PCIT v. Sahara India Life Insurance Co. Ltd.

432 ITR 84High Court2021#519 most cited

What is PCIT v. Sahara India Life Insurance Co. Ltd. authority for?

The Assessing Officer's failure to specify the exact limb (i.e., concealment of income or furnishing inaccurate particulars) in the show-cause notice issued under Section 274 for penalty under Section 271(1)(c) vitiates the entire penalty proceedings.

182

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2021 to 2026.

Also referred to as

PCIT v. Sahara India Life Insurance Co. Ltd. · Section 271(1)(c) · Section 274 · penalty show-cause notice · specifying limb · concealment of income · furnishing inaccurate particulars · vitiates penalty proceedings · Section 270A · 270AA immunity

Also reported as

108 Taxmann.com 597

Sections most often in play

Section 271(1)(c)Section 274Section 143(3)Section 270ASection 153ASection 250Section 147Section 270AA

Issues it is cited on

section 270(a)record dateimmunity under section 270aasection 270a(8)section 270aasection 270a(6)section 271(l)(c)section 271(l)section 270a(9)section 274penalty u/s 270afurnishing inaccurate particulars

Judgments citing PCIT v. Sahara India Life Insurance Co. Ltd.

ZF STEERING GEAR (INDIA) LIMITED,PUNE vs. DCIT CENTRAL CIRCLE 15, DELHI

In the result, the appeal of the assessee is allowed in very terms

ITA 4807/DEL/2025[2014-15]Status: DisposedITAT Delhi27 Mar 2026AY 2014-15

Bench: Sh. M. Balaganesh & Sh. Sudhir Kumarassessment Year: 2014-15 Vs M/S Zf Sterling Gear Dcit Central Circle-15, (India) Limited, New Delhi Gat 1242 1244 Vadhu Room No. 245, Dgit Budruk Takuka Shirur (Systems) Ara Koregaon Bhima, Pune, Centre, Ground Maharashtara Floor E-2 (Pan: Aaacz0549G) Jhandewalan Extension, New Delhi (Appellant) (Respondent)

Section 271(1)Section 271(1)(c)

…1 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘C’, NEW DELHI BEFORE SH. M. BALAGANESH, ACCOUNTANT MEMBER AND SH. SUDHIR KUMAR, JUDICIAL MEMBER Assessment Year: 2014-15 Vs M/s ZF STERLING GEAR DCIT Central Circle-15, (INDIA) LIMITED, NEW DELHI GAT 1242 1244 VADHU ROOM NO. 245, DGIT BUDRUK TAKUKA SHIRUR (SYSTEMS) ARA KOREGAON BHIMA, PUNE, CENTRE, GROUND MAHARASHTARA FLOOR E-2 (PAN: AAACZ0549G) JHANDEWALAN EXTENSION, NEW DELHI (APPELLANT) (RESPONDENT) Appellant by Shri Shivam Garg, Adv. & Shri Mihir Kaushik, Adv. Respondent by Shri Om Prakash, Sr. DR. Date of hearing: 12/03/2026 Date of Pronouncement: 27…

DAZZLER CONFECTIONERY COMPANY PRIVATE LIMITED,MUMBAI vs. INCOME TAX OFFICER WARD 3(1)(1, MUMBAI

In the result, the Assessee’s Appeal is allowed

ITA 8411/MUM/2025[2013-14]Status: DisposedITAT Mumbai13 Mar 2026AY 2013-14

Bench: Shri Narender Kumar Choudhryshri Prabhash Shankar

For Appellant: Mr. Rahul Sarda, Ld. ARFor Respondent: Shri Annavaram Kosuri, SR AR
Section 250Section 271(1)(c)Section 274Section 35D

…e irrelevant clause would lead to an inference of non-application of mind by the Assessing Officer and levy of penalty would suffers from non-application of mind. 16. The Hon'ble High Court of Delhi in the case of M/s. Sahara India Life Insurance Company Ltd. 432 ITR 84 (Del.) while following the above judgement in CIT v. Manjunatha Cotton & Ginning Factory 359 ITR 565 (Kar), held as under: "21. The Respondent had challenged the upholding of the penalty imposed under Section 271(1)(c) of the Act, which was accepted by the ITAT. It followed the decision of the Karnataka High Court in 10 Dazzler Confectionery Compa…

