ITAT Delhi Judgments — July 2025

SHALIMAR CORP LTD.,LUCKNOW vs DCIT, CENTRAL CIRCLE-30, NEW DELHI

ITA 2766/DEL/2022[2014-15]Status: Disposed31 Jul 2025AY 2014-15Partly Allowed

The Tribunal held that adding the Rs. 101 crores on-money admission over and above the special auditor's quantification was a double addition and directed its deletion. Additions related to unsecured loans and unexplained investments were to be treated as business turnover and assessed at 20%.

SHALIMAR CORP LTD,LUCKNOW vs DCIT, CENTRAL CIRCLE-30, NEW DELHI

ITA 2768/DEL/2022[2016-17]Status: Disposed31 Jul 2025AY 2016-17Partly Allowed

The Tribunal held that adding the Rs. 101 crores on-money admission over and above the special auditor's quantification was a double addition and directed its deletion. Additions related to unsecured loans and unexplained investments were to be treated as business turnover and assessed at 20%.

ACIT, CENTRAL CIRCLE- 15, NEW DELHI vs FOCUS BUILDWELL PVT. LTD., NEW DELHI

ITA 2273/DEL/2018[2010-11]Status: Disposed31 Jul 2025AY 2010-11Dismissed

The Tribunal held that while a search warrant may not necessarily be executed at the registered office, it must be established that the search was initiated and conducted upon the company at its registered office or where it was represented by an authorized person. Mere mention of the name on the warrant is insufficient if no overt act of search commencement is proven.

SHALIMAR CORP LTD.,LUCKNOW vs DCIT,CENTRAL CIRCLE-30, NEW DELHI

ITA 2765/DEL/2022[2013-14]Status: Disposed31 Jul 2025AY 2013-14Partly Allowed

The Tribunal held that adding the Rs. 101 crores on-money admission over and above the special auditor's quantification was a double addition and directed its deletion. Additions related to unsecured loans and unexplained investments were to be treated as business turnover and assessed at 20%.

SHALIMAR CORP LTD.,LUCKNOW vs DCIT, CENTRAL CIRCLE-30, NEW DELHI

ITA 2767/DEL/2022[2015-16]Status: Disposed31 Jul 2025AY 2015-16Partly Allowed

The Tribunal held that adding the Rs. 101 crores on-money admission over and above the special auditor's quantification was a double addition and directed its deletion. Additions related to unsecured loans and unexplained investments were to be treated as business turnover and assessed at 20%.

BHAWANI METALLOY PRIVATE LIMITED,NEW DELHI vs DCIT, CENTRAL CIRCLE 13, DELHI, DELHI

ITA 2052/DEL/2025[2021-22]Status: Disposed31 Jul 2025AY 2021-22Allowed

The Tribunal found that while notices were mentioned in the Ld. CIT(A)'s order, the mode of service and the ends of justice require an opportunity for the assessee to contest on merits and legal issues. Therefore, the issues were restored to the Ld. CIT(A).

ACIT, CENTRAL CIRCLE- 15, NEW DELHI vs FOCUS BUILDWELL PVT. LTD., NEW DELHI

ITA 2271/DEL/2018[2009-10]Status: Disposed31 Jul 2025AY 2009-10Dismissed

The Tribunal held that while a search warrant may not necessarily be executed at the registered office, it must be established that the search was initiated and conducted upon the company at its registered office or where it was represented by an authorized person. Mere mention of the name on the warrant is insufficient if no overt act of search commencement is proven.

ACIT, CENTRAL CIRCLE- 15, NEW DELHI vs FOCUS BUILDWELL PVT. LTD., NEW DELHI

ITA 2272/DEL/2018[2011-12]Status: Disposed31 Jul 2025AY 2011-12Dismissed

The Tribunal held that although the warrant was in the assessee's name, there was no commencement or initiation of search at the assessee's premises or where it was represented. Therefore, the provisions of Section 153A could not be invoked.

NISHA JAIN,FARIDABAD vs ACIT DCIT CIRCLE 1, FARIDABAD

ITA 2361/DEL/2024[2015-2016]Status: Disposed31 Jul 2025AY 2015-2016Dismissed

The Tribunal noted that the proceeding initiated under Section 271(1)(c) of the Act culminated in an order of penalty that had become infructuous. Therefore, the appeal was dismissed as infructuous.

