Financial Services Pvt. Ltd. v. Dy. CIT

457 ITR 647High Court2023#1186 most cited

What is Financial Services Pvt. Ltd. v. Dy. CIT authority for?

The amended Section 151 of the Income-tax Act, governing the sanction for reassessment proceedings under Sections 148 and 148A, applies to cases initiated under the new reassessment regime. The specified authority for granting such sanction becomes the Principal Chief Commissioner or Principal Director General if more than three years have elapsed from the end of the relevant assessment year.

95

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2024 to 2026.

Also referred to as

Siemens Financial Services v Dy CIT · section 151 · section 148 · section 148A · amended section 151 · pre-amended section 151 · specified authority · sanction for reassessment · Principal Chief Commissioner · Principal Director General · more than three years

Also reported as

154 Taxmann.com 159

Sections most often in play

Section 148Section 151Section 147Section 148ASection 149Section 144BSection 250Section 69A

Issues it is cited on

section 13asection 151(i)section 151(ii)within four yearsapproval under section 151section 282a(1)section 151(2)order under section 148a(d)section 151(1)specified authoritysanctioning authoritysection 65a

Judgments citing Financial Services Pvt. Ltd. v. Dy. CIT

Toyota Boshoku Corporation, Japan vs. Assistant Commissioner of Income Tax Circle 3(1)(1) International Taxation New Delhi, New Delhi

In the result, both the appeals of the Assessee are allowed

ITA 2462/DEL/2024[2016-2017]Status: DisposedITAT Delhi24 Dec 2025AY 2016-2017

Bench: Shri Vikas Awasthy & Shri M. Balaganesh

For Appellant: Shri Vishal Kalra, AdvFor Respondent: Shri Kashish Gupta, CA
Section 143(3)Section 144C(5)Section 148Section 148ASection 151

…otices will also have to go." ITA Nos. 2462 & 2463/Del/2024 Toyota Boshoku Corporation [emphasis added] 15. In a latter decision in Siemens Financial Services (P.) Ltd. v. Deputy Commissioner of Income-tax: 2023 SCC OnLine Bom 2822/[2023] 154 taxmann.com 159/457 ITR 647 (Bombay), the Bombay High Court reiterated the said view in the following words: "24. As per section 151 of the Act, the "specified authority" who has to grant his sanction for the purposes of section 148 and section 148A is the Principal Chief Commissioner or Principal Director General or where there is no Principal Chief Commissioner or Princip…

Brij Bhushan Kalia, Up vs. ITO, Ward-61(1), Delhi

Appeal is allowed in above terms

ITA 7624/DEL/2025[2017-18]Status: DisposedITAT Delhi23 Dec 2025AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 7624/Del/2025 : Asstt. Year: 2017-18 Brij Bhushan Kalia, Vs Income Tax Officer, C/O Chaurasia & Associates, Ward-61(1), C-2302, Ats Advantage, New Delhi-110002 Indirapuram, Ghaziabad-201014 (Appellant) (Respondent) Pan No. Aaepk9068Q Assessee By: Sh. Venketesh Chaurasia, Adv. Revenue By : Sh. Amit Shukla, Sr. Dr Date Of Hearing: 23.12.2025 Date Of Pronouncement: 23.12.2025 Order This Assessee’S Appeal For Assessment Year 2017-18 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1081596042(1) Dated 09.10.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Venketesh Chaurasia, AdvFor Respondent: Sh. Amit Shukla, Sr. DR
Section 13ASection 147Section 148Section 148ASection 29A

…xtends the time limits for completion of specified tasks up to March 31, 2021, itself becomes irrelevant because of the nature of the challenge in these writ petitions. 15. In Siemens Financial Services [Siemens Financial Services Pvt. Ltd. v. Dy. CIT, (2023) 457 ITR 647 (Bom); 2023 SCC OnLine Bom 2822; (2023) 154 taxmann.com 159 (Bom).] , the Division Bench of the Bombay High Court concluded, in substantially similar facts and circumstances, that the amended section 151 and not the preamended section 151 would apply. For reasons set out above, I concur with the conclusion in Siemens Financial Services [Siemens F…