SANJAY JAIN,SAHARANPUR vs. INCOME TAX OFFICER, WARD-3(3)(1),, SAHARANPUR

In the result, the appeal of the assessee is allowed

ITA 6650/DEL/2025[2013-14]Status: DisposedITAT Delhi13 Mar 2026AY 2013-14

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2013-14 Vs Sanjay Jain, Ito, Ward-3(3)(1), 39, Mission Compound, Sahranpur-247001 Saharanpur-247001 Uttar Pradesh [Pan: Ackpj3369F) (Appellant) (Respondent)

Section 145(3)Section 271(1)Section 271(1)(c)

…1 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI BEFORE SH. S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SH. SUDHIR KUMAR, JUDICIAL MEMBER Assessment Year: 2013-14 Vs SANJAY JAIN, ITO, WARD-3(3)(1), 39, MISSION COMPOUND, SAHRANPUR-247001 SAHARANPUR-247001 UTTAR PRADESH [PAN: ACKPJ3369F) (APPELLANT) (RESPONDENT) Appellants by Shri Ankit Gupta, Adv. Respondent by Shri Rajesh Kumar Dhanesta, Sr. DR Date of hearing: 25/02/2026 Date of Pronouncement: 13/03/2026 ORDER PER SUDHIR KUMAR, JM: This appeal by the assessee is directed against the order of Ld. National Faceless Appeal Centre (NFAC), Delhi…

AMBER CORPORATION,KALYAN vs. ITO WARD 3(1), KALYAN, KALYAN, THANE

In the result the Assessee’s Appeal is allowed

ITA 8373/MUM/2025[2010-2011]Status: DisposedITAT Mumbai26 Feb 2026AY 2010-2011

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2010-11

For Appellant: Shri. Hitesh ShahFor Respondent: Shri. Surendra Mohan (SR. DR.)
Section 250Section 271Section 271(1)(c)Section 274

…e irrelevant clause would lead to an inference of non-application of mind by the Assessing Officer and levy of penalty would suffers from non-application of mind. 16. The Hon'ble High Court of Delhi in the case of M/s. Sahara India Life Insurance Company Ltd. 432 ITR 84 (Del.) while following the above judgement in CIT v. Manjunatha Cotton & Ginning Factory 359 ITR 565 (Kar), held as under: "21. The Respondent had challenged the upholding of the penalty imposed under Section 271(1)(c) of the Act, which was accepted by the ITAT. It followed the decision of the Karnataka High Court in CIT v. Manjunatha Cotton & Gin…

M/S.ALLIED DIGITAL SERVICES LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(3), MUMBAI, MUMBAI

In the result the Assessee‟s Appeal is allowed

ITA 8147/MUM/2025[2010-11]Status: DisposedITAT Mumbai26 Feb 2026AY 2010-11

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2010-11 M/S. Allied Digital Services Deputy Commissioner Of Limited, Income Tax, Central 808, 8Th Floor, Mafatlal Centre, Circile 1(3), 905,9Th Floor, Nariman Point, Vs. Mumbai – 400021. Old Cgo Building, Pan – Aaaca5509K Pratishtha Bhavan, M.K. Road, Mumbai – 400020. (Appellant) (Respondent) Present For: Assessee By : Ms. Vinita Shah, Ld. A.R. Revenue By : Shri Surendra Mohan, Sr. D.R. Date Of Hearing : 12.02.2026 Date Of Pronouncement : 26.02.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 11.07.2025, Impugned Herein, Passed By Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short „The Act‟) For The A.Y. 20101-11. 2. In The Instant Case, The Ao Vide Assessment Order Dated 28.03.2013 Under Section 143 (3) R.W.S. 153(A) Of The Act Has Made The Additions Of Rs.5,35,91,882/- & Rs.1,25,66,049/- On Account Of Disallowances Under Section 69C Of The Act & Section 2 M/S. Allied Digital Services Limited

For Appellant: Ms. Vinita Shah, Ld. A.RFor Respondent: Shri Surendra Mohan, Sr. D.R
Section 143Section 2Section 250Section 271(1)(c)Section 274Section 69C

…irrelevant clause would lead to an inference of non- application of mind by the Assessing Officer and levy of penalty would suffers from non-application of mind. 16. The Hon'ble High Court of Delhi in the case of M/s. Sahara India Life Insurance Company Ltd. 432 ITR 84 (Del.) while following the above judgement in CIT v. Manjunatha Cotton & Ginning Factory 359 ITR 565 (Kar), held as under: "21. The Respondent had challenged the upholding of the penalty imposed under Section 271(1)(c) of the Act, which was accepted by the ITAT. It followed the decision of the Karnataka High Court in CIT v. Manjunatha Cotton & Gin…

DCIT, DELHI vs. ASTER TRADELINKS PRIVATE LIMITED, DELHI

In the result, the appeal of the revenue is dismissed and the cross objection of the assessee is allowed

ITA 6254/DEL/2025[2016-17]Status: DisposedITAT Delhi13 Feb 2026AY 2016-17

Bench: Shri Mahavir Singh, Hon’Ble & Smt. Renu Jauhri, Hon’Ble

Section 147Section 153(2)Section 250Section 271(1)(c)

…nt of income’ or ‘for furnishing of inaccurate particulars of income’. Ld. AR has placed reliance on several decisions on this issue, including that of the jurisdictional High Court in the case of PCIT v. M/s Sahara India Life Insurance Company Limited, (2021)432 ITR 84 (Del) wherein it was held that whether notice issued by the Ld. AO did not specify under which limb of section 271(1)(c) penalty proceedings had been initiated i.e., whether for ‘concealment of income’ or ‘for furnishing of inaccurate particulars of income’, the penalty notice issued would be bad in law. 7.2 On the other hand, Ld. DR has relied on…

UNITECH RESIDENTIAL RESORTS LTD.,NEW DELHI vs. DCIT, CIRCLE-27(1), NEW DELHI

ITA 4409/DEL/2019[2010-11]Status: DisposedITAT Delhi12 Feb 2026AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 250

…the other hand has vehemently argued that such a defect is 8 | P a g e ITA Nos.4408 & 4409/Del/2019 only a procedural one which is not fatal to the impugned penalty. 8. Faced with this situation, we quote PCIT Vs. Sahara India Life Insurance Co. Ltd. (2021) 432 ITR 84 (Del.) and PCIT Vs. Gopal Kumar Goyal (2023) 153 taxmann.com 534 (Del.) to conclude that once the learned Assessing Officer had nowhere specified the corresponding limb in his section 271(1)(c) penalty show-cause notice forming part of the case records, his failure to this clinching effect indeed vitiates the penalty proceedings itself. Quashed ac…

UNITECH REALITY PVT. LTD.,,NEW DELHI vs. DCIT CIRCLE-27(1), NEW DELHI

ITA 4408/DEL/2019[2013-14]Status: DisposedITAT Delhi12 Feb 2026AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 250

…the other hand has vehemently argued that such a defect is 8 | P a g e ITA Nos.4408 & 4409/Del/2019 only a procedural one which is not fatal to the impugned penalty. 8. Faced with this situation, we quote PCIT Vs. Sahara India Life Insurance Co. Ltd. (2021) 432 ITR 84 (Del.) and PCIT Vs. Gopal Kumar Goyal (2023) 153 taxmann.com 534 (Del.) to conclude that once the learned Assessing Officer had nowhere specified the corresponding limb in his section 271(1)(c) penalty show-cause notice forming part of the case records, his failure to this clinching effect indeed vitiates the penalty proceedings itself. Quashed ac…

CHIRAGKUMAR RAJENDRABHAI SHAH,MUMBAI vs. ITO WARD 30(1)(2), MUMBAI

In the result, ITA No. 7130/M/2025 is allowed

ITA 7132/MUM/2025[2011-12]Status: DisposedITAT Mumbai05 Feb 2026AY 2011-12

Bench: Shri Narender Kumar Choudhry & Shri Jagadish

For Appellant: Shri A K Sharma, AdvFor Respondent: Shri Virabhadra Mahajan, (SR. D.R.)
Section 143(3)Section 147Section 250Section 271(1)(c)Section 274Section 69C

…e irrelevant clause would lead to an inference of non-application of mind by the Assessing Officer and levy of penalty would suffers from non-application of mind. 16. The Hon'ble High Court of Delhi in the case of M/s. Sahara India Life Insurance Company Ltd. 432 ITR 84 (Del.) while following the above judgement in CIT v. Manjunatha Cotton & Ginning Factory 359 ITR 565 (Kar), held as under: "21. The Respondent had challenged the upholding of the penalty imposed under Section 271(1)(c) of the Act, which was accepted by the ITAT. It followed the decision of the Karnataka High Court in CIT v. Manjunatha Cotton & Gi…

CHIRAGKUMAR RAJENDRABHAI SHAH,MUMBAI vs. ITO WARD 30(1)(2), MUMBAI

In the result, ITA No. 7130/M/2025 is allowed

ITA 7131/MUM/2025[2010-11]Status: DisposedITAT Mumbai05 Feb 2026AY 2010-11

Bench: Shri Narender Kumar Choudhry & Shri Jagadish

For Appellant: Shri A K Sharma, AdvFor Respondent: Shri Virabhadra Mahajan, (SR. D.R.)
Section 143(3)Section 147Section 250Section 271(1)(c)Section 274Section 69C

…e irrelevant clause would lead to an inference of non-application of mind by the Assessing Officer and levy of penalty would suffers from non-application of mind. 16. The Hon'ble High Court of Delhi in the case of M/s. Sahara India Life Insurance Company Ltd. 432 ITR 84 (Del.) while following the above judgement in CIT v. Manjunatha Cotton & Ginning Factory 359 ITR 565 (Kar), held as under: "21. The Respondent had challenged the upholding of the penalty imposed under Section 271(1)(c) of the Act, which was accepted by the ITAT. It followed the decision of the Karnataka High Court in CIT v. Manjunatha Cotton & Gi…

CHIRAGKUMAR RAJENDRABHAI SHAH,MUMBAI vs. INCOME TAX OFFICER, MUMBAI

In the result, ITA No. 7130/M/2025 is allowed

ITA 7130/MUM/2025[2009-10]Status: DisposedITAT Mumbai05 Feb 2026AY 2009-10

Bench: Shri Narender Kumar Choudhry & Shri Jagadish

For Appellant: Shri A K Sharma, AdvFor Respondent: Shri Virabhadra Mahajan, (SR. D.R.)
Section 143(3)Section 147Section 250Section 271(1)(c)Section 274Section 69C

…e irrelevant clause would lead to an inference of non-application of mind by the Assessing Officer and levy of penalty would suffers from non-application of mind. 16. The Hon'ble High Court of Delhi in the case of M/s. Sahara India Life Insurance Company Ltd. 432 ITR 84 (Del.) while following the above judgement in CIT v. Manjunatha Cotton & Ginning Factory 359 ITR 565 (Kar), held as under: "21. The Respondent had challenged the upholding of the penalty imposed under Section 271(1)(c) of the Act, which was accepted by the ITAT. It followed the decision of the Karnataka High Court in CIT v. Manjunatha Cotton & Gi…

ITO WARD -18(1), NEW DELHI vs. NEMINATH INDUSTRIES PVT. LTD., NEW DELHI

Appeal is dismissed

ITA 4494/DEL/2019[2013-14]Status: DisposedITAT Delhi03 Feb 2026AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra**

Section 271(1)(c)

…ntire proceedings itself. The Revenue on the other hand has vehemently argued that such a defect is only a procedural one which is not fatal to the impugned penalty. - 4. Faced with this situation, we quote PCIT Vs. Sahara India Life Insurance Co. Ltd. (2021) 432 ITR 84 (Del.) and PCIT Vs. Gopal Kumar Goyal (2023) 153 taxmann.com 534 (Del.) to conclude that once the learned Assessing Officer had nowhere specified the corresponding limb in his section 271(1)(c) penalty show-cause notice forming part of the case records, his failure to this clinching effect indeed vitiates the penalty proceedings itself. Quashed a…

JAYCO PROMOTERS & DEVELOPERS PVT. LTD.,DELHI vs. INCOME TAX OFFICER, WARD 13(3), DELHI

In the result, the appeal of the assessee is allowed

ITA 101/DEL/2025[2007-08]Status: DisposedITAT Delhi13 Jan 2026AY 2007-08

Bench: Shri M. Balaganesh & Shri Vimal Kumarjayco Promoters & Developers Vs. Income Tax Officer, Pvt. Ltd, Ward-13(3), C-5, Madhu Vihar, Patparganj, Delhi Delhi (Appellant) (Respondent) Pan: Aabcj7631E

For Appellant: Shri Vibhu Gupta, AdvFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 271(1)Section 271(1)(c)Section 274

…INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “A”: NEW DELHI BEFORE SHRI M. BALAGANESH, ACCOUNTANT MEMBER AND SHRI VIMAL KUMAR, JUDICIAL MEMBER Jayco Promoters & Developers Vs. Income Tax Officer, Pvt. Ltd, Ward-13(3), C-5, Madhu Vihar, Patparganj, Delhi Delhi (Appellant) (Respondent) PAN: AABCJ7631E Assessee by : Shri Vibhu Gupta, Adv Revenue by: Shri Ajay Kumar Arora, Sr. DR Date of Hearing 09/12/2025 Date of pronouncement 13/01/2026 O R D E R PER M. BALAGANESH, A. M.: 1. The appeal in ITA No. 101/Del/2025 for AY 2007-08, arises out of the order of the National Faceless Appeal Centre (NFAC), Delhi [hereinafter…