SHALIMAR CORP LTD.,LUCKNOW vs DCIT CENTER CIRCLE-30, DELHI

ITA 2764/DEL/2022[2012-13]Status: Disposed31 Jul 2025AY 2012-13Partly Allowed

The Tribunal held that adding the Rs. 101 crores on-money admission over and above the special auditor's quantification was a double addition and directed its deletion. Additions related to unsecured loans and unexplained investments were to be treated as business turnover and assessed at 20%.

ADDL. CIT, SPECIAL RANGE- 4 , NEW DELHI vs HUDCO LTD., NEW DELHI

ITA 2063/DEL/2018[2014-15]Status: Disposed31 Jul 2025AY 2014-15Partly Allowed

The Tribunal held that CSR expenses incurred as per regulatory mandate, for disaster rehabilitation, were allowable for assessment years prior to the introduction of Explanation 2 to Section 37(1). It also held that interest income on FDRs and Bonds had a direct nexus to the assessee's business of providing finance for housing and infrastructure development.

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-II, NOIDA vs PACIFIC MINING PRODUCTS PVT. LTD., DELHI

ITA 2132/DEL/2024[2014-15]Status: Disposed31 Jul 2025AY 2014-15Dismissed

The Tribunal held that since the quantum appeals against additions were already dismissed by a Co-ordinate Bench, there was no concealed income on which penalty could be levied. Therefore, the deletion of penalty by the Ld. CIT(A) was upheld.

DCIT, CENTRAL CIRCLE, GHAZIABAD vs SSG INFRATECH PRIVATE LIMITED, NEW DELHI

ITA 1338/DEL/2021[2013-14]Status: Disposed31 Jul 2025AY 2013-14Dismissed

The Tribunal held that the approval granted under Section 153D was invalid as it was granted mechanically for numerous cases and assessment years in a single day without proper application of mind. Consequently, the assessment orders passed based on this invalid approval were vitiated.

BHAWANI METALLOY PRIVATE LIMITED,NEW DELHI vs DCIT, CENTRAL CIRCLE-13, DELHI

ITA 2051/DEL/2025[2020-21]Status: Disposed31 Jul 2025AY 2020-21Allowed

The Tribunal found that while notices were mentioned in the Ld. CIT(A)'s order, the mode of service and the ends of justice require an opportunity for the assessee to contest on merits and legal issues. Therefore, the issues were restored to the Ld. CIT(A).

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-II, NOIDA vs PACIFIC MINING PRODUCTS PVT. LTD., DELHI

ITA 2131/DEL/2024[2013-14]Status: Disposed31 Jul 2025AY 2013-14Dismissed

The Tribunal held that since the quantum appeals against additions were already dismissed by a Co-ordinate Bench, there was no concealed income on which penalty could be levied. Therefore, the deletion of penalty by the Ld. CIT(A) was upheld.

ACME CLEANTECH,HARYANA vs ACIT,CIRCLE-1 (1) , NEW DELHI

ITA 2142/DEL/2022[2018-19]Status: Disposed31 Jul 2025AY 2018-19Partly Allowed

The Tribunal remanded the issues of notional interest on receivables from AEs and provision for warranty to the TPO/AO for fresh examination. It held that disallowance under Section 14A cannot exceed the actual exempt income and directed the AO to restrict it to Rs.29,447/- for AY 2017-18 and Rs.40,243/- for AY 2018-19. The listing fees for Non-Convertible Debentures were found to be allowable, reversing the disallowance. The disallowance under Section 36(1)(iii) for diversion of funds was also remanded to the AO for fresh consideration, while the disallowance under Section 40(a)(ia) for AY 2018-19 was sustained.

DCIT, CIRCLE-7(1), DELHI vs ESYS INFORMATION TECHNOLOGIES PRIVATE LIMITED, CHANDIGARH

ITA 1628/DEL/2025[2014-15]Status: Disposed31 Jul 2025AY 2014-15Dismissed

The Tribunal accepted the Ld. AR's contention that the actual tax effect of the CIT(A)'s order was Rs. 50,52,498/-, which is below the prescribed monetary limit of Rs. 60 lakhs for filing appeals before the Hon'ble ITAT, as per CBDT Circulars. Therefore, the Revenue's appeal was dismissed as not maintainable.

MITSUI MINING AND SMELTING COMPANY LIMITED,TOKYO JAPAN vs ASSISTANT COMMISSIONER OF INCOME TAX - CIRCLE 2(2)(1), CIVIC CENTRE, MINTO ROAD, NEW DELHI

ITA 1407/DEL/2025[2022-23]Status: Disposed31 Jul 2025AY 2022-23Allowed

The Tribunal held that the secondment agreement and the actual working conditions did not establish an employer-employee relationship between the assessee and the seconded employees. The Indian subsidiary, MKCI, maintained sole control over the seconded employees and its operations.

