ATS Infrastructure Ltd. v. ACIT

166 Taxmann.com 61High Court2024#4646 most cited

What is ATS Infrastructure Ltd. v. ACIT authority for?

Once an addition made based on original reasons recorded for reopening is deleted, other additions not part of those original reasons cannot be sustained.

26

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2024 to 2026.

Also referred to as

ATS Infrastructure Ltd v ACIT · section 148 · income escaping assessment · additions · original reasons · reopening · deleted additions · other additions · sustaining additions

Issues it is cited on

Judgments citing ATS Infrastructure Ltd. v. ACIT

ACIT, NEW DELHI vs. VRINDA FARMS PRIVATE LIMITED, NEW DELHI

In the result, the appeal of the Revenue as well as cross objections of the assessee are dismissed

ITA 4849/DEL/2024[2016-17]Status: DisposedITAT Delhi29 Oct 2025AY 2016-17

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Acit, Central Circle 4, Vs. Vrinda Farms Private Limited, New Delhi. 43, Community Centre, Bhageria House, Zakir Nagar, New Friends Colony, New Delhi – 110 025. (Pan : Aaacv0355L) Co Nos.13 & 19/Del/2025 (In Ita No.4849/Del/2024) (Assessment Year: 2016-17) Vrinda Farms Private Limited, Vs. Acit, Central Circle 4, 43, Community Centre, New Delhi. Bhageria House, Zakir Nagar, New Friends Colony, New Delhi – 110 025. (Pan : Aaacv0355L) (Appellant) (Respondent) Assessee By : Shri Biren Shah, Ca Revenue By : Shri Dheeraj Kumar Jain, Sr. Dr Date Of Hearing : 02.09.2025 Date Of Order : 29.10.2025 Order Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Revenue Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-23, New Delhi [“Ld. Cit(A)”, For Short]

For Appellant: Shri Biren Shah, CAFor Respondent: Shri Dheeraj Kumar Jain, Sr. DR
Section 132(4)Section 133(6)Section 68

…9IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’: NEW DELHI BEFORE SHRIS.RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER ACIT, Central Circle 4, vs. Vrinda Farms Private Limited, New Delhi. 43, Community Centre, Bhageria House, Zakir Nagar, New Friends Colony, New Delhi – 110 025. (PAN : AAACV0355L) CO Nos.13 & 19/Del/2025 (in ITA No.4849/DEL/2024) (Assessment Year: 2016-17) Vrinda Farms Private Limited, vs. ACIT, Central Circle 4, 43, Community Centre, New Delhi. Bhageria House, Zakir Nagar, New Friends Colony, New Delhi – 110 025. (PAN : AAACV0355L) (APPELLANT) (RESPONDENT) ASS…

ARVIND JAIN,DELHI vs. ITO WARD 5(1)(1), UTTAR PRADESH

Appeal is allowed

ITA 5173/DEL/2025[2013-14]Status: DisposedITAT Delhi24 Sept 2025AY 2013-14

Bench: Sh. Satbeer Singh Godaraita No. 5173/Del/2025 : Asstt. Year : 2013-14 Arvind Jain, Vs Income Tax Officer, 487, 11Nd Floor, Haveli Haider Kuli, Ward-5(1)(1), Chandni Chowk, Delhi-110006 Gautam Budh Nagar, Noida-201301 (Appellant) (Respondent) Pan No. Acapj9132E Assessee By: Sh. S. S. Nagar, Ca Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 24.09.2025 Date Of Pronouncement: 24.09.2025 Order This Assessee’S Appeal For Assessment Year 2013-14, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1077776400(1) Dated 25.06.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. S. S. Nagar, CAFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 147Section 148

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘SMC’, NEW DELHI Before Sh. Satbeer Singh Godara, Judicial Member ITA No. 5173/Del/2025 : Asstt. Year : 2013-14 Arvind Jain, Vs Income Tax Officer, 487, 11nd Floor, Haveli Haider Kuli, Ward-5(1)(1), Chandni Chowk, Delhi-110006 Gautam Budh Nagar, Noida-201301 (APPELLANT) (RESPONDENT) PAN No. ACAPJ9132E Assessee by: Sh. S. S. Nagar, CA Revenue by : Sh. Manoj Kumar, Sr. DR Date of Hearing: 24.09.2025 Date of Pronouncement: 24.09.2025 ORDER This assessee’s appeal for Assessment Year 2013-14, arises against the CIT(A)/NFAC, Delhi’s DIN & order No. ITBA/NFAC/S/250/20…

SH. ASHOK KUMAR,HARIDWAR vs. ITO, HARIDWAR

In the result, the appeal of the assessee is allowed

ITA 107/DDN/2025[2015-16]Status: DisposedITAT Dehradun17 Sept 2025AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalashok Kumar, Assessment Unit, 19, Sitapur Mazara, Jwalapur, Income Tax Haridwar, Uttarakhand-249407 Vs. Department. Pan-Btupk9604E (Appellant) (Respondent) Assessee By Shri Pankaj Goel, Adv. Department By Shri A. S. Rana, Sr. Dr Date Of Hearing 08/09/2025 Date Of Pronouncement 17/09/2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (‘The Ld. Cit(A)’ For Short) In Appeal No. Nfac/2014-15/10271519 Dated 10.04.2025 For Assessment Year 2015-16. 2. Brief Facts Of The Case Are That The Assessee Is An Agriculturist Having No Any Other Source Of Income Than Agricultural Income. Since, The Income From Agricultural Operations Is Exempt From Tax, He Was Not Obliged To File The Return Of Income. The Assessing Officer Based On The Information That Assessee Has Deposited A Sum Of Rs.76,00,000/- In Zila Sahkari Bank Ltd., Initiated Reassessment Proceedings In The Case Of Assessee By Recording Reasons That Income To The Extent Of Rs.76,00,000/- Has Escaped Assessment In The Order Passed U/S 148A(D) Of The Act. Accordingly, Notices U/S 148 Was Issued On 26.03.2022. In Response To Which Assessee Filed Return Of Income On 12.04.2022 Ashok Kumar Vs. Ito Declaring Total Income Of Rs.10,00,000/- From Agriculture Activity & Claimed The Same As Exempt From Tax. The Assessing Officer Passed The Reassessment Order Wherein He Has Made The Additions On Account Of Agriculture Income Of Rs.10,00,000/- By Treating The Same As Income From Other Sources & Further Made Additions Of Rs.76,00,000/- Being Cash Deposited During Demonetization As Unexplained Money U/S 69A Of The Act. The Ao Further Made Additions Of Rs.2,67,195/- As Against Nil Income Declared Towards Bank Interest.

Section 147Section 148Section 148ASection 69A

…IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN BENCH: DEHRADUN BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER Ashok Kumar, Assessment Unit, 19, Sitapur Mazara, Jwalapur, Income Tax Haridwar, Uttarakhand-249407 Vs. Department. PAN-BTUPK9604E (Appellant) (Respondent) Assessee by Shri Pankaj Goel, Adv. Department by Shri A. S. Rana, Sr. DR Date of Hearing 08/09/2025 Date of Pronouncement 17/09/2025 O R D E R PER MANISH AGARWAL, AM: This appeal is filed by the assessee against the order of Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFA…

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