EVEREST KANTO CYLINDER LTD,MUMBAI vs. DCIT CIRCLE 3(4), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 5790/MUM/2025[2010-11]Status: DisposedITAT Mumbai10 Dec 2025AY 2010-11

Bench: Shri Rahul Chaudhary & Shri Prabhash Shankareverest Kanto Cylinder V/S. Deputy Commissioner Of Ltd. बनाम Income Tax, Circle – 3(4), 204,Raheja Centre, Free World Trade Centre 1, Cuffe Press Journal Marg, Parade, Mumbai – 400005, Nariman Point, Mumbai – Maharashtra 400 021, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaace0836F Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Shekhar Gupta,ARFor Respondent: Shri Hemanshu Joshi, (Sr.DR)
Section 115JSection 143(3)Section 271(1)Section 271(1)(c)Section 274

…IN THE INCOME-TAX APPELLATE TRIBUNAL “E” BENCH, MUMBAI BEFORE SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER Everest Kanto Cylinder v/s. Deputy Commissioner of Ltd. बनाम Income Tax, Circle – 3(4), 204,Raheja Centre, Free World Trade Centre 1, Cuffe Press Journal Marg, Parade, Mumbai – 400005, Nariman Point, Mumbai – Maharashtra 400 021, Maharashtra स्थायी लेखा सं./जीआइआर सं./PAN/GIR No: AAACE0836F Appellant/अपीलार्थी .. Respondent/प्रतिवादी Appellant by : Shri Shekhar Gupta,AR Respondent by : Shri Hemanshu Joshi, (Sr.DR) Date of Hearing 12.11.2025 Date of Pronouncement 10.12.2…

BRIJ GOPAL CONSTRUCTION COMPANY (P) LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-3, DELHI

In the result, assessee’s appeal is allowed

ITA 4800/DEL/2025[2017-18]Status: DisposedITAT Delhi28 Nov 2025AY 2017-18

Bench: Shri M Balaganesh & Ms. Madhumita Royassessment Year: 2017-18

Section 1Section 143Section 143(3)Section 270ASection 270A(2)(a)

…erald Meadows reported in 73 taxmann.com 241 (Kar)] ii) 282 Taxman 463 (SC) PCIT v. Goa Coastal Resorts and Recreation (P.) Ltd.SLP Dismissed [arising out of PCIT v. Goa Coastal Resorts and Recreation (P.) Ltd. reported in 272 Taxman 157 (Bom)] HIGH COURTS i) 432 ITR 84 (Del) Pr. CIT v. Sahara India Life Insurance Company Ltd. ii) 359 ITR 565 (Kar) CIT v. Manjunatha Cotton & Ginning Factory iii) 434 ITR 1 (Bom) (FB) Mohd. Farhan A. sheikh v. DCIT iv) ITA No. 1154/2014 (Bom) dated 5.1.2017 CIT v. Shri Samson Perincherry v) 264 CTR 502 (Karn) CIT v. MWP Ltd. SLP dismissed by Apex Court in CC No. 7485/2014 vi) 370 I…

PARVEEN TAYAL,FARIDABAD HARYANA vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2, FARIDABAD HARYANA

Appeal is allowed

ITA 2073/DEL/2025[2016-17]Status: DisposedITAT Delhi20 Nov 2025AY 2016-17

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

For Appellant: Sh. Deepesh Garg, AdvFor Respondent: Sh. Manish Gupta, Sr. DR
Section 271(1)(c)

…to whether it was an instance of concealment or furnishing of inaccurate particulars of taxable income; as the case may be. 5. The Revenue could hardly dispute that various landmark judicial precedents in PCIT Vs. Sahara India Life Insurance Co. Ltd. (2021) 432 ITR 84 (Del.) and PCIT Vs. Gopal Kumar Goyal (2023) 153 taxmann.com 534 (Del.) has settled the issue in the assessee’s favour and against the department that such a failure on the learned Assessing authorities part indeed vitiated the penalty proceedings itself. We accordingly find merit in the assessee’s vehement contentions to delete the impugned secti…