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-II, NOIDA vs PACIFIC MINING PRODUCTS PVT. LTD., DELHI

ITA 2130/DEL/2024[2012-13]Status: Disposed31 Jul 2025AY 2012-13Dismissed

The Tribunal held that since the quantum appeals against additions were already dismissed by a Co-ordinate Bench, there was no concealed income on which penalty could be levied. Therefore, the deletion of penalty by the Ld. CIT(A) was upheld.

SHALIMAR CORP LIMITED,DELHI vs DCIT, CENTRAL CIRCLE-30, , NEW DELHI

ITA 2360/DEL/2023[2011-12]Status: Disposed31 Jul 2025AY 2011-12Partly Allowed

The Tribunal held that adding the Rs. 101 crores on-money admission over and above the special auditor's quantification was a double addition and directed its deletion. Additions related to unsecured loans and unexplained investments were to be treated as business turnover and assessed at 20%.

DCIT, DELHI vs SHALIMAR CORP. LIMITED, MUMBAI

ITA 2502/DEL/2023[2011-12]Status: Disposed31 Jul 2025AY 2011-12Partly Allowed

The Tribunal held that adding the Rs. 101 crores on-money admission over and above the special auditor's quantification was a double addition and directed its deletion. Additions related to unsecured loans and unexplained investments were to be treated as business turnover and assessed at 20%.

MAHASHIV METAL & ALLOYS PVT LTD,DELHI vs ACIT CENTRAL CIRCLE-13, DELHI

ITA 1352/DEL/2023[2013-14]Status: Disposed31 Jul 2025AY 2013-14Dismissed

The Tribunal heard the Ld. DR and perused the explanation of the assessee for the delay. The Tribunal found the explanation unacceptable and dismissed all the appeals as barred by limitation.

KOHINOOR FOODS LTD,FARIDABAD vs ACIT CIRCLE-14(2), NEW DELHI

ITA 1441/DEL/2023[2016-17]Status: Disposed31 Jul 2025AY 2016-17Allowed

The Tribunal held that for Assessment Year 2012-13, provisions of Section 92B are not applicable to outstanding receivables. For all three years, if no interest was charged on delayed payments from non-AEs, no notional interest can be added for AEs. For corporate guarantee, the Tribunal directed AO to apply 1% rate.

HOUSING & URBAN DEVELOPMENT CORPORATION LTD,NEW DELHI vs ADDL. CIT, RANGE-4, NEW DELHI

ITA 1954/DEL/2018[2014-15]Status: Disposed31 Jul 2025AY 2014-15Partly Allowed

The Tribunal held that CSR expenses incurred as per regulatory mandate, for disaster rehabilitation, were allowable for assessment years prior to the introduction of Explanation 2 to Section 37(1). It also held that interest income on FDRs and Bonds had a direct nexus to the assessee's business of providing finance for housing and infrastructure development.

BHAWANI METALLOY PRIVATE LIMITED,NEW DELHI vs DCIT, CENTRAL CIRCLE -13, DELHI

ITA 2049/DEL/2025[2018-19]Status: Disposed31 Jul 2025AY 2018-19Allowed

The Tribunal found that while notices were mentioned in the Ld. CIT(A)'s order, the mode of service and the ends of justice require an opportunity for the assessee to contest on merits and legal issues. Therefore, the issues were restored to the Ld. CIT(A).

BHAWANI METALLOY PRIVATE LIMITED,DELHI vs DCIT CENTRAL CIRCLE-13, CENTRAL DELHI

ITA 2048/DEL/2025[2017-18]Status: Disposed31 Jul 2025AY 2017-18Allowed

The Tribunal found that while notices were mentioned in the Ld. CIT(A)'s order, the mode of service and the ends of justice require an opportunity for the assessee to contest on merits and legal issues. Therefore, the issues were restored to the Ld. CIT(A).

