New Delhi Television Ltd. v. DCIT

116 Taxmann.com 151Supreme Court of India2020#734 most cited

What is New Delhi Television Ltd. v. DCIT authority for?

Reassessment initiated under Section 147/148 is invalid if the Assessing Officer relies on material obtained post-recording of reasons, or if it amounts to a mere change of opinion on facts fully and truly disclosed by the assessee during the original assessment. An assessee's obligation extends only to the full and true disclosure of primary facts, not to provide further assistance or inferences.

139

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2012 to 2026.

Also referred to as

New Delhi Television Ltd. v. DCIT · Section 147 · Section 148 · Income Tax Act 1961 · reassessment validity · mere change of opinion · full and true disclosure · primary facts · reasons recorded · material post-recording · Kelvinator principle · first proviso to section 147

Also reported as

424 ITR 607271 Taxmann 1

Sections most often in play

Section 143(3)Section 147Section 1961Section 148Section 142(1)Section 153CSection 132Section 151
Read the full judgment

Issues it is cited on

section 292c(1)(i)section 292c(1)full and true disclosurebeyond four yearstrue and full disclosurefirst proviso to section 147fresh tangible materialmaterial facts necessary for assessmentmere change of opinionkelvinatorsection 35dsection 151(2)

Judgments citing New Delhi Television Ltd. v. DCIT

DCIT, Circle-7(1), Delhi vs. Dlf Limited, Delhi

In the result, appeal of the Revenue is dismissed

ITA 715/DEL/2024[2021-22]Status: DisposedITAT Delhi30 Oct 2025AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

…ITA No.713/Del/2024 & Others THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER & SHRI MANISH AGARWAL, ACCOUNTANT MEMBER Sl.No. ITA No. AY Name of Name of Appellant Respondent 1. 713/Del/2024 2019-20 DCIT, DLF Limited [Revenue’s Circle-7(1) 9th Floor, DLF appeal] Delhi-110002 Centre, Sansad Marg H.O.Sansad Marg, New Delhi- 110001 PAN-AAACD3494N 2. 714/Del/2024 2020-21 DCIT, DLF Limited [Revenue’s Circle-7(1) 9th Floor, DLF appeal] Delhi-110002 Centre, Sansad Marg H.O.Sansad Marg, New Delhi- 110001 PAN-AAACD3494N 3. 715/Del/2024 2021-22 DCIT, DLF Limite…

DCIT, Circle-7(1), Delhi vs. Dlf Limited, Delhi

In the result, appeal of the Revenue is dismissed

ITA 714/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Oct 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

…ITA No.713/Del/2024 & Others THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER & SHRI MANISH AGARWAL, ACCOUNTANT MEMBER Sl.No. ITA No. AY Name of Name of Appellant Respondent 1. 713/Del/2024 2019-20 DCIT, DLF Limited [Revenue’s Circle-7(1) 9th Floor, DLF appeal] Delhi-110002 Centre, Sansad Marg H.O.Sansad Marg, New Delhi- 110001 PAN-AAACD3494N 2. 714/Del/2024 2020-21 DCIT, DLF Limited [Revenue’s Circle-7(1) 9th Floor, DLF appeal] Delhi-110002 Centre, Sansad Marg H.O.Sansad Marg, New Delhi- 110001 PAN-AAACD3494N 3. 715/Del/2024 2021-22 DCIT, DLF Limite…

DCIT, Circle-7(1), Delhi vs. Dlf Limited, Delhi

In the result, appeal of the Revenue is dismissed

ITA 713/DEL/2024[2019-20]Status: DisposedITAT Delhi30 Oct 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

…ITA No.713/Del/2024 & Others THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER & SHRI MANISH AGARWAL, ACCOUNTANT MEMBER Sl.No. ITA No. AY Name of Name of Appellant Respondent 1. 713/Del/2024 2019-20 DCIT, DLF Limited [Revenue’s Circle-7(1) 9th Floor, DLF appeal] Delhi-110002 Centre, Sansad Marg H.O.Sansad Marg, New Delhi- 110001 PAN-AAACD3494N 2. 714/Del/2024 2020-21 DCIT, DLF Limited [Revenue’s Circle-7(1) 9th Floor, DLF appeal] Delhi-110002 Centre, Sansad Marg H.O.Sansad Marg, New Delhi- 110001 PAN-AAACD3494N 3. 715/Del/2024 2021-22 DCIT, DLF Limite…

