Saksham Commodities Ltd. v. Income Tax Officer

Kailash Kuamr, Haryana vs. DCIT, Delhi

The appeals are allowed for statistical purposes

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 2741 To 2746/Del/2025 Ita Nos. 2819 & 2820/Del/2025 (Assessment Years: 2013-14 To 2020-21)

…take cognizance u/s 153C of the Act or in the impugned orders there is any reference of any incriminating material found and relied. Reliance was heavily placed on the decision of Hon’ble Delhi High Court in the case of Saksham Commodities Ltd. Vs. ITO (2024) 464 ITR 1 (Delhi). It was also pointed out that in regard to AY: 2020-21 in fact the assessment should have been u/s 153C as a search year has to be determined on the basis of date of recording of satisfaction note. Therefore, assessment concluded u/s 143(3) for AY: 2020-21 are not sustainable in the light of decision of Hon’ble Delhi High Court in CIT Vs. R…

Kailash Kumar, Haryana vs. DCIT, New Delhi

The appeals are allowed for statistical purposes

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 2741 To 2746/Del/2025 Ita Nos. 2819 & 2820/Del/2025 (Assessment Years: 2013-14 To 2020-21)

…take cognizance u/s 153C of the Act or in the impugned orders there is any reference of any incriminating material found and relied. Reliance was heavily placed on the decision of Hon’ble Delhi High Court in the case of Saksham Commodities Ltd. Vs. ITO (2024) 464 ITR 1 (Delhi). It was also pointed out that in regard to AY: 2020-21 in fact the assessment should have been u/s 153C as a search year has to be determined on the basis of date of recording of satisfaction note. Therefore, assessment concluded u/s 143(3) for AY: 2020-21 are not sustainable in the light of decision of Hon’ble Delhi High Court in CIT Vs. R…

Kailash Kumar, Hariyana vs. DCIT, New Delhi

The appeals are allowed for statistical purposes

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 2741 To 2746/Del/2025 Ita Nos. 2819 & 2820/Del/2025 (Assessment Years: 2013-14 To 2020-21)

…take cognizance u/s 153C of the Act or in the impugned orders there is any reference of any incriminating material found and relied. Reliance was heavily placed on the decision of Hon’ble Delhi High Court in the case of Saksham Commodities Ltd. Vs. ITO (2024) 464 ITR 1 (Delhi). It was also pointed out that in regard to AY: 2020-21 in fact the assessment should have been u/s 153C as a search year has to be determined on the basis of date of recording of satisfaction note. Therefore, assessment concluded u/s 143(3) for AY: 2020-21 are not sustainable in the light of decision of Hon’ble Delhi High Court in CIT Vs. R…

Narender Singh, Haryana vs. Asst. Commissioner of Income Tax, Delhi

The appeals are allowed for statistical purposes

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 2741 To 2746/Del/2025 Ita Nos. 2819 & 2820/Del/2025 (Assessment Years: 2013-14 To 2020-21)

…take cognizance u/s 153C of the Act or in the impugned orders there is any reference of any incriminating material found and relied. Reliance was heavily placed on the decision of Hon’ble Delhi High Court in the case of Saksham Commodities Ltd. Vs. ITO (2024) 464 ITR 1 (Delhi). It was also pointed out that in regard to AY: 2020-21 in fact the assessment should have been u/s 153C as a search year has to be determined on the basis of date of recording of satisfaction note. Therefore, assessment concluded u/s 143(3) for AY: 2020-21 are not sustainable in the light of decision of Hon’ble Delhi High Court in CIT Vs. R…

Narender Singh, Haryana vs. Asst. Commissioner of Income Tax, Delhi

The appeals are allowed for statistical purposes

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 2741 To 2746/Del/2025 Ita Nos. 2819 & 2820/Del/2025 (Assessment Years: 2013-14 To 2020-21)

…take cognizance u/s 153C of the Act or in the impugned orders there is any reference of any incriminating material found and relied. Reliance was heavily placed on the decision of Hon’ble Delhi High Court in the case of Saksham Commodities Ltd. Vs. ITO (2024) 464 ITR 1 (Delhi). It was also pointed out that in regard to AY: 2020-21 in fact the assessment should have been u/s 153C as a search year has to be determined on the basis of date of recording of satisfaction note. Therefore, assessment concluded u/s 143(3) for AY: 2020-21 are not sustainable in the light of decision of Hon’ble Delhi High Court in CIT Vs. R…

Narender Singh, Haryana vs. Asst. Commissioner of Income Tax, Delhi

The appeals are allowed for statistical purposes

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 2741 To 2746/Del/2025 Ita Nos. 2819 & 2820/Del/2025 (Assessment Years: 2013-14 To 2020-21)

…take cognizance u/s 153C of the Act or in the impugned orders there is any reference of any incriminating material found and relied. Reliance was heavily placed on the decision of Hon’ble Delhi High Court in the case of Saksham Commodities Ltd. Vs. ITO (2024) 464 ITR 1 (Delhi). It was also pointed out that in regard to AY: 2020-21 in fact the assessment should have been u/s 153C as a search year has to be determined on the basis of date of recording of satisfaction note. Therefore, assessment concluded u/s 143(3) for AY: 2020-21 are not sustainable in the light of decision of Hon’ble Delhi High Court in CIT Vs. R…

Narender Singh, Haryana vs. Asst. Commissioner of Income Tax, Delhi

The appeals are allowed for statistical purposes

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 2741 To 2746/Del/2025 Ita Nos. 2819 & 2820/Del/2025 (Assessment Years: 2013-14 To 2020-21)

…take cognizance u/s 153C of the Act or in the impugned orders there is any reference of any incriminating material found and relied. Reliance was heavily placed on the decision of Hon’ble Delhi High Court in the case of Saksham Commodities Ltd. Vs. ITO (2024) 464 ITR 1 (Delhi). It was also pointed out that in regard to AY: 2020-21 in fact the assessment should have been u/s 153C as a search year has to be determined on the basis of date of recording of satisfaction note. Therefore, assessment concluded u/s 143(3) for AY: 2020-21 are not sustainable in the light of decision of Hon’ble Delhi High Court in CIT Vs. R…

Narender Singh, Haryana vs. Asst. Commissioner of Income Tax, Delhi

The appeals are allowed for statistical purposes

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 2741 To 2746/Del/2025 Ita Nos. 2819 & 2820/Del/2025 (Assessment Years: 2013-14 To 2020-21)

…take cognizance u/s 153C of the Act or in the impugned orders there is any reference of any incriminating material found and relied. Reliance was heavily placed on the decision of Hon’ble Delhi High Court in the case of Saksham Commodities Ltd. Vs. ITO (2024) 464 ITR 1 (Delhi). It was also pointed out that in regard to AY: 2020-21 in fact the assessment should have been u/s 153C as a search year has to be determined on the basis of date of recording of satisfaction note. Therefore, assessment concluded u/s 143(3) for AY: 2020-21 are not sustainable in the light of decision of Hon’ble Delhi High Court in CIT Vs. R…

Narender Singh, Haryana vs. Asst. Commissioner of Income Tax, Delhi

The appeals are allowed for statistical purposes

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 2741 To 2746/Del/2025 Ita Nos. 2819 & 2820/Del/2025 (Assessment Years: 2013-14 To 2020-21)

…take cognizance u/s 153C of the Act or in the impugned orders there is any reference of any incriminating material found and relied. Reliance was heavily placed on the decision of Hon’ble Delhi High Court in the case of Saksham Commodities Ltd. Vs. ITO (2024) 464 ITR 1 (Delhi). It was also pointed out that in regard to AY: 2020-21 in fact the assessment should have been u/s 153C as a search year has to be determined on the basis of date of recording of satisfaction note. Therefore, assessment concluded u/s 143(3) for AY: 2020-21 are not sustainable in the light of decision of Hon’ble Delhi High Court in CIT Vs. R…

Joginder Payla, Haryana vs. DCIT, Delhi

The appeals are allowed for statistical purposes

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 2741 To 2746/Del/2025 Ita Nos. 2819 & 2820/Del/2025 (Assessment Years: 2013-14 To 2020-21)

…take cognizance u/s 153C of the Act or in the impugned orders there is any reference of any incriminating material found and relied. Reliance was heavily placed on the decision of Hon’ble Delhi High Court in the case of Saksham Commodities Ltd. Vs. ITO (2024) 464 ITR 1 (Delhi). It was also pointed out that in regard to AY: 2020-21 in fact the assessment should have been u/s 153C as a search year has to be determined on the basis of date of recording of satisfaction note. Therefore, assessment concluded u/s 143(3) for AY: 2020-21 are not sustainable in the light of decision of Hon’ble Delhi High Court in CIT Vs. R…

Joginder Payla, Haryana vs. DCIT, Delhi

The appeals are allowed for statistical purposes

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 2741 To 2746/Del/2025 Ita Nos. 2819 & 2820/Del/2025 (Assessment Years: 2013-14 To 2020-21)

…take cognizance u/s 153C of the Act or in the impugned orders there is any reference of any incriminating material found and relied. Reliance was heavily placed on the decision of Hon’ble Delhi High Court in the case of Saksham Commodities Ltd. Vs. ITO (2024) 464 ITR 1 (Delhi). It was also pointed out that in regard to AY: 2020-21 in fact the assessment should have been u/s 153C as a search year has to be determined on the basis of date of recording of satisfaction note. Therefore, assessment concluded u/s 143(3) for AY: 2020-21 are not sustainable in the light of decision of Hon’ble Delhi High Court in CIT Vs. R…

Joginger Payla, Haryana vs. DCIT, Delhi

The appeals are allowed for statistical purposes

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 2741 To 2746/Del/2025 Ita Nos. 2819 & 2820/Del/2025 (Assessment Years: 2013-14 To 2020-21)

…take cognizance u/s 153C of the Act or in the impugned orders there is any reference of any incriminating material found and relied. Reliance was heavily placed on the decision of Hon’ble Delhi High Court in the case of Saksham Commodities Ltd. Vs. ITO (2024) 464 ITR 1 (Delhi). It was also pointed out that in regard to AY: 2020-21 in fact the assessment should have been u/s 153C as a search year has to be determined on the basis of date of recording of satisfaction note. Therefore, assessment concluded u/s 143(3) for AY: 2020-21 are not sustainable in the light of decision of Hon’ble Delhi High Court in CIT Vs. R…

Joginder Payla, Hayrana vs. DCIT, Delhi

The appeals are allowed for statistical purposes

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 2741 To 2746/Del/2025 Ita Nos. 2819 & 2820/Del/2025 (Assessment Years: 2013-14 To 2020-21)

…take cognizance u/s 153C of the Act or in the impugned orders there is any reference of any incriminating material found and relied. Reliance was heavily placed on the decision of Hon’ble Delhi High Court in the case of Saksham Commodities Ltd. Vs. ITO (2024) 464 ITR 1 (Delhi). It was also pointed out that in regard to AY: 2020-21 in fact the assessment should have been u/s 153C as a search year has to be determined on the basis of date of recording of satisfaction note. Therefore, assessment concluded u/s 143(3) for AY: 2020-21 are not sustainable in the light of decision of Hon’ble Delhi High Court in CIT Vs. R…

Joginder Payla, Haryana vs. DCIT, Delhi

The appeals are allowed for statistical purposes

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 2741 To 2746/Del/2025 Ita Nos. 2819 & 2820/Del/2025 (Assessment Years: 2013-14 To 2020-21)

…take cognizance u/s 153C of the Act or in the impugned orders there is any reference of any incriminating material found and relied. Reliance was heavily placed on the decision of Hon’ble Delhi High Court in the case of Saksham Commodities Ltd. Vs. ITO (2024) 464 ITR 1 (Delhi). It was also pointed out that in regard to AY: 2020-21 in fact the assessment should have been u/s 153C as a search year has to be determined on the basis of date of recording of satisfaction note. Therefore, assessment concluded u/s 143(3) for AY: 2020-21 are not sustainable in the light of decision of Hon’ble Delhi High Court in CIT Vs. R…

Joginder Payla, Haryana vs. DCIT, Delhi

The appeals are allowed for statistical purposes

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 2741 To 2746/Del/2025 Ita Nos. 2819 & 2820/Del/2025 (Assessment Years: 2013-14 To 2020-21)

…take cognizance u/s 153C of the Act or in the impugned orders there is any reference of any incriminating material found and relied. Reliance was heavily placed on the decision of Hon’ble Delhi High Court in the case of Saksham Commodities Ltd. Vs. ITO (2024) 464 ITR 1 (Delhi). It was also pointed out that in regard to AY: 2020-21 in fact the assessment should have been u/s 153C as a search year has to be determined on the basis of date of recording of satisfaction note. Therefore, assessment concluded u/s 143(3) for AY: 2020-21 are not sustainable in the light of decision of Hon’ble Delhi High Court in CIT Vs. R…

Joginder Payla, Haryana vs. DCIT, Delhi

The appeals are allowed for statistical purposes

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 2741 To 2746/Del/2025 Ita Nos. 2819 & 2820/Del/2025 (Assessment Years: 2013-14 To 2020-21)

…take cognizance u/s 153C of the Act or in the impugned orders there is any reference of any incriminating material found and relied. Reliance was heavily placed on the decision of Hon’ble Delhi High Court in the case of Saksham Commodities Ltd. Vs. ITO (2024) 464 ITR 1 (Delhi). It was also pointed out that in regard to AY: 2020-21 in fact the assessment should have been u/s 153C as a search year has to be determined on the basis of date of recording of satisfaction note. Therefore, assessment concluded u/s 143(3) for AY: 2020-21 are not sustainable in the light of decision of Hon’ble Delhi High Court in CIT Vs. R…

Joginder Payla, Haryana vs. DCIT, Delhi

The appeals are allowed for statistical purposes

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 2741 To 2746/Del/2025 Ita Nos. 2819 & 2820/Del/2025 (Assessment Years: 2013-14 To 2020-21)