SSG INFRATECH PRIVATE LIMITED,NOIDA vs DCIT, CC, GHAZIABAD

ITA 1194/DEL/2021[2012-13]Status: Disposed31 Jul 2025AY 2012-13Partly Allowed

The Tribunal held that the approval granted by the Additional Commissioner of Income Tax under Section 153D of the Income Tax Act, 1961, was invalid. The Tribunal noted that the approval was granted on 28.12.2018 for 51 cases, including the assessee's, for multiple assessment years, on the very next day after the draft assessment orders were sent. While the approval mentioned perusal of relevant assessment records, it was silent on which specific records or seized material were examined. The Tribunal found it improbable to examine 51 assessment records in a single day, leading to the conclusion that the approval was granted mechanically without proper application of mind. This reasoning was supported by the decisions of the Hon'ble Delhi High Court in PCIT vs. Shiv Kumar Nayyar and PCIT vs. MDLR Hotels (P) Ltd. Consequently, the assessment orders passed based on this mechanical approval were vitiated. The assessee's ground challenging the validity of the approval was allowed. As a result, the appeals filed by the assessee were allowed, and the appeals filed by the Revenue for the corresponding assessment years were dismissed. The Revenue's appeal for AY 2014-15 was also dismissed for parity of reasons.

SSG INFRATECH PRIVATE LIMITED,NOIDA vs DCIT, CC, GHAZIABAD

ITA 1195/DEL/2021[2013-14]Status: Disposed31 Jul 2025AY 2013-14Partly Allowed

The Tribunal held that the approval granted under Section 153D of the Income Tax Act, 1961, was invalid. The Additional Commissioner of Income Tax granted approval for 51 cases, including the assessee's for multiple assessment years, on a single day (December 28, 2018). The Tribunal found that this manner of approval was mechanical and lacked proper application of mind, citing the impossibility of examining 51 cases in one day. The approval order was silent on which specific assessment records or seized material were examined. The Tribunal relied on the Delhi High Court's decisions in PCIT vs. Shiv Kumar Nayyar and PCIT vs. MDLR Hotels (P) Ltd., which held that single approvals granted mechanically for multiple assessment years and multiple assessees are invalid. Consequently, the assessment orders passed based on this invalid approval were vitiated. The assessee's ground of appeal concerning the validity of the Section 153D approval was allowed. As this legal issue was decided in favour of the assessee, other grounds became academic. The appeals of the assessee for AYs 2012-13, 2013-14, and 2015-16 to 2017-18 were allowed. The appeals of the Revenue for the corresponding assessment years, and for AY 2014-15, were dismissed.

BHAWANI METALLOY PRIVATE LIMITED,NEW DELHI vs DCIT, CENTRAL CIR 13, DELHI, DELHI

ITA 2050/DEL/2025[2019-20]Status: Disposed31 Jul 2025AY 2019-20Allowed

The Tribunal found that while notices were mentioned in the Ld. CIT(A)'s order, the mode of service and the ends of justice require an opportunity for the assessee to contest on merits and legal issues. Therefore, the issues were restored to the Ld. CIT(A).

SSG INFRATECH PRIVATE LIMITED,NOIDA vs DCIT, CC, GHAZIABAD

ITA 1196/DEL/2021[2015-16]Status: Disposed31 Jul 2025AY 2015-16Dismissed

The Tribunal held that the approval granted under Section 153D was invalid as it was granted mechanically for numerous cases and assessment years in a single day without proper application of mind. Consequently, the assessment orders passed based on this invalid approval were vitiated.

M/S. EXPERION DEVELOPERS PVT. LTD.,GURGAON vs ACIT, NEW DELHI

ITA 1367/DEL/2017[2012-13]Status: Disposed31 Jul 2025AY 2012-13Allowed

The Tribunal held that the assessee consistently followed its accounting method and incurred the expenditure wholly and exclusively for business purposes. The Assessing Officer's ad-hoc disallowance of 90% of the expenditure was considered arbitrary, especially since he himself allowed 10%.

SSG INFRATECH PRIVATE LIMITED,NOIDA vs DCIT, CC, GHAZIABAD

ITA 1197/DEL/2021[2016-17]Status: Disposed31 Jul 2025AY 2016-17Dismissed

The Tribunal held that the approval granted under Section 153D was invalid as it was granted mechanically for numerous cases and assessment years in a single day without proper application of mind. Consequently, the assessment orders passed based on this invalid approval were vitiated.

KOHINOOR FOODS LTD.,FARIDABAD vs DCIT CENTRAL CIRCLE-28, NEW DELHI

ITA 1442/DEL/2023[2012-13]Status: Disposed31 Jul 2025AY 2012-13Allowed

The Tribunal held that for Assessment Year 2012-13, provisions of Section 92B are not applicable to outstanding receivables. For all three years, if no interest was charged on delayed payments from non-AEs, no notional interest can be added for AEs. For corporate guarantee, the Tribunal directed AO to apply 1% rate.