Dlf Limited, Delhi vs. National Faceless Assessment Centre, Delhi

In the result, appeal of the Revenue is dismissed

ITA 677/DEL/2024[2021-22]Status: DisposedITAT Delhi30 Oct 2025AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

…ITA No.713/Del/2024 & Others THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER & SHRI MANISH AGARWAL, ACCOUNTANT MEMBER Sl.No. ITA No. AY Name of Name of Appellant Respondent 1. 713/Del/2024 2019-20 DCIT, DLF Limited [Revenue’s Circle-7(1) 9th Floor, DLF appeal] Delhi-110002 Centre, Sansad Marg H.O.Sansad Marg, New Delhi- 110001 PAN-AAACD3494N 2. 714/Del/2024 2020-21 DCIT, DLF Limited [Revenue’s Circle-7(1) 9th Floor, DLF appeal] Delhi-110002 Centre, Sansad Marg H.O.Sansad Marg, New Delhi- 110001 PAN-AAACD3494N 3. 715/Del/2024 2021-22 DCIT, DLF Limite…

Dlf Limited, Delhi vs. National Faceless Assessment Centre, Delhi

In the result, appeal of the Revenue is dismissed

ITA 676/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Oct 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

…ITA No.713/Del/2024 & Others THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER & SHRI MANISH AGARWAL, ACCOUNTANT MEMBER Sl.No. ITA No. AY Name of Name of Appellant Respondent 1. 713/Del/2024 2019-20 DCIT, DLF Limited [Revenue’s Circle-7(1) 9th Floor, DLF appeal] Delhi-110002 Centre, Sansad Marg H.O.Sansad Marg, New Delhi- 110001 PAN-AAACD3494N 2. 714/Del/2024 2020-21 DCIT, DLF Limited [Revenue’s Circle-7(1) 9th Floor, DLF appeal] Delhi-110002 Centre, Sansad Marg H.O.Sansad Marg, New Delhi- 110001 PAN-AAACD3494N 3. 715/Del/2024 2021-22 DCIT, DLF Limite…

Ashish Kalra, New Delhi vs. ACIT, Central Circle-4, New Delhi

In the result, the appeal of the assessee for Assessment Year 2008-09 in ITA

ITA 4309/DEL/2019[2009-10]Status: DisposedITAT Delhi14 Oct 2025AY 2009-10

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.4309/Del/2019 (Assessment Year 2009-10) Mr. Ashish Kalra Acit, C-3/313, Mig Flats, Janakpuri, Central Circle-4, New Delhi-110058. Vs. New Delhi. Pan-Aippk0526N (Appellant) (Respondent) Assessee By Shri Tarandeep Singh, Adv. Department By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 16/07/2025 Date Of Pronouncement 14/10/2025 O R D E R Per Manish Agarwal, Am: These Two Appeals Are Filed By The Assessee Against The Common Order Of Ld. Commissioner Of Income Tax (Appeals)-23, New Delhi [Cit(A), In Short] Dated 28.01.2019 In Appeal No. 159/2016-17 & 3/2017-18 For Asst. Years 2008-09 & 2009-10 Respectively, Both Arising Out Of Order Passed U/S 147 R.W.S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’). 2. Since, Both The Appeals Are Having Identical Issues, Therefore, They Are Adjudicated By A Common Order. First We Take Up The Appeal For Assessment Year 2008-09 In Ita No.4308/Del/2019. Ashish Kalra Vs. Acit

Section 139(1)Section 147Section 148Section 153CSection 251

…herwise or by relying upon any further material not forming part of reasons recorded. Reasons recorded are to be read as it is. Material obtained post recording of reasons cannot be used to validate reopening. Refer: Ashish Kalra vs. ACIT  NDTV reported in 424 ITR 607(SC) - copy enclosed at pages 377 to 400 of PB relevant at pages 398-399.  Abha Gupta reported in (2025) 173 taxmann.com 834(Del) - copy enclosed at pages 412 to 417 of PB relevant at page 416 of PB, para 11 4. ITSC order dated 30-05-2014 (copy enclosed at pages 115 to 132 of the PB) in case of M/s Bright Group and dated 30-05-2014 in case of Mr.…

Ashish Kalra, New Delhi vs. ACIT, Central Circle-4, New Delhi

In the result, the appeal of the assessee for Assessment Year 2008-09 in ITA

ITA 4308/DEL/2019[2008-09]Status: DisposedITAT Delhi14 Oct 2025AY 2008-09

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.4309/Del/2019 (Assessment Year 2009-10) Mr. Ashish Kalra Acit, C-3/313, Mig Flats, Janakpuri, Central Circle-4, New Delhi-110058. Vs. New Delhi. Pan-Aippk0526N (Appellant) (Respondent) Assessee By Shri Tarandeep Singh, Adv. Department By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 16/07/2025 Date Of Pronouncement 14/10/2025 O R D E R Per Manish Agarwal, Am: These Two Appeals Are Filed By The Assessee Against The Common Order Of Ld. Commissioner Of Income Tax (Appeals)-23, New Delhi [Cit(A), In Short] Dated 28.01.2019 In Appeal No. 159/2016-17 & 3/2017-18 For Asst. Years 2008-09 & 2009-10 Respectively, Both Arising Out Of Order Passed U/S 147 R.W.S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’). 2. Since, Both The Appeals Are Having Identical Issues, Therefore, They Are Adjudicated By A Common Order. First We Take Up The Appeal For Assessment Year 2008-09 In Ita No.4308/Del/2019. Ashish Kalra Vs. Acit

Section 139(1)Section 147Section 148Section 153CSection 251

…herwise or by relying upon any further material not forming part of reasons recorded. Reasons recorded are to be read as it is. Material obtained post recording of reasons cannot be used to validate reopening. Refer: Ashish Kalra vs. ACIT  NDTV reported in 424 ITR 607(SC) - copy enclosed at pages 377 to 400 of PB relevant at pages 398-399.  Abha Gupta reported in (2025) 173 taxmann.com 834(Del) - copy enclosed at pages 412 to 417 of PB relevant at page 416 of PB, para 11 4. ITSC order dated 30-05-2014 (copy enclosed at pages 115 to 132 of the PB) in case of M/s Bright Group and dated 30-05-2014 in case of Mr.…

Income Tax Officer, Ward-2(3), Vijayawada vs. Sreelakshmi Musunuru, Penamaluru

ITA 278/VIZ/2024[2013-14]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2013-14

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.278/Viz/2024 (िनधा"रण वष"/Assessment Year: 2013-14) Income Tax Officer, Vs. Sreelakshmi Musunuru, Ward-2(3), Penamaluru. Vijayawada. Pan: Aojpm4884K (Appellant) (Respondent)

For Appellant: Sri C. Subrahmanyam, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 143(3)Section 147Section 148Section 149(1)(b)Section 69

…ed fully and truly all the material facts regarding the purchase of agricultural land admeasuring 2.80 acres at Ganguru. We may herein observe that the Hon’ble Supreme Court in the case of New Delhi Television Ltd. vs. Deputy Commissioner of Income Tax (2020) 116 Taxmann.com 151 (SC), had, inter alia, held that though the assessee is obligated to disclose the “primary facts” but it is neither required to disclose the “secondary facts” nor required to give any assistance to the A.O by disclosure of the other facts and it is for the A.O to decide what inferences are to be drawn from the facts before him. It was obs…

Agri Gold Foods and Farm Products Limited, Vijayawada vs. Asst.Commissioner of Income Tax, Circle-2(1), Vijayawada

ITA 2000/HYD/2017[2007-08]Status: DisposedITAT Visakhapatnam09 Sept 2025AY 2007-08