Asb Designs LLP, New Delhi vs. Central Circle 26, Delhi

Appeal is allowed in above terms

ITA 6691/DEL/2025[2018-19]Status: DisposedITAT Delhi23 Dec 2025AY 2018-19

Bench: Sh. Satbeer Singh Godaraita No. 6691/Del/2025 : Asstt. Year: 2018-19 Asb Designs Llp, Vs Dcit, B-223, Naraina Industrial Area, Central Circle-26, New Delhi-110028 New Delhi-110001 (Appellant) (Respondent) Pan No. Abdfa1476G Assessee By: Sh. Sandeep Vijh, Ar Revenue By : Sh. Amit Shukla, Sr. Dr Date Of Hearing: 23.12.2025 Date Of Pronouncement: 23.12.2025 Order This Assessee’S Appeal For Assessment Year 2018-19 Arises Against The Cit(A)-29, New Delhi’S Order Dated 22.08.2025, In Case No. Cit(A), Delhi-29/10559/2017-18, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Sandeep Vijh, ARFor Respondent: Sh. Amit Shukla, Sr. DR
Section 13ASection 147Section 148Section 148ASection 29A

…xtends the time limits for completion of specified tasks up to March 31, 2021, itself becomes irrelevant because of the nature of the challenge in these writ petitions. 15. In Siemens Financial Services [Siemens Financial Services Pvt. Ltd. v. Dy. CIT, (2023) 457 ITR 647 (Bom); 2023 SCC OnLine Bom 2822; (2023) 154 taxmann.com 159 (Bom).] , the Division Bench of the Bombay High Court concluded, in substantially similar facts and circumstances, that the amended section 151 and not the preamended section 151 would apply. For reasons set out above, I concur with the conclusion in Siemens Financial Services [Siemens F…

Manishaben Dilip Vankar, Bharuch vs. The Dy.CIT, Circle- 1(1)(1), Vadodara

In the result, the appeal filed by the assessee is hereby allowed

ITA 691/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad19 Dec 2025AY 2016-17

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 143(1)Section 147Section 148Section 148ASection 149Section 149(1)Section 149(1)(b)Section 151Section 68Section 69C

…d the sanction for reopening is obtained not from Competent Authority thereby the entire reassessment proceedings is liable to be vitiated and relied upon Bombay High Court Judgment in the case of M/s. Siemens Financial Services (P.) Ltd. vs. DCIT reported in 457 ITR 647 (Bom) and other case laws. 6. Per contra, Ld. Sr. D.R. appearing for the Revenue supported the orders passed by the Lower Authorities and requested to uphold the same. 7. We have given our thoughtful consideration and perused the materials available on record and first adjudicate the jurisdiction issue. As per the amended provision of section 1…

Dy. Commissioner of Income Tax, Central Circle 3, Delhi vs. Pankaj Goel, Delhi

ITA 4159/DEL/2025[2017-18]Status: DisposedITAT Delhi17 Dec 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2017-18 Dy. Commissioner Of Vs. Sh. Pankaj Goel, Income Tax, 662/3A, Ghati Road, Central Circle-3, Anand Paravt, Central Delhi, Delhi New Delhi Pan: Aswpg8949E (Appellant) (Respondent) With C.O. No.236/Del/2025 [Arising Out Of Ita No.4159/Del/2025] Assessment Year: 2017-18 Sh. Pankaj Goel, Vs. Dy. Commissioner Of Income 662/3A, Ghati Road, Tax, Anand Paravt, Central Circle-3, Central Delhi, Delhi New Delhi Pan: Aswpg8949E (Appellant) (Respondent) Assessee By Ms. Mansi Jain, Adv. Sh. Siddharth Bajaj, Adv. Department By Sh. Siddharth Bhim Singh Meena, Cit(Dr) Date Of Hearing 08.12.2025 Date Of Pronouncement 17.12.2025 Order Per Satbeer Singh Godara, Jm This Revenue’S Appeal Ita No.4159/Del/2025 Along With Assessee’S Cross Objection C.O. No. 236/Del/2025 For Assessment & C.O. No.236/Del/2025