…take cognizance u/s 153C of the Act or in the impugned orders there is any reference of any incriminating material found and relied. Reliance was heavily placed on the decision of Hon’ble Delhi High Court in the case of Saksham Commodities Ltd. Vs. ITO (2024) 464 ITR 1 (Delhi). It was also pointed out that in regard to AY: 2020-21 in fact the assessment should have been u/s 153C as a search year has to be determined on the basis of date of recording of satisfaction note. Therefore, assessment concluded u/s 143(3) for AY: 2020-21 are not sustainable in the light of decision of Hon’ble Delhi High Court in CIT Vs. R…

Dilip Chadha, Paharganj, New Delhi vs. Deputy Commissioner of Income Tax Central Circle-32, Jhandewalan Extn., New Delhi

Appeal is allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shuklaassessment Year: 2020-21 Sh. Dilip Chadha, Vs. Dcit, 9327, 2Nd Floor, Circle-32, Street No. 7, Multani New Delhi Dhanda, New Delhi Pan: Agypc9846Q (Appellant) (Respondent) Assessee By Sh. Sumit Lalchandani, Adv. Ms. Sejal Arora, Adv. Sh. Shivam Yadav, Adv. Department By Ms. Amish S. Gupt, Cit(Dr)

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘E’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI AMITABH SHUKLA, ACCOUNTANT MEMBER Assessment Year: 2020-21 Sh. Dilip Chadha, Vs. DCIT, 9327, 2nd Floor, Circle-32, Street No. 7, Multani New Delhi Dhanda, New Delhi PAN: AGYPC9846Q (Appellant) (Respondent) Assessee by Sh. Sumit Lalchandani, Adv. Ms. Sejal Arora, Adv. Sh. Shivam Yadav, Adv. Department by Ms. Amish S. Gupt, CIT(DR) Date of hearing 21.01.2026 Date of pronouncement 21.01.2026 ORDER PER SATBEER SINGH GODARA, JM This assessee’s appeal for assessment year 2020-21, arises against t…

Gautam Chopra, New Delhi vs. DCIT, Jhandewallan Extension

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

…ITA No. 2567/DEL/2025 Gautam Chopra Vs. DCIT IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER & SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA No. 2567/DEL/2025 [Assessment Year: 2021-22) GAUTAM CHOPRA Vs DCIT A-11, DDA Commercial Complex Ring Road, Defence Colony, Greater Kailash, South Delhi-110048 (APPELLANT) PAN No. ААНРС 6500 G Central Cirle-20, ARA Centre, Jhandewallan, New Delhi (RESPONDENT) Appellant by Respondent by Shri R.S. Singhvi, CA & Shri Satyajeet Goel, Adv Shri Rajesh Kumar Dhanesta, Sr. DR Date of Hearing 13.01.2026 Date of Pronouncement 21.…

G S Automobiles Private Limited, Delhi vs. DCIT, Central Circle-6, Delhi

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

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmang.S. Automobiles Private Limited, Vs. Dcit, Central Circle 6, B – 26, Okhla Industrial Area, Phase Ii, Delhi. Delhi – 110 020. (Pan : Aadcg1150B) (Appellant) (Respondent) Assessee By : Shri Neeraj Mangla, Ca Revenue By : Shri Jitender Singh, Cit Dr Date Of Hearing : 19.11.2025 Date Of Order : 30.12.2025 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals), Delhi – 24 [“Ld. Cit(A)”, For Short] Dated 19.06.2025 For The Assessment Year 2015-16 Raising Following Grounds Of Appeal :- “1. That The Orders Passed By Ld. Ao U/S 153C Of The Act As Well As Appellate Order Passed By Ld. Cit(A) Are Bad In Law & Are Passed In Contravention Of Prevailing Law As Well As Facts Of The Case, Therefore Liable To Be Annulled. 2. That Assumption Of Jurisdiction Of Ld. Ao In Consequence Of Order Passed By Ld. Pcit U/S 127(3) Of The Act Of The Act Is Illegal & Not Tenable Under The Law Because Of Said Order Being Mechanical & Being Passed

…r AYs 2016-17 to 2021-22. Therefore, AY 2015-16 in the present case is outside the provisions of section 153C of the Act. In this regard, he relied on the judgement of Hon’ble Jurisdictional High Court in the case of Saksham Commodities Ltd reported in (2024) 161 Taxmann.com 485 (Delhi). 4. On the other hand, ld. DR of the Revenue relied on the findings of the lower authorities. 5. Considered the rival submissions and material placed on record. We observed that the search in the case of Ashish Begwani Group of cases was carried on 22.10.2016 and based on above search, the case of the assessee was initiated u/s 15…