to be confronted with back material and no opportunity to cross examine the revenue's witness was given despite mandated in revenue office manual which is flouted by the ld. A.O. and CIT(A).9. That without prejudice to above, addition of Rs.41,74,789/- as made by the assessing officer u/s 40A(3) and confirmed by CIT(A) is outside the purview of reasons recorded and no subsequent information has come to A.O. within the meaning of Explanation 3 of section 147, no notice u/s 148 is issued for that item, addition sustained is patently invalid. Further genuineness of payment never doubted as per circular 6P of 1968 issued by CBDT, therefore, addition sustained is bad merit also.JSP Constructions10. That without prejudice to above, estimated/ ad- hoc addition of Rs.1,24,84,178/- as made by assessing officer on account of alleged payment of commission @ 5 % to Mr. Yadav Singh and confirmed by CIT(A) to the tune of Rs.82,09,389/-, is without any basis and appellant had not made any payment to Yadav Singh through Ramendra Singh as alleged."3. The assessee is a civil contractor doing work for Government and Semi-Government agency namely GNOIDA, NBCC, PWD etc. The case has been reopened u/s 147 of the Income Tax Act, 1961 vide issue of notice dated 03.09.2015 on the grounds that the assessee paid commission @ 5% on the contracts awarded by the authorities.4. During the course of assessment proceedings, the Assessing Officer directed the assessee to produce books of accounts for verification. Further, notice u/s 133(6) of the Act was issued to CEO, NOIDA calling for information of contracts awarded by the NOIDA during the financial year 2011 -12 for which the NOIDA replied that the assessee has been awarded contracts to the tune of Rs.24.96 crores. During the assessment proceedings, the AO asked the assessee to produce details of purchases, labour expenses, wages, freight expenses along with requisite bills, vouchers and muster roll. The AO issued show-cause notice why no t the profits be estimated @ 8% of the total receipts owing to non-submission o f bills. The assessee vide letter dated 28.12.2016 submitted that all financial and necessary documents have been submitted and explained every debit entry of withdrawal and payment from bank account. The AO not satisfied with the reply of the assessee and has disallowed an amount @ 5% of the contract work awarded by NOIDA.JSP Constructions5. The relevant part of the assessment order is reproduced as under for ready reference:"Conside ring the totality of facts of this case as also considering the nature of construction business, also relying on N.P. rate declared by other assessees in similar line of business and also considering the large turnover of Rs.1,60,53,89,443/- shown during the year, application o f 8% o n the to tal turnover in the case of the assessee appears to be excessive. Despite so, assessee failed to produce original bills/vouchers, muster roll etc. for verification and further seen that most of the transactions have been made in cash. Also various discrepancies have been noticed from the ledger furnished by the assessee, which are being discussed in subsequent para. Perusal of the ledger reveals that the assessee has made cash payments exceeding Rs.20,000/- to a single party and the assessee has willfully bifurcated the above payments below the threshold limit to outwink the revenue. And, the payments have been exclusively made in cash for which, assessee has failed to produce original bills/vouchers for verification. Under the prevailing circumstances as the assessee cannot substantiate the above discrepancy, it cannot be denied that the assessee had diverted the funds for paying commissions in the guise of various expenses shown in the books, majority of which has been incurred in cash. Moreover, in the absence o f proper bills/vouchers/documentary evidences, the source of cash payments remained unconfirmed. Hence, it is not possible to vouch the source of commission paid by the assessee @ 5% of contract work awarded in the tenure of Sh. Yadav Singh. As already discussed above, total work contract is JSP Constructions Rs.24,96,83,556/-. Hence, 5% of Rs.24,96,83,556/- worked out to be Rs.1,24,84,178/- which is being disallowed and added to the income of the assessee."6. The ld. CIT (A) confirmed the addition. While confirming, the ld. CIT (A) assumed that "the Assessing Officer has given a finding that 5% of the total turnover must have been paid by the appellant as commission by diverting funds in the guise of various expenses shown in the books majority of which has been incurred in cash. The AO has also given a finding that the appellant had paid Rs.41,74,789/- in contravention to provisions of Section 40A(3) of the Act. The addition made by the Assessing Officer of Rs.41,74,789/- is confirmed. Howeve r, since this amount is also embedded in the 5% commission made in cash i.e. amount of Rs.1,24,84,178/-, the said addition is to be reduced by Rs.41,74,789/-. T he Assessing Officer is directed to make an addition of Rs.83,09,389/- on this account".7. Thus, the question before us to adjudicate remains as to "whether the amount of Rs.83,09,389/- confirmed by the ld. CIT (A) out of the disallowance made by the Assessing Officer on account of expenses which is a source of alleged commission paid is correct or not" ?8. Heard the arguments of both the parties and perused the material available on record.9. From the assessment order, we find that, a. The assessee received contracts from NOIDA to the tune of Rs.24.96 crores.b. The total turnover of the assessee was Rs.160.53 crores JSP Constructions c. The show-cause notice has been issued for determination of estimation of profits @8% d. The net profit disclosed by the assessee was 6.77%10. At the outset, we find that while the show-cause has been issued for determination of profits @8%, the disallowance has been made @5% on the contracts of Rs.24.96 crores. In addition to the net profits disclosed, the Assessing Officer has disallowed 5% of the expenses on the total contract work awarded by NOIDA. The AO also held that the application of 8% on the turnover appears to be excessive. While doing so, the Assessing Officer has held that payments exceeding Rs.20,000/- were made to a single party and the assessee has willfully bifurcated the payments to keep it within the threshold limit. Beyond this, the Assessing Officer has not brought anything on record to disallow 5% of the expenses. He has not determined even the head under which the ex

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penses have been inflated or bogus. Even, in the case of payments made in cash, absolutely no enquiries have been conducted. The Assessing Officer held that the assessee could not substantiate the discrepancies but did not mention anything as to what are all the discrepancies found. The mere allegations cannot be treated as evidences. The fundamental principle of justice requires the Assessing Officer to discover and collect evidence and confront the assessee before making any disallowance. In the instant case, there was no mention at all as to which of the expenses is bogus or inflated. In the instant case, we find no primary evidences or secondary evidences or even any probabilities brought out by the revenue to resort to disallowance of 5% expenses over and above 6.77% net profit disclosed by the JSP Constructions assessee. Any disallowance made by the revenue without bringing any evidence on record is liable to be set aside.11. In the result, the appeal of the assessee is allowed.12. Since, the assessee gets relief on merits of the case, we refrain to adjudicate on the technical grounds being academic in nature.
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