Bench: Us:

Section 143(3)

…Foods and Farm Products Limited are mentioned in Notes to Accounts in Annual Report under para no. 8 of 4 and 5).” 22. We may herein observe that the Hon’ble Supreme Court in the case of New Delhi Television Ltd. vs. Deputy Commissioner of Income Tax (2020) 116 Taxmann.com 151 (SC), has, inter alia, held that though the assessee is obligated to disclose the “primary facts” but it is neither required to disclose the “secondary facts” nor required to give any assistance to the A.O by disclosure of the other facts and it is for the A.O to decide what inferences are to be drawn from the facts before him. It was obs…

Tata Motors Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(4), Mumbai

ITA 3511/MUM/2025[2014-15]Status: DisposedITAT Mumbai12 Aug 2025AY 2014-15

Bench: Shri Amit Shukla, Hon'Ble & Shri Arun Khodpia, Hon'Ble

Section 115BSection 115JSection 143(2)Section 143(3)Section 147Section 148Section 154Section 250Section 32A

…stify jurisdiction for re-assessment • Kelvinator India Limited [(320 ITR 561) (SC)] (enclosed at page nos.394 to 396 of the legal paperbook) • TechSpan India Pvt Ltd [Civil Appeal No. 2732/2007 dated 24 April 2018 (SC)) • New Delhi Television Ltd. [(2020) 424 ITR 607 dated 3 April 2020 (SC)] (enclosed at page nos.549 to 564 of the legal paperbook): "33. In our view the assessee disclosed all the primary facts necessary for assessment of its case to the assessing officer. What the revenue urges is that the assessee did not make a full and true disclosure of certain other facts. We are of the view that the ass…

M/S. Ashok Leyland Ltd., Chennai vs. DCIT, Ncc-8(1), Ltu-II, Chennai

In the result, appeal filed by the assessee is allowed

ITA 601/CHNY/2025[2010-11]Status: DisposedITAT Chennai29 Jul 2025AY 2010-11

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 143(2)Section 143(3)Section 147Section 148Section 32(1)(iia)

…failure on the assessee's part to truly and fully disclose all material facts in the course of original assessment. 12. This legal principle has been reiterated by the Hon'ble Supreme Court in the case of New Delhi Television Ltd. [NDTV] v. Dy. CIT [2020] 424 ITR 607 wherein it was held that, the Revenue can take the benefit of extended period of limitation beyond four years and upto six years only if the Revenue can show that the assessee had failed to disclose fully and truly all material facts necessary for its assessment. In this case (NDTV), we note that the assessee had issued step-up convertible bond…

Deputy Commissioner of Income Tax, Circle-1(3)(1), Mumbai vs. Tmf Holdings Limited, Mumbai

In the result, the appeal of the revenue bearing ITA No

ITA 2983/MUM/2025[2017-18]Status: DisposedITAT Mumbai18 Jul 2025AY 2017-18

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhrideputy Commissioner Of Vs Tmf Holdings Limited 14, 4Th Floor, Sir H C Dinshaw Income Tax, Circle 1(3)(1), Mumbai Building, 16, Horniman Circle, Fort, Room No.535, 5Th Floor, Aaykar Mumbai-400 001 Bhavan, M.K. Road, Mumbai- Pan: Aacct4644A 400 020 Appellant Respondent

For Appellant: Shri Rajan Vora a/w Shri Nikhil TiwariFor Respondent: Shri Ritesh Mishra, CIT DR
Section 115JSection 143(3)Section 144BSection 147Section 148Section 250Section 37(1)

…by the Department. However, in the present case that is not the case 9. Further, it is humbly submitted that the applicability of the decision in case of Phoolchand Bajrang Lai (1993) 203 ITR 456 (SC)] has been examined in case of New Delhi Television Ltd. (424 ITR 607 (SC)] [refer page nos. 520 to 535 of the legal paperbook] which while distinguishing the decision of the Hon'ble HC has held as under: 27. The High Court held that there was no "true and fair disclosure" in view of the law laid down by this Court in Phool Chand Bajrang Lal's case (supra), and the judgment of the Delhi High Court in Honda Siel Po…