Section 13ASection 147Section 148Section 148ASection 151Section 29A

…xtends the time limits for completion of specified tasks up to March 31, 2021, itself becomes irrelevant because of the nature of the challenge in these writ petitions. 15. In Siemens Financial Services [Siemens Financial Services Pvt. Ltd. v. Dy. CIT, (2023) 457 ITR 647 (Bom); 2023 SCC OnLine Bom 2822; (2023) 154 taxmann.com 159 (Bom).] , the Division Bench of the Bombay High Court concluded, in substantially similar facts and circumstances, that the amended section 151 and not the preamended section 151 would apply. For reasons set out above, I concur with the conclusion in Siemens Financial Services [Siemens F…

Brijesh Chandwani, Hyderabad vs. DCIT., Circle -6(1), Hyderabad

In the result, appeal of the assessee for the assessment year 2020-2021 is allowed for statistical purposes

ITA 1528/HYD/2025[2020-2021]Status: DisposedITAT Hyderabad28 Nov 2025AY 2020-2021

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1527 & 1528/Hyd/2025 Assessment Years – 2016-2017 & 2020-2021 Brijesh Chandwani The Dcit, Circle-6(1), Vs. Hyderabad – 500 034 Hyderabad. Pan Adkpc1537H (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Pawan Kumar Chakrapani राज" व "ारा /Revenue By: Sri Ranjan Agrawala, Sr. Ar

For Appellant: CA Pawan Kumar ChakrapaniFor Respondent: Sri Ranjan Agrawala, Sr. AR
Section 133ASection 143(1)(a)Section 143(3)Section 147Section 148Section 148ASection 234A

…d 11.03.2025 for the assessment year 2017-2018, where under identical set of facts, the Tribunal by following certain judicial precedents including the decision of Hon’ble Bombay High Court in the case of Siemens Financial Services (P.) Ltd., vs., DCIT [2023] 457 ITR 647 (Bom.) held as under: 35 ITA.No.1527 & 1528/Hyd./2025 “7. We have heard the rival submissions of both the parties and perused the material available on record. There is no dispute between the parties that the assessee is a Non- Resident Indian. Admittedly, in the instant case, the assessment has been reopened u/sec.147 of the Act by issuance of…

Brijesh Chandwani, Hyderabad vs. DCIT., Circle -6(1), Hyderabad

The appeal of the Assessee is allowed on this ground alone

ITA 1527/HYD/2025[2016-2017]Status: DisposedITAT Hyderabad28 Nov 2025AY 2016-2017
For Appellant: CA Pawan Kumar ChakrapaniFor Respondent: Sri Ranjan Agrawala, Sr. AR
Section 133ASection 143(1)(a)Section 143(3)Section 147Section 148Section 148ASection 234A

…d 11.03.2025 for the assessment year 2017-2018, where under identical set of facts, the Tribunal by following certain judicial precedents including the decision of Hon'ble Bombay High Court in the case of Siemens Financial Services (P.) Ltd., vs., DCIT [2023] 457 ITR 647 (Bom.) held as under: "7. We have heard the rival submissions of both the parties and perused the material available on record. There is no dispute between the parties that the assessee is a Non- Resident Indian. Admittedly, in the instant case, the assessment has been reopened u/sec.147 of the Act by issuance of notice u/sec.148 of the Act dated…

Vinod Ojha, Hyderabad vs. Income Tax Officer, Ward-5(1), Hyderabad

In the result, appeal of the Assessee is allowed

ITA 1231/HYD/2024[2016-17]Status: DisposedITAT Hyderabad28 Nov 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1231/Hyd/2024 (िनधा"रण वष"/Assessment Year 2016-2017) Vinod Ojha, The Income Tax Officer, Ward-5(1), Hyderabad-500012. Vs. Hyderabad – 500 057. Telangana. Telangana. Pan Aahpo3171F (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Kumar Pal Tated राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit-Dr

For Appellant: CA Kumar Pal TatedFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 139(1)Section 144Section 147Section 148Section 149

…e decision of ITAT, Mumbai Bench in the case of Manish Jagdish Joshi vs. CIT ITA.No.1617/Mum./2024 and the Mumbai Bench of the Tribunal by following the decision of Hon’ble Bombay High Court in the case of Siemens Financial Services (P.) Ltd., vs. DCIT [2023] 457 ITR 647 (Bom.) held as under : “We find that while considering the similar issue and similar submissions the Hon'ble Jurisdictional High Court in 33 ITA.No.1231/Hyd./2024 Siemens Financial Services (P.) Ltd. v/s DCIT, (2023) 457 ITR 647 (Bom.) held that TOLA would not affect the scope of section 151 and sanction of Specified Authority was to be obtained…

Satendra Pal Singh, New Delhi vs. ITO, Ward 36(1), Delhi

Appeal is allowed

ITA 6627/DEL/2025[2016-17]Status: DisposedITAT Delhi26 Nov 2025AY 2016-17

Bench: Shri Satbeer Singh Godaraassessment Year: 2016-17 Sh. Satendra Pal Singh, Vs. Income Tax Officer, 155, Village-Dhaka, Ward-36(1), New Delhi Delhi Pan: Autps1163K (Appellant) (Respondent) Assessee By Sh. Satyajeet Goel, Adv. Department By Sh. Manoj Kumar, Sr. Dr

Section 13ASection 147Section 148Section 148ASection 151Section 29A

…xtends the time limits for completion of specified tasks up to March 31, 2021, itself becomes irrelevant because of the nature of the challenge in these writ petitions. 15. In Siemens Financial Services [Siemens Financial Services Pvt. Ltd. v. Dy. CIT, (2023) 457 ITR 647 (Bom); 2023 SCC OnLine Bom 2822; (2023) 154 taxmann.com 159 (Bom).] , the Division Bench of the Bombay High Court concluded, in substantially similar facts and circumstances, that the amended section 151 and not the preamended section 151 would apply. For reasons set out above, I concur with the conclusion in Siemens Financial Services [Siemens F…

Income Tax Officer, Ward-14(3), New Delhi vs. Kolahai Infotech Private Limited, Delhi

Accordingly, the cross objections for AY 2016-17 filed by the assessee is allowed

ITA 3554/DEL/2025[2017-18]Status: DisposedITAT Delhi26 Nov 2025AY 2017-18

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Ms. Amisha S. Gupt, CIT DR
Section 148Section 148ASection 151

…lhi High Court had referred to the earlier decisions including the decision rendered by the Bombay High Court in J M Financial & Investments Consultancy Services (P.) Ltd. v. ACIT [W.P. No. 1050 of 2020]; Siemens Financial Services (P.) Ltd. v. Dy. CIT [2023] 457 ITR 647 (Bom) and Vidyadhar Shetty v. Income Tax Officer, Ward 28(1)(1), Mumbai & Ors. [W.P. No. 10849 of 2024]; the Madras High Court in Ramachandran Shivan v. ITO [W.P. No.8570 of 2023] and the Orissa High Court in Ambika Iron and Steel (P.) Ltd. v. Pr. CIT [2023] 452 ITR 285 (Ori.) and had noted that the question as to which is the specified authority…

Income Tax Officer, Ward-14(3), Delhi vs. Kolahai Infotech Private Limited, Delhi

Accordingly, the cross objections for AY 2016-17 filed by the assessee is allowed

ITA 3553/DEL/2025[2016-17]Status: DisposedITAT Delhi26 Nov 2025AY 2016-17

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Ms. Amisha S. Gupt, CIT DR
Section 148Section 148ASection 151

…lhi High Court had referred to the earlier decisions including the decision rendered by the Bombay High Court in J M Financial & Investments Consultancy Services (P.) Ltd. v. ACIT [W.P. No. 1050 of 2020]; Siemens Financial Services (P.) Ltd. v. Dy. CIT [2023] 457 ITR 647 (Bom) and Vidyadhar Shetty v. Income Tax Officer, Ward 28(1)(1), Mumbai & Ors. [W.P. No. 10849 of 2024]; the Madras High Court in Ramachandran Shivan v. ITO [W.P. No.8570 of 2023] and the Orissa High Court in Ambika Iron and Steel (P.) Ltd. v. Pr. CIT [2023] 452 ITR 285 (Ori.) and had noted that the question as to which is the specified authority…

Imran Majeed, Srinagar vs. ITO, Ward 1, Srinagar

In the result, the appeal for the Asstt

ITA 586/ASR/2024[2019-20]Status: DisposedITAT Amritsar25 Nov 2025AY 2019-20

Bench: Dr. M. L. Meena & Sh. Udayan Dasgupta

For Appellant: Sh. Rohit Kapoor, Adv. &
Section 147Section 148Section 148ASection 151Section 151ASection 250

…s ITO Ward 5(1) Panvel WRIT PETITION NO. 10749 OF 2024 DATE 12 August 2024, on the issue of sanction obtained u/s 151 of the Act 61, where the Hon’ble court has also considered the decision of Siemens Financial Services Pvt Ltd vs DCIT - 8(2), Mumbai [2023] 457 ITR 647 (Bombay): 14. The relevant paragraph – 6 of the order is reproduced: “6. Apart from the petitioner's contention that the proceedings would stand covered by the decision of this Court in Hexaware Technologies Limited (supra), another contention as raised by the petitioner is in regard to the impugned notice also being contrary to the decision of…

Imran Majeed, Srinagar vs. ITO Ward 1, Srinagar

In the result, the appeal for the Asstt

ITA 585/ASR/2024[2018-19]Status: DisposedITAT Amritsar25 Nov 2025AY 2018-19

Bench: Dr. M. L. Meena & Sh. Udayan Dasgupta

For Appellant: Sh. Rohit Kapoor, Adv. &
Section 147Section 148Section 148ASection 151Section 151ASection 250

…s ITO Ward 5(1) Panvel WRIT PETITION NO. 10749 OF 2024 DATE 12 August 2024, on the issue of sanction obtained u/s 151 of the Act 61, where the Hon’ble court has also considered the decision of Siemens Financial Services Pvt Ltd vs DCIT - 8(2), Mumbai [2023] 457 ITR 647 (Bombay): 14. The relevant paragraph – 6 of the order is reproduced: “6. Apart from the petitioner's contention that the proceedings would stand covered by the decision of this Court in Hexaware Technologies Limited (supra), another contention as raised by the petitioner is in regard to the impugned notice also being contrary to the decision of…

Rakesh, Copernicus Marg vs. ITO Ward 43, Delhi

Appeal is allowed

ITA 6481/DEL/2025[2018-19]Status: DisposedITAT Delhi25 Nov 2025AY 2018-19

Bench: Shri Satbeer Singh Godaraassessment Year: 2018-19 Vs. Income Tax Officer, Sh. Rakesh, D-65, Pinces Park, Ward-43, Copernicus Marg, Delhi Delhi Pan: Bwppr4036R (Appellant) (Respondent) Assessee By Sh. Shikhar Garg, Ca Department By Sh. Manoj Kumar, Sr. Dr

Section 13ASection 147Section 148Section 148ASection 151Section 29A

…xtends the time limits for completion of specified tasks up to March 31, 2021, itself becomes irrelevant because of the nature of the challenge in these writ petitions. 15. In Siemens Financial Services [Siemens Financial Services Pvt. Ltd. v. Dy. CIT, (2023) 457 ITR 647 (Bom); 2023 SCC OnLine Bom 2822; (2023) 154 taxmann.com 159 (Bom).] , the Division Bench of the Bombay High Court concluded, in substantially similar facts and circumstances, that the amended section 151 and not the preamended section 151 would apply. For reasons set out above, I concur with the conclusion in Siemens Financial Services [Siemens F…

