DIVYA CAPITAL ONE\nPRIVATE LIMITED v. ACIT

445 ITR 436High Court2022#14209 most cited
7

judgments rely on this decision, according to BharatTax’s citation analysis of 344,197 Indian tax judgments — from 2024 to 2025.

Sections most often in play

Section 147Section 148Section 148ASection 148A(b)Section 148A(d)Section 250Section 68

Issues it is cited on

section 148bsanction under section 151order under section 148a(d)approval under section 151paper companymaximum marginal rateshort term capital gainsnon application of mindsection 148a(b)section 148a(d)specified authoritynon-application of mind

Judgments citing DIVYA CAPITAL ONE\nPRIVATE LIMITED v. ACIT

North East Hire Purchase Company (India) Pvt.Ltd., Guwahati vs. ITO Ward 1(2), Guwahati

Appeal of the assessee is allowed

ITA 201/GTY/2025[2018-19]Status: DisposedITAT Guwahati21 Nov 2025AY 2018-19

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI MANOMOHAN DAS (Judicial Member)

Section 147Section 148Section 148ASection 250Section 68

…hich was available with the assessing officer at the time of issuance of notice under section 148A(b) of the Act which has led to an erroneous order dated 7th April, 2022 being passed. 7. In Divya Capital One (P.) Ltd. v. Asstt. CIT [2022] 139 taxmann.com 461/445 ITR 436 (Delhi), the Court had considered the new re-assessment claim and held as follows: "7. This Court is of the view that the new re-assessment scheme (vide amended sections 147 to 151 of the Act) was introduced by the Finance Act, 2021 with the intent of reducing litigation and to promote ease of doing business. In fact, the legislature brought in…

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Rosha Alloys Pvt. Ltd., Mandi Gobindgarh

In the result, the appeals filed by the Revenue are dismissed,

ITA 923/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh28 May 2025AY 2020-21
Section 148BSection 151

…DAS (1976) 3 SCC 757, (103 ITR 457). Though this decision was rendered long before the amendment to the subject section was effected, its inner voice animates the Division Bench decision of Delhi High Court in DIVYA CAPITAL ONE PRIVATE LIMITED vs. ACIT [2022] 445 ITR 436 (Del), (Refer page no. 158 to 165 of case law index book) that has been rendered post- amendment. (b) If one looks at the reasons given in the notices in question, as also in the impugned orders that followed the said notices, it becomes evident that they merely mention that, information was received in line with the risk management strategy. The…

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Rosha Alloys Pvt. Ltd., Mandi Gobindgarh

In the result, the appeals filed by the Revenue are dismissed,

ITA 922/CHANDI/2024[2019-20]Status: DisposedITAT Chandigarh28 May 2025AY 2019-20
Section 148BSection 151

…DAS (1976) 3 SCC 757, (103 ITR 457). Though this decision was rendered long before the amendment to the subject section was effected, its inner voice animates the Division Bench decision of Delhi High Court in DIVYA CAPITAL ONE PRIVATE LIMITED vs. ACIT [2022] 445 ITR 436 (Del), (Refer page no. 158 to 165 of case law index book) that has been rendered post- amendment. (b) If one looks at the reasons given in the notices in question, as also in the impugned orders that followed the said notices, it becomes evident that they merely mention that, information was received in line with the risk management strategy. The…

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Rosha Alloys Pvt. Ltd., Mandi Gobindgarh

In the result, the appeals filed by the Revenue are dismissed,

ITA 921/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh28 May 2025AY 2018-19
Section 148BSection 151

…DAS (1976) 3 SCC 757, (103 ITR 457). Though this decision was rendered long before the amendment to the subject section was effected, its inner voice animates the Division Bench decision of Delhi High Court in DIVYA CAPITAL ONE PRIVATE LIMITED vs. ACIT [2022] 445 ITR 436 (Del), (Refer page no. 158 to 165 of case law index book) that has been rendered post- amendment. (b) If one looks at the reasons given in the notices in question, as also in the impugned orders that followed the said notices, it becomes evident that they merely mention that, information was received in line with the risk management strategy. The…

Rosha Alloys P Limited, Amloh Road, Village Turan, Mandi Gobindgarh, Punjab vs. DCIT Central Circle 1, Ludhiana, Punjab

In the result, the appeals filed by the Revenue are dismissed,

ITA 888/CHANDI/2024[2018-2019]Status: DisposedITAT Chandigarh28 May 2025AY 2018-2019
Section 148BSection 151

…DAS (1976) 3 SCC 757, (103 ITR 457). Though this decision was rendered long before the amendment to the subject section was effected, its inner voice animates the Division Bench decision of Delhi High Court in DIVYA CAPITAL ONE PRIVATE LIMITED vs. ACIT [2022] 445 ITR 436 (Del), (Refer page no. 158 to 165 of case law index book) that has been rendered post- amendment. (b) If one looks at the reasons given in the notices in question, as also in the impugned orders that followed the said notices, it becomes evident that they merely mention that, information was received in line with the risk management strategy. The…

Vivog Commercial Limited, Mumbai vs. DCIT, Circle -5(1), Kolkata

In the result, the connected application for stay (IA No

ITA 1631/KOL/2024[2014-15]Status: DisposedITAT Kolkata27 Nov 2024AY 2014-15

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Siddarth Agarwal, ARFor Respondent: Shri Kumar Ashutosh, DR
Section 144BSection 147Section 148Section 148A

…ich was available with the assessing officer at the time of issuance of notice under section 148A(b) of the Act which has led to an erroneous order dated 7th April, 2022 being passed. 7. In Divya Capital One (P.) Ltd. v. Asstt. CIT [2022] 139 taxmann.com 461/445 ITR 436 (Delhi), the Court had considered the new re-assessment claim and held as follows: "7. This Court is of the view that the new re-assessment scheme (vide amended sections 147 to 151 of the Act) was introduced by the Finance Act, 2021 with the intent of reducing litigation and to promote ease of doing business. In fact, the legislature brought in…

Vivog Commercial Limited, Mumbai vs. DCIT, Circle -5(1), Kolkata

In the result, the connected application for stay (IA No

ITA 1630/KOL/2024[2013-14]Status: DisposedITAT Kolkata27 Nov 2024AY 2013-14

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Siddarth Agarwal, ARFor Respondent: Shri Kumar Ashutosh, DR
Section 144BSection 147Section 148Section 148A

…ich was available with the assessing officer at the time of issuance of notice under section 148A(b) of the Act which has led to an erroneous order dated 7th April, 2022 being passed. 7. In Divya Capital One (P.) Ltd. v. Asstt. CIT [2022] 139 taxmann.com 461/445 ITR 436 (Delhi), the Court had considered the new re-assessment claim and held as follows: "7. This Court is of the view that the new re-assessment scheme (vide amended sections 147 to 151 of the Act) was introduced by the Finance Act, 2021 with the intent of reducing litigation and to promote ease of doing business. In fact, the legislature brought in…

DIVYA CAPITAL ONE\nPRIVATE LIMITED v. ACIT (445 ITR 436) — Cited in 7 Judgments | BharatTax