Pr. Commissioner of Income Tax (Central)-2 vs. M/S K.R. Pulp and Papers Ltd

ITA/529/2023HC Delhi31 May 2025

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE TEJAS KARIA

For Appellant: Mr. Sanjay Kumar, Ms. Monica BenjaminFor Respondent: Mr. Gautam Jain and Mr. Manish Yadav
Section 143(3)Section 147Section 148Section 260ASection 68Section 80I

…ITA No. 529/2023 Page 1 of 25 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment delivered on: 31.05.2025 + ITA No. 529/2023 PR. COMMISSIONER OF INCOME TAX (CENTRAL)-2 .....Appellant versus M/S K.R. PULP AND PAPERS LTD. .....Respondent Advocates who appeared in this case For the Appellant : Mr. Sanjay Kumar, Ms. Monica Benjamin and Ms. Easha Kadian, Advocates. For the Respon…

Pr. Commissioner of Income Tax (Central)-2 vs. M/S K.R. Pulp and Papers Ltd

ITA-529/2023HC Delhi31 May 2025
For Appellant: Mr. Sanjay Kumar, Ms. Monica BenjaminFor Respondent: Mr. Gautam Jain and Mr. Manish Yadav
Section 143(3)Section 147Section 148Section 260ASection 68Section 80I

…ITA No. 529/2023 Page 1 of 25 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment delivered on: 31.05.2025 + ITA No. 529/2023 PR. COMMISSIONER OF INCOME TAX (CENTRAL)-2 .....Appellant versus M/S K.R. PULP AND PAPERS LTD. .....Respondent Advocates who appeared in this case For the Appellant : Mr. Sanjay Kumar, Ms. Monica Benjamin and Ms. Easha Kadian, Advocates. For the Respon…

Ashiana Buildprop Private Limited, Udaipur vs. DCIT, Central Circle-1, Udiapur, Udaipur

ITA 709/JODH/2024[2016-17]Status: DisposedITAT Jodhpur26 May 2025AY 2016-17

Bench: DR. MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

Section 132Section 145(3)Section 153ASection 234ASection 250

…re sought to be made which is in gross violation of the principles of natural justice and the procedure adopted by the Department is not fair or proper. Ashiana Buildprop Pvt. Ltd., Udaipur. In the case of New Delhi Television Ltd. Vs. DCIT reported in [2020] 424 ITR 607 (SC), it is held by the Hon'ble Apex Court that the Assessee must be put to notice of all the provisions on which the Department relies. Recently the same has also been laid down by this honble ITAT in the case of M/s Kajari Mineral Pvt. Ltd v/s DCIT Central Circle-1 Udaipur in ITA No. 217 and 218/Jodh/2024 dt.21.11.2024 and also in Smt. Prabhati…

Ashiana Buildprop Private Limited, Udaipur vs. DCIT, Central Circle-1 Udaipur, Udaipur

ITA 708/JODH/2024[2015-16]Status: DisposedITAT Jodhpur26 May 2025AY 2015-16
Section 132Section 145(3)Section 153ASection 234ASection 250

…ned and/or under which the additions are sought to be made which is in gross violation of the principles of natural justice and the procedure adopted by the Department is not fair or proper. In the case of New Delhi Television Ltd. Vs. DCIT reported in [2020] 424 ITR 607 (SC), it is held by the Hon'ble Apex Court that the Assessee must be put to notice of all the provisions on which the Department relies. Recently the same has also been laid down by this honble ITAT in the case of M/s Kajari Mineral Pvt. Ltd v/s DCIT Central Circle-1 Udaipur in ITA No. 217 and 218/Jodh/2024 dt.21.11.2024 and also in Smt. Prabhati…

Ashiana Buildprop Private Limited, Udaipur vs. DCIT- Central Circle-1 Udiapur, Udaipue

ITA 707/JODH/2024[2014-15]Status: DisposedITAT Jodhpur26 May 2025AY 2014-15
Section 132Section 145(3)Section 153ASection 234ASection 250