SSG INFRATECH PRIVATE LIMITED,NOIDA vs DCIT, CC, GHAZIABAD

ITA 1198/DEL/2021[2017-18]Status: Disposed31 Jul 2025AY 2017-18Dismissed

The Tribunal held that the approval granted under Section 153D was invalid as it was granted mechanically for numerous cases and assessment years in a single day without proper application of mind. Consequently, the assessment orders passed based on this invalid approval were vitiated.

DCIT, CENTRAL CIRCLE, GHAZIABAD vs SSG INFRATECH PRIVATE LIMITED, NEW DELHI

ITA 1341/DEL/2021[2016-17]Status: Disposed31 Jul 2025AY 2016-17Partly Allowed

The Tribunal held that the approval granted by the Additional Commissioner of Income Tax under Section 153D of the Income Tax Act, 1961, was invalid. The reasoning was that the approval was granted for 51 cases, including multiple assessment years for the assessee, on a single day (December 28, 2018). The Tribunal found it improbable that such a large number of cases could be properly examined and approved within a single day, indicating a mechanical exercise of power without independent application of mind. The Tribunal noted that while the approval mentioned perusal of records, it was silent on which specific records were examined. This manner of approval was deemed to vitiate the assessment orders passed by the Assessing Officer. The Tribunal relied on the precedents set by the Delhi High Court in PCIT vs. Shiv Kumar Nayyar and PCIT vs. MDLR Hotels (P) Ltd. Consequently, the assessee's grounds of appeal were allowed, and the Revenue's appeals were dismissed. The Tribunal did not deliberate on other grounds of appeal as the primary legal issue was decided in favour of the assessee.

DCIT, CENTRAL CIRCLE, GHAZIABAD vs SSG INFRATECH PRIVATE LIMITED, NEW DELHI

ITA 1340/DEL/2021[2015-16]Status: Disposed31 Jul 2025AY 2015-16Dismissed

The Tribunal held that the approval granted under Section 153D was invalid as it was granted mechanically for numerous cases and assessment years in a single day without proper application of mind. Consequently, the assessment orders passed based on this invalid approval were vitiated.

BHUSHAN GUPTA,DELHI vs ITO, WARD 47(1), DELHI, NEW DELHI

ITA 1112/DEL/2025[2016-17]Status: Disposed31 Jul 2025AY 2016-17Allowed

The Tribunal held that for notices issued beyond three years, approval from the Principal Chief Commissioner (or equivalent) is mandatory under Section 151(ii). Since approval was obtained from a lower authority (Principal Commissioner), the notices were invalid.

ERNST & YOUNG U.S. LLP,NOIDA vs ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE INTERNATIONAL TAX 1(2)(2), NEW DELHI, NEW DELHI

ITA 1243/DEL/2025[2022-23]Status: Disposed31 Jul 2025AY 2022-23Allowed

The Tribunal held that the issues raised were covered by previous judgments of a co-ordinate bench in the assessee's own case. Specifically, the Tribunal followed the precedent regarding the taxability of secondment employees and the interpretation of 'professional services' under Article 15(2) of the DTAA, finding that the 'make available' requirement was not met for Fees for Included Services (FIS).

BHUSHAN GUPTA,DELHI vs ITO, WARD 47(1), DELHI, NEW DELHI

ITA 1113/DEL/2025[2017-18]Status: Disposed31 Jul 2025AY 2017-18Allowed

The Tribunal held that for notices issued beyond three years, approval from the Principal Chief Commissioner (or equivalent) is mandatory under Section 151(ii). Since approval was obtained from a lower authority (Principal Commissioner), the notices were invalid.

ERNST & YOUNG U.S. LLP,NOIDA vs ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE INTERNATIONAL TAX 1(2)(2), NEW DELHI, NEW DELHI

ITA 1254/DEL/2025[2018-19]Status: Disposed31 Jul 2025AY 2018-19Allowed

The Tribunal held that the issues raised were covered by previous judgments of a co-ordinate bench in the assessee's own case. Specifically, the Tribunal followed the precedent regarding the taxability of secondment employees and the interpretation of 'professional services' under Article 15(2) of the DTAA, finding that the 'make available' requirement was not met for Fees for Included Services (FIS).

