TR 83 (Del.), Bimal Kumar Anant Kumar Vs. CIT (2007) 159 TAXMAN 402 (All.), Salem Steel Co. v. CIT

377 ITR 158High Court2015#9970 most cited
11

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2020 to 2025.

Sections most often in play

Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 148B

Issues it is cited on

penalty under section 271econstruction pepenalty under section 271dcorpus fundsection 269ton money receiptsection 53joint development agreementsection 269sjdatrcsection 271e

Judgments citing TR 83 (Del.), Bimal Kumar Anant Kumar Vs. CIT (2007) 159 TAXMAN 402 (All.), Salem Steel Co. v. CIT

DCIT, CENTRAL CIRCLE - 2, NOIDA, NOIDA vs. M/S MONTAGE ENTERPRISES PVT. LTD., NEW DELHI

ITA 5906/DEL/2025[2022-23]Status: DisposedITAT Delhi29 Dec 2025AY 2022-23

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2022-23 Montage Enterprises Pvt. Vs. Dcit/Acit, Ltd., Central Circle-Ii, