Dy. Commissioner of Income Tax, Hisar vs. M/S. Tayal Sons Pvt. Ltd., Hisar
The Appeals of the Assessee are allowed
ITA 3467/DEL/2025[2019-20]Status: DisposedITAT Delhi28 Nov 2025AY 2019-20
Bench: Yogesh Kumar U.S. & Shri Manish Agarwalita No. 3323/Del/2025 (A.Y. 2019-20) Tayal Sons Private Vs Dcit Limited Income Tax Office, Sesctor14, 653A, Kath Mandi Road, Hisar, Hisar, Haryana Pan: Aabct6693E Appellant Respondent Ita No. 3467/Del/2025 (A.Y. 2019-20) Dcit Vs Tayal Sons Private Limited Income Tax Office, 653A, Kath Mandi Road, Hisar, Sesctor14, Hisar, Haryana. Pan: Aabct6693E Appellant Respondent Assessee By Sh. Sh. Salil Kapoor, Adv, Ms. Ananya Kapoor, Adv, Ms. Ishitafarsiya, Adv, Ms. Soumya Singh, Adv& Ms. Sakshirustagi. Revenue By Ms. Amisha S. Gupt, Cit (Dr) Date Of Hearing 27/11/2025 Date Of Pronouncement 28/11/2025 Order Per Yogesh Kumar, U.S. Jm: The Captioned Two Appeals Are Filed By The Assessee & Two
Section 144BSection 148Section 148ASection 151
…dia and others in CWP No. 21509 of 2023 dated 29- 7-2024 and in the case of Vinay Sharma vs ITO in CWP No. 16228 of 2025 (O&M) dated 29-5-2025. 5. Further we find that the Hon‘ble Telengana High Court in the case of Sri Venkataramana Reddy vs DCIT reported in 468 ITR 181 (Tel) in Writ Petition Nos. 13353, 16141 and 16877 of 2024 dated 24-7-2024 ( which is a case of assessee in International Taxation) had categorically observed that in respect of international taxation charges, notices under section 148 were required to be issued in a faceless manner applying provisions of section 144B and as effected under provis…