DCIT, CENTRAL CIRCLE-20, DELHI vs. LOTUS HERBALS PVT. LTD, DELHI

ITA 2445/DEL/2023Status: DisposedITAT Delhi23 December 2025AY 2016-1744 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the CIT(A)'s deletion of disallowances on A&M expenses, finding the reassessment proceedings to be without jurisdiction as the assessee had fully disclosed material facts during the original assessment. Additions under Section 14A were also upheld as per the CIT(A)'s order.

What were the facts?

The Revenue appealed against the CIT(A)'s orders deleting disallowances made on Advertisement and Marketing expenses and reducing additions under Section 14A. The assessee also challenged the initiation of reassessment proceedings under Section 148.

What were the issues?

Validity of reassessment proceedings initiated after four years without failure to disclose material facts, and the correctness of disallowances made under Section 14A.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 143(3),Section 151,Section 14A

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Cases cited in this judgment(30)Show list

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Income Tax Appellate Tribunal, DELHI BENCH ‘E’: NEW DELHI

Before: SHRI SUDHIR KUMAR & SHRI MANISH AGARWAL

For Appellant: Shri Rohit Jain, Adv. and Shri Shivam Gupta, CA
For Respondent: DR and Ms. Pooja Swroop, CIT-DR
Pronounced: 23.12.2025

PER MANISH AGARWAL, AM: These are five appeals filed by the Revenue against the separate orders of Learned Commissioner of Income Tax (Appeals)-27, New Delhi. All are dated 12.06.2023 for Assessment Years as tabulated as under: ITA Assessment Year Remarks 2442/Del/2023 2013-14 Order u/s 143(3)/147 2443/Del/2023 2014-15 Order u/s 143(3)/147 2444/Del/2023 2015-16 Order u/s 143(3) 2445/Del/2023 2016-17 Order u/s 143(3) 200/Del/2023 2019-20 Order u/s 143(3)

2.

Since in all appeals, issues raised by the revenue are common and interlinked, therefore, all the appeals of the revenue a

The order continues below.

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