…ned and/or under which the additions are sought to be made which is in gross violation of the principles of natural justice and the procedure adopted by the Department is not fair or proper. In the case of New Delhi Television Ltd. Vs. DCIT reported in [2020] 424 ITR 607 (SC), it is held by the Hon'ble Apex Court that the Assessee must be put to notice of all the provisions on which the Department relies. Recently the same has also been laid down by this honble ITAT in the case of M/s Kajari Mineral Pvt. Ltd v/s DCIT Central Circle-1 Udaipur in ITA No. 217 and 218/Jodh/2024 dt.21.11.2024 and also in Smt. Prabhati…

Ashiana Buildprop Private Limited, Udaipur vs. DCIT, Central Circle-1, Udaipur

ITA 706/JODH/2024[2013-14]Status: DisposedITAT Jodhpur26 May 2025AY 2013-14
Section 132Section 145(3)Section 153ASection 234ASection 250

…ned and/or under which the additions are sought to be made which is in gross violation of the principles of natural justice and the procedure adopted by the Department is not fair or proper. In the case of New Delhi Television Ltd. Vs. DCIT reported in [2020] 424 ITR 607 (SC), it is held by the Hon'ble Apex Court that the Assessee must be put to notice of all the provisions on which the Department relies. Recently the same has also been laid down by this honble ITAT in the case of M/s Kajari Mineral Pvt. Ltd v/s DCIT Central Circle-1 Udaipur in ITA No. 217 and 218/Jodh/2024 dt.21.11.2024 and also in Smt. Prabhati…

Akshay Kumar Rungta, Bangalore vs. Income Tax Officer, Ward 2(1), International Taxation

In the result, appeal filed by the assessee is allowed as per above terms

ITA 66/BANG/2024[2015-16]Status: DisposedITAT Bangalore07 May 2025AY 2015-16

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyit(It)A No.66/Bang/2024 Assessment Year :2015-16

For Appellant: Shri. Ravishankar S. V, AdvocateFor Respondent: Ms. Neha Sahay, JCIT(DR)(ITAT), Bangalore
Section 10(38)Section 143(3)Section 144CSection 147Section 147rSection 148Section 151Section 153Section 153CSection 250

…aised in this writ petition would have to be evaluated. However, and before we proceed to do so, we also deem it apposite to notice the following illuminating passages which appear in New Delhi Television Ltd. v. Dy. CIT [2020] 116 taxmann.com 15/271 Taxman 1/424 ITR 607 (SC)/2020 SCC OnLine SC 446 and where the Supreme Court had an occasion to also notice Claggett Brachi Co. Ltd. (supra) and Phool Chand IT(IT)A No.66/Bang/2024 Page 21 of 31 Bajrang Lal (supra), two decisions which had been cited by Mr. Chandra for our consideration. 43. While dealing with information that may come to light subsequently and post…

Jai Prakash Shahani, Indore vs. Income Tax Officer - NFAC, Delhi

In the result, appeal of the assessee is allowed

ITA 524/IND/2023[2014-15]Status: DisposedITAT Indore29 Apr 2025AY 2014-15

Bench: Shri Manish Boradjai Prakashshahani, Income Tax Officer, Prop. M/S Jai Prakash Impex, Nfac, Delhi Vs. 73, New Palasia, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Apqps7948G Assessee By Ms. Ruchira Singhal, Ar Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 27.02.2025 Date Of Pronouncement 29.04.2025

Section 139(1)Section 143(3)Section 144BSection 147Section 148Section 37

…the information received from Investigation Wing and already been disclosed in the Income Tax Return as well as furnished in the scrutiny proceedings. At this juncture, I would like to refer to the judgment of Hon’ble Apex Court in the case of NDTV V/s DCIT (116 Taxmann.com 151) in which Hon’ble Court held that when the assessee has disclosed all primary facts before the A.O, it was not required to give any further assistance to the Assessing Officer by disclosure of other facts. It was for the Assessing Officer at this stage to decide what inference should be drawn from the facts of the case. The Hon’ble cour…