Prashant Soni, New Delhi vs. DCIT, Central Circle-7, Delhi
In the result, the appeal of the assessee is allowed
ITA 2612/DEL/2022[2015-16]Status: DisposedITAT Delhi30 Dec 2025AY 2015-16
Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanprashant Soni, Vs. Dcit, Central Circle 7, M-50, First Floor, Delhi. Guru Harkishan Nagar, Sunder Vihar, New Delhi – 110 087. (Pan : Basps5961H) (Appellant) (Respondent) Assessee By : Shri Ankit Kumar, Advocate Revenue By : Shri Jitender Singh, Cit Dr Date Of Hearing : 17.11.2025 Date Of Order : 30.12.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)-24, New Delhi [Hereinafter Referred To As ‘Ld. Cit (A)] Dated 30.08.2022 For Assessment Year 2015-16. 2. At The Outset, Ld. Ar Of The Assessee Raised Legal Issue Relating To Assumption Of Jurisdiction Under Section 153C Of The Income-Tax Act, 1961 (For Short ‘The Act’) By Raising Ground Nos.1 & 2 Which Read As Under :- “1. On The Facts & Circumstances Of The Case, The Order Passed By The Ld. Ao & Impugned Order Passed By The Cit (A) Is Bad Both In The Eye Of Law & On Facts.
For Appellant: Shri Ankit Kumar, AdvocateFor Respondent: Shri Jitender Singh, CIT DR
Section 132Section 132(4)Section 153ASection 153BSection 153CSection 292C
…tted that the Assessing Officer has proceeded on a complete misconception of factual matrix of the appellant and statutory provisions of law and reliance is placed on the following judgments: 6 i) 386 ITR 680 (Del) CIT v. Nikki Drugs & Chemicals (P) Ltd. ii) 380 ITR 612 (Del) CIT v. RRJ Securities 9. He further submitted that the plain reading of the satisfaction note would show that proceedings have been initiated to make fishing and roving enquiries and thus conduct fresh examination, which is not permissible in law and reliance is placed on the following decisions: i) ITA No.2637/Del/2010 dated 27.11.2013 AC…