Sathi Bhai Sathyavrithan, Delhi vs. Income Tax Officer Ward 68(1), Civic Centre, New Delhi 110002, Delhi

Appeal is allowed

ITA 6274/DEL/2025[2017-18]Status: DisposedITAT Delhi24 Nov 2025AY 2017-18

Bench: Shri Satbeer Singh Godaraassessment Year: 2017-18 Vs. Income Tax Officer, Sathi Bhai Sathyavrithan, Rz 31-32, Roshan Mandi Ward-68(1), Surya Kiran Hospital, New Delhi Najafgarh, New Delhi Pan: Ayqps2816L (Appellant) (Respondent) Assessee By Sh. Pranshu Singhal, Ca Department By Sh. Manoj Kumar, Sr. Dr

Section 13ASection 147Section 148Section 148ASection 151Section 29A

…xtends the time limits for completion of specified tasks up to March 31, 2021, itself becomes irrelevant because of the nature of the challenge in these writ petitions. 15. In Siemens Financial Services [Siemens Financial Services Pvt. Ltd. v. Dy. CIT, (2023) 457 ITR 647 (Bom); 2023 SCC OnLine Bom 2822; (2023) 154 taxmann.com 159 (Bom).] , the Division Bench of the Bombay High Court concluded, in substantially similar facts and circumstances, that the amended section 151 and not the preamended section 151 would apply. For reasons set out above, I concur with the conclusion in Siemens Financial Services [Siemens F…

Neelam Jain, Delhi vs. Income Tax Officer Ward 36(1) Civic Centre, New Delhi 110002, Delhi

Appeal is allowed

ITA 6261/DEL/2025[2017-18]Status: DisposedITAT Delhi24 Nov 2025AY 2017-18

Bench: Shri Satbeer Singh Godaraassessment Year: 2017-18 Vs. Income Tax Officer, Neelam Jain, 374, Veer Apartment, Ward-36(1), Sector-103, Rohini, New Delhi Delhi Pan: Ajppj0908E (Appellant) (Respondent) Assessee By Sh. Pranshu Singhal, Ca Department By Sh. Manoj Kumar, Sr. Dr

Section 13ASection 147Section 148Section 148ASection 151Section 29A

…xtends the time limits for completion of specified tasks up to March 31, 2021, itself becomes irrelevant because of the nature of the challenge in these writ petitions. 15. In Siemens Financial Services [Siemens Financial Services Pvt. Ltd. v. Dy. CIT, (2023) 457 ITR 647 (Bom); 2023 SCC OnLine Bom 2822; (2023) 154 taxmann.com 159 (Bom).] , the Division Bench of the Bombay High Court concluded, in substantially similar facts and circumstances, that the amended section 151 and not the preamended section 151 would apply. For reasons set out above, I concur with the conclusion in Siemens Financial Services [Siemens F…

Shambhu Dayal Soni, Ramganj Bazar vs. Income Tax Officer Ward 2(1), Jaipur

In the result, the appeal of the assessee is allowed

ITA 921/JPR/2025[2017-18]Status: DisposedITAT Jaipur20 Nov 2025AY 2017-18
For Appellant: Sh. S. L. Poddar, AdvFor Respondent: Sh. Gautam Singh Choudhary, Addl. CIT
Section 115BSection 147Section 148Section 148ASection 149(1)(b)Section 151(2)Section 69A

…d authority and none else. The power conferred upon a specific authority must be exercised by such authority only. It cannot be abdicated in favour of another authority, nor delegated to a lower authority. (2) Seimens Financial Services P. Ltd Vs. DCIT (2023) 457 ITR 647 (Bombay) Approval/sanction by PCIT was wrong, it was required from PCCIT as the assessment year involved was beyond three years from the end of the relevant assessment year. Sanction granted by CIT invalid. (3) Chandra Kanta Vithal Bhopai Vs. ITO (2025) 74 CCH 0012 (ITAT Pune) In the case, the approval granted by PCIT is invalid as the same sho…