MR. RAVINDER KUMAR JAIN,DELHI vs. DCIT,CENTRAL CIRCLE-07, DELHI

In the result, appeal of the Assessee is allowed

ITA 1579/DEL/2025[2006-07]Status: DisposedITAT Delhi12 Nov 2025AY 2006-07

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A No.1579/Del/2025 िनधा"रणवष"/Assessment Year:2006-07 बनाम Mr. Ravinder Kumar Jain, Dcit, H 82, South Extension, Part-1, Vs. Central Circle 07, New Delhi. New Delhi. Pan No.Aalpj7172P अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 144Section 271(1)(c)

…amount of Rs.58,85,666/- which itself shows that the amount of Rs.58,85,666/- was not the income concealed in the eyes of the law. It is submitted that the AO has not specifically pointed out the specific limb in which the penalty is likely to be imposed. - 432 ITR 84 (Del), PCIT vs. Sahara India Life Insurance Co. Ltd. - 434 ITR 1 (Bom.) (FB), Mohd. Farhan A. Shaikh vs. DCIT - 462 ITR 307 (Del), PCIT vs. Unitech Reliable Projects Pvt. Ltd. (SLP dismissed in 300 Taxman 585 (SC)). 7. Ld. Counsel submitted that as far as the other two items amounting to Rs.1,25,000/- and Rs.1,00,000/- are concerned, the Assessi…

ADDL. CIT, NEW DELHI vs. M/S. PHI SEEDS PVT. LTD., HYDERABAD

The appeals of the Revenue are dismissed and both the Rule 27 application of the assessee are allowed for A

ITA 3084/DEL/2017[2009-10]Status: DisposedITAT Delhi31 Oct 2025AY 2009-10

Bench: Shri Mahavir Singh & Shri Brajesh Kumar Singh

Section 1Section 10(1)Section 143Section 143(3)Section 271(1)(c)Section 274

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, F: NEW DELHI BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT AND SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER ITA Nos.- 3083 & 3084/Del/2017 [Assessment Years: 2008-09 & 2009-10] Additional commissioner of M/s PHI Seeds Pvt. Ltd., Income Tax, (Now known as Corteva Special Range-7, Vs Agriscience Seeds Pvt. Ltd.) Room No. -211, CR Building, 3rd Floor, 6-3-1099/1100, IP Estates, Babukhans Millenium New Delhi-110002, Centre, Raj Bhawan Road, Somajiguda, Hyderabad-500082. PAN- AACCP3920F Revenue Assessee Revenue by Ms. Monika Singh, CIT(DR) Assessee by Shri Sandeep Bansal,…

ADDL. CIT, NEW DELHI vs. M/S. PHI SEEDS PVT. LTD., HYDERABAD

The appeals of the Revenue are dismissed and both the Rule 27 application of the assessee are allowed for A

ITA 3083/DEL/2017[2008-09]Status: DisposedITAT Delhi31 Oct 2025AY 2008-09

Bench: Shri Mahavir Singh & Shri Brajesh Kumar Singh

Section 1Section 10(1)Section 143Section 143(3)Section 271(1)(c)Section 274

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, F: NEW DELHI BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT AND SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER ITA Nos.- 3083 & 3084/Del/2017 [Assessment Years: 2008-09 & 2009-10] Additional commissioner of M/s PHI Seeds Pvt. Ltd., Income Tax, (Now known as Corteva Special Range-7, Vs Agriscience Seeds Pvt. Ltd.) Room No. -211, CR Building, 3rd Floor, 6-3-1099/1100, IP Estates, Babukhans Millenium New Delhi-110002, Centre, Raj Bhawan Road, Somajiguda, Hyderabad-500082. PAN- AACCP3920F Revenue Assessee Revenue by Ms. Monika Singh, CIT(DR) Assessee by Shri Sandeep Bansal,…

PRRINCIPAL COMMISSIONER OF INCOME TAX-7 vs. M/S SHINE STAR BUILDCON PVT.LTD

The appeals are disposed of in favour of the

ITA/541/2025HC Delhi28 Oct 2025

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

Section 260ASection 271(1)(C)Section 271(1)(c)

…r of Income Tax v. Gragerious Projects Pvt. Ltd; Neutral Citation:2024:DHC:9019-DB, wherein this Court in paragraph 21 held as under: “21. The High Court in the case of Principal Commissioner of Income Tax vs. Sahara India Life Insurance Co. Ltd., (2021) 432 ITR 84 Delhi, followed the decision of the Karnataka High Court in in CIT vs Manjunatha Cotton & Ginning Factory (2013) 359 ITR 565(Kar.) and held as under:- “The Respondent had challenged the upholding of the Signed By:PRADEEP SHARMA Signing Date:03.11.2025 15:42:28 Signature Not Verified…

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