CIT v. RRJ Securities Ltd.

Deputy Commissioner of Income Tax, Delhi vs. Veena Gupta, Delhi

Appeal is dismissed for assessment year 2014-15 in the case of ACIT vs

Bench: Sh. M. Balaganesh & Sh. Sudhir Kumar

…ent year involved herein is 2014-15 i.e. beyond the maximum time period of assessment years from the date of section 153C satisfaction i.e. 16.01.2023 relevant to assessment year 2023-24. Various recent judicial precedents CIT-7 Vs. RRJ Securities Ltd. (2016) 380 ITR 612 (Del), PCIT Vs. Ojjus Medicare (P) Ltd., (2024) 465 ITR 101 (Del) and CIT Vs. Jasjit Singh (2024) 465 ITR 101 (SC) have already settled the issue against the department that the date of satisfaction u/s 153C(1) first proviso which has to be construed as the date of search for the purpose of computing the corresponding assessment years in question…

Deputy Commissioner of Income Tax, Delhi vs. Saurabh Maheshwari, Gurgaon

Appeal is dismissed for assessment year 2014-15 in the case of ACIT vs

Bench: Sh. M. Balaganesh & Sh. Sudhir Kumar

…ent year involved herein is 2014-15 i.e. beyond the maximum time period of assessment years from the date of section 153C satisfaction i.e. 16.01.2023 relevant to assessment year 2023-24. Various recent judicial precedents CIT-7 Vs. RRJ Securities Ltd. (2016) 380 ITR 612 (Del), PCIT Vs. Ojjus Medicare (P) Ltd., (2024) 465 ITR 101 (Del) and CIT Vs. Jasjit Singh (2024) 465 ITR 101 (SC) have already settled the issue against the department that the date of satisfaction u/s 153C(1) first proviso which has to be construed as the date of search for the purpose of computing the corresponding assessment years in question…

Deputy Commissioner of Income Tax, Delhi vs. Saurabh Maheshwari, Delhi

Appeal is dismissed for assessment year 2014-15 in the case of ACIT vs

Bench: Sh. M. Balaganesh & Sh. Sudhir Kumar

…ent year involved herein is 2014-15 i.e. beyond the maximum time period of assessment years from the date of section 153C satisfaction i.e. 16.01.2023 relevant to assessment year 2023-24. Various recent judicial precedents CIT-7 Vs. RRJ Securities Ltd. (2016) 380 ITR 612 (Del), PCIT Vs. Ojjus Medicare (P) Ltd., (2024) 465 ITR 101 (Del) and CIT Vs. Jasjit Singh (2024) 465 ITR 101 (SC) have already settled the issue against the department that the date of satisfaction u/s 153C(1) first proviso which has to be construed as the date of search for the purpose of computing the corresponding assessment years in question…

Deputy Commissioner of Income Tax, Delhi vs. Saurabh Maheshwari, Delhi

Appeal is dismissed for assessment year 2014-15 in the case of ACIT vs

Bench: Sh. M. Balaganesh & Sh. Sudhir Kumar

…ent year involved herein is 2014-15 i.e. beyond the maximum time period of assessment years from the date of section 153C satisfaction i.e. 16.01.2023 relevant to assessment year 2023-24. Various recent judicial precedents CIT-7 Vs. RRJ Securities Ltd. (2016) 380 ITR 612 (Del), PCIT Vs. Ojjus Medicare (P) Ltd., (2024) 465 ITR 101 (Del) and CIT Vs. Jasjit Singh (2024) 465 ITR 101 (SC) have already settled the issue against the department that the date of satisfaction u/s 153C(1) first proviso which has to be construed as the date of search for the purpose of computing the corresponding assessment years in question…

Pr. Commissioner of Income Tax -7, Delhi vs. Pragun Finance Pvt. Ltd

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

…Whether on the facts and circumstances of the case and in law, the Ld. ITAT is correct in holding that the notice u/s 153C of the Act is time barred by relying upon the judgment of the Hon’ble Delhi High Court in case of CIT-7 Vs RRJ Securities Ltd. (2016) 380 ITR 612 (Del) without appreciating that the judgment will not apply to the instant case pursuant to the amendment made in Section 153C by Finance Act, 2017?” 10. According to Mr. Rai, in terms of the amendment to Section 153C which came into effect on 01.04.2017, the judgment in the case of RRJ Securities Ltd. (supra) shall have no applicability…

DCIT, Central Circle-15, Delhi vs. Geeta Arora, Delhi

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalwith C.O. No.80/Del/2025 Assessment Year: 2011-12 Vs. Geeta Arora, Dcit, Central Circle-15, M-75, Greater Kailash, Delhi Part-1, New Delhi Pan: Aekpa4628J (Appellant) (Respondent/Cross-Objector) Assessee By Sh. Ved Jain, Adv. Ms. Uma Upadhayay, Ca Sh. Aditya Garg, Ar Department By Sh. Rajesh Chardra, Cit(Dr) Date Of Hearing 13.08.2025 Date Of Pronouncement 13.08.2025 Order Per Satbeer Singh Godara, Jm This Revenue’S Appeal Ita No.401/Del/2025 With Assessee’S Cross Objection C.O. No. 80/Del/2025 For Assessment Year 2011- 12, Arise Against The Commissioner Of Income Tax (Appeals)-26 [In Short, The “Cit(A)”], Delhi’S Order Dated 13.11.2024 Passed In Case No. 26/10127/2010-11, Involving Proceedings Under Section 153C