LALL CONSTRUCTION CO. ,NEW DELHI vs ACIT, CIRCLE- 34(1), NEW DELHI

ITA 1680/DEL/2018[2010-11]Status: Disposed31 Jul 2025AY 2010-11Allowed

The Tribunal held that since the basis of the penalty levy under Section 271(1)(c) is under settlement, it is expedient to delete the penalty. The appeal is allowed subject to conditions related to the settlement of the main dispute.

DCIT, CENTRAL CIRCLE, GHAZIABAD vs SSG INFRATECH PRIVATE LIMITED, NEW DELHI

ITA 1348/DEL/2021[2017-18]Status: Disposed31 Jul 2025AY 2017-18Dismissed

The Tribunal held that the approval granted under Section 153D was invalid as it was granted mechanically for numerous cases and assessment years in a single day without proper application of mind. Consequently, the assessment orders passed based on this invalid approval were vitiated.

MAHASHIV METAL & ALLOYS PVT LTD,DELHI vs ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-13, DELHI

ITA 1354/DEL/2023[2015-16]Status: Disposed31 Jul 2025AY 2015-16Dismissed

The Tribunal heard the Ld. DR and perused the explanation of the assessee for the delay. The Tribunal found the explanation unacceptable and dismissed all the appeals as barred by limitation.

KOHINOOR FOODS LTD.,FARIDABAD vs ACIT, CIRCLE-14(2), NEW DELHI

ITA 1443/DEL/2023[2014-15]Status: Disposed31 Jul 2025AY 2014-15Allowed

The Tribunal held that for Assessment Year 2012-13, provisions of Section 92B are not applicable to outstanding receivables. For all three years, if no interest was charged on delayed payments from non-AEs, no notional interest can be added for AEs. For corporate guarantee, the Tribunal directed AO to apply 1% rate.

MAHASHIV METAL & ALLOYS PVT. LTD.,NEW DELHI vs ACIT CENTRAL CIRCLE-13, NEW DELHI

ITA 1350/DEL/2023[2011-12]Status: Disposed31 Jul 2025AY 2011-12Dismissed

The Tribunal heard the Ld. DR and perused the explanation of the assessee for the delay. The Tribunal found the explanation unacceptable and dismissed all the appeals as barred by limitation.

MAHASHIV METAL & ALLOYS PVT LTD.,NEW DELHI vs ACIT CENTRAL CIRCLE-13, NEW DELHI

ITA 1351/DEL/2023[2012-13]Status: Disposed31 Jul 2025AY 2012-13Dismissed

The Tribunal heard the Ld. DR and perused the explanation of the assessee for the delay. The Tribunal found the explanation unacceptable and dismissed all the appeals as barred by limitation.

DCIT, CENTRAL CIRCLE, GHAZIABAD vs SSG INFRATECH PRIVATE LIMITED, NEW DELHI

ITA 1339/DEL/2021[2014-15]Status: Disposed31 Jul 2025AY 2014-15Dismissed

The Tribunal held that the approval granted under Section 153D was invalid as it was granted mechanically for numerous cases and assessment years in a single day without proper application of mind. Consequently, the assessment orders passed based on this invalid approval were vitiated.

DCIT, CENTRAL CIRCLE, GHAZIABAD vs SSG INFRATECH PRIVATE LIMITED, NEW DELHI

ITA 1337/DEL/2021[2012-13]Status: Disposed31 Jul 2025AY 2012-13Dismissed

The Tribunal held that the approval granted under Section 153D was invalid as it was granted mechanically for numerous cases and assessment years in a single day without proper application of mind. Consequently, the assessment orders passed based on this invalid approval were vitiated.

VINOD MONGIA,WAST AZAD NAGAR, DELHI vs INCOME TAX OFFICER , VIKAS BHAWAN,DELHI

ITA 1844/DEL/2024[2012-2013]Status: Disposed31 Jul 2025AY 2012-2013Allowed

The Tribunal held that the reassessment order was bad in law and void ab initio due to the non-issuance of a mandatory notice under Section 143(2) before completing the assessment. This violation renders the entire reassessment proceedings a nullity.

ISHWAR CHAND AGGARWAL,FARIDABAD vs INCOME TAX OFFICER- WARD 1(3), NEW CGO COMPLEX

ITA 2844/DEL/2024[2014-15]Status: Disposed31 Jul 2025AY 2014-15Allowed

The Tribunal held that a notice issued under Section 148 of the Act in the name of a dead person is void ab initio. The entire reassessment proceeding is vitiated because the Assessing Officer failed to satisfy the prerequisite conditions for acquiring jurisdiction.