Praveen Kumar Diddige, Medak vs. Income Tax Officer, Ward-1, Sangareddy

In the result, appeal of the Assessee is allowed

ITA 1370/HYD/2025[2017-18]Status: DisposedITAT Hyderabad19 Nov 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1370/Hyd/2025 Assessment Year – 2017-2018 Praveen Kumar The Income Tax Officer, Diddige, Medak Ward-1, Sangareddy. Vs. Pin – 502 291. Pin – 502001. Pan Aeapd8792G Telangana. (Appellant) (Respondent) Ca Pv Raghavendra Kumar िनधा"रती "ारा /Assessee By: & Ca K A Sai Prasad राज" व "ारा /Revenue By: Sri R. Kumaran, Sr. Ar

For Appellant: And CA K A Sai PrasadFor Respondent: Sri R. Kumaran, Sr. AR
Section 144Section 147Section 148Section 151

…ssment year 2017-2018, where under identical set of facts, the Tribunal by following certain judicial precedents including the decision of Hon’ble Bombay 8 ITA.No.1370/Hyd./2025 High Court in the case of Siemens Financial Services (P.) Ltd., vs., DCIT [2023] 457 ITR 647 (Bom.) held as under: “7. We have heard the rival submissions of both the parties and perused the material available on record. There is no dispute between the parties that the assessee is a Non-Resident Indian. Admittedly, in the instant case, the assessment has been reopened u/sec.147 of the Act by issuance of notice u/sec.148 of the Act dated…

Income Tax Officer, Ward-1, Nellore vs. Venkata Ramanamma Sakamuri, Nellore

In the result, the appeal filed by the revenue being devoid and bereft of any substance is dismissed

ITA 482/HYD/2025[2018-19]Status: DisposedITAT Hyderabad14 Nov 2025AY 2018-19

Bench: Us:

Section 147Section 148Section 148ASection 151

…d. CIT(A) is correct in allowing the assessee's appeal on 31.12.2024 relying on the order dated 01.10.2024 of the Hon'ble ITAT, Mumbai, which in turn relied on the judgement of Hon'ble Bombay High Court in Siemens Financial Services (P.) Ltd. v/s DCIT, (2023) 457 ITR 647 (Bom.), which was overturned by the Hon'ble Supreme Court vide judgement dated 03.10.2024 in TOLA case in Civil Appeal No. 8629 of 2024? (ii) Whether the order of the Ld. CIT(A) is correct in quashing the notice u/s. 148 of the Act when the show cause notice u/s. 148A(b) was issued before 31.03.2022 and order u/s 148A(d) & notice u/s 148 were als…

Rajbir Singh, Gurgaon vs. ACIT, Central Circle-19, New Delhi

In the result, Appeal of the Assessee is allowed

ITA 3104/DEL/2025[2013-14]Status: DisposedITAT Delhi14 Nov 2025AY 2013-14

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Rajbir Singh Vs. Acit 1625A, The Magnolia, Dlf Central Circle-19, City, Phase-V, Gurgaon, Khandewalan, Haryana New Delhi Pan: Aaups2176H Appellant Respondent Assessee By Sh. Amarjeet Singh, Ca Revenue By Sh. Om Prakash, Sr. Dr Date Of Hearing 17/09/2025 Date Of Pronouncement 14/11/2025 Order

Section 13ASection 148Section 148ASection 151Section 29A

…s the time limits for completion o f specified tasks up to March 31, 2021, itself becomes irrelevant because o f the nature o f the challenge in these writ petitions . 15. In Siemens Financial Services [Siemens Financial Services Pvt. Ltd. v . Dy. CIT, (2023) 457 ITR 647 (Bom); 2023 SCC OnLineBom 2822; (2023) 154 taxmann .com 159 (Bom) .] , the Division Bench of the Bombay High Court concluded , in substantially similar facts and circum stances, that the amended section 151 and no t the preamended section 151 would apply. For reasons set out above , I concur with the conclusion in Siemens Financial Services [Siem…