…year involved herein is 2011-12 i.e. beyond the maximum time period of 10 assessment years from the date of section 153C satisfaction i.e. 01.02.2022 relevant to assessment year 2022-23. Various recent judicial precedents CIT-7 Vs. RRJ Securities Ltd. (2016) 380 ITR 612 (Del), PCIT Vs. Ojjus Medicare (P) Ltd., (2024) 465 ITR 101 (Del) and CIT Vs. Jasjit Singh (2024) 465 ITR 101 (SC) have already settled the issue against the department that the date of satisfaction u/s 153C(1) first proviso which has to be construed as the date of search for the purpose of computing the corresponding assessment 2 | P a g e ITA…

Deputy Commissioner of Income, Delhi vs. Sperry Plast Ltd, Delhi

Bench: Shri Sunil Kumar Singh & Shri Brajesh Kumar Singh

…-13 i.e. AY 2007-08 10 AY 2012-13. Thus no notice could be issued under Section 153 C of the Act to reopen the Assessee's assessment for AY 2006-07. Reliance is placed on the decision of this Court in Commissioner of Income-tax-7 v. RRJ Securities Lid. (2016) 380 ITR 612 (Del) where this very question was examined and answered in favour of the Assessee and against the Revenue. 8. In RRJ Securities (supra), the Court after noticing the decision in SSP Aviation Lid. v. Deputy CIT (2012) 346 ITR 177 (Del), held as follows.…

ACIT, New Delhi vs. Nouvelle Securities Private Limited, New Delhi

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2012-13 Acit, Vs Nouvelle Securities Private Ltd., Cc-4, 43, Community Centre, Delhi. New Friends Colony, New Delhi. Pan: Aaacn0211F Co No.39/Del/2025 (Ita No.4996/Del/2024) Assessment Year: 2012-13 Nouvelle Securities Private Ltd., Vs. Acit, 43, Community Centre, Cc-4, New Friends Colony, Delhi New Delhi. Pan: Aaacn0211F (Appellant) (Respondent) Assessee By : Shri Biren Shah, Ca Revenue By : Shri Dheeraj Kumar Jain, Sr. Dr Date Of Hearing : 17.07.2025 Date Of Pronouncement : 31.07.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Revenue Against The Order Dated 21.08.2024 Of The Commissioner Of Income-Tax (Appeals)-23, New Delhi (Hereinafter Referred To As The Ld. First Appellate Authority Or ‘The Ld. Faa’, Co No.39/Del/2025 For Short) In Appeal No.Cit(A), Delhi-23/10079/2011-12 Arising Out Of The Appeal Before It Against The Order Dated 26.03.2024 Passed U/S 147 R.W.S. 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By The Acit, Cc-4, Delhi (Hereinafter Referred To As The Ld. Ao). The Assessee Has Filed Cross Objection.

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES: E : NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI ANUBHAV SHARMA, JUDICIAL MEMBER Assessment Year: 2012-13 ACIT, Vs Nouvelle Securities Private Ltd., CC-4, 43, Community Centre, Delhi. New Friends Colony, New Delhi. PAN: AAACN0211F CO No.39/Del/2025 (ITA No.4996/Del/2024) Assessment Year: 2012-13 Nouvelle Securities Private Ltd., Vs. ACIT, 43, Community Centre, CC-4, New Friends Colony, Delhi New Delhi. PAN: AAACN0211F (Appellant) (Respondent) Assessee by : Shri Biren Shah, CA Revenue by : Shri Dheeraj Kumar Jain, Sr. DR Date of Hearing…

DCIT Central Circle-27, New Delhi vs. Jasmine Buildmart Pvt Ltd, New Delhi

Bench: Shri Anubhav Sharma & Shri Avdhesh Kumar Mishraassessment Year: 2012-13 Dcit, Vs Jasmine Buildmart Pvt. Ltd., Central Circle-27, 406, Elegance Tower-8, New Delhi. Jsola District Centre, New Delhi – 110 025. Pan: Aaccj5119J Co No.34/Del/2023 (Ita No.1268/Del/2020) Assessment Year: 2012-13 Jasmine Buildmart Pvt. Ltd., Vs. Dcit, 406, Elegance Tower-8, Central Circle-27, Jsola District Centre, New Delhi. New Delhi – 110 025. Pan: Aaccj5119J (Appellant) (Respondent) Assessee By : Shri Vinod Kumar Bindal, Ca; Shri Anmol Jha, Advocate; & Ms Rinki Sharma, Itp. Revenue By : Shri Daya Inder Singh Sidhu, Cit-Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 30.07.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Revenue Against The Order Dated 22.11.2019 Of The Commissioner Of Income-Tax (Appeals)-3, Gurgaon Co No.34/Del/2020 (Hereinafter Referred To As Ld. First Appellate Authority Or In Short Ld. ‘Faa’) In Appeal No.44/Cit(A)(C)/Ggn/2014-15 Arising Out Of The Appeal Before It Against The Order Dated 24.03.2014 Passed U/S 153B(1)(B) R.W.S. 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By The Dcit, Central Circle-I, Faridabad (Hereinafter Referred To As The Ld. Ao). The Assessee Has Also Filed The Cross Objections.

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES: C : NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER AND SHRI AVDHESH KUMAR MISHRA, ACCOUNTANT MEMBER Assessment Year: 2012-13 DCIT, Vs Jasmine Buildmart Pvt. Ltd., Central Circle-27, 406, Elegance Tower-8, New Delhi. Jsola District Centre, New Delhi – 110 025. PAN: AACCJ5119J CO No.34/Del/2023 (ITA No.1268/Del/2020) Assessment Year: 2012-13 Jasmine Buildmart Pvt. Ltd., Vs. DCIT, 406, Elegance Tower-8, Central Circle-27, Jsola District Centre, New Delhi. New Delhi – 110 025. PAN: AACCJ5119J (Appellant) (Respondent) Assessee by : Shri Vinod Kumar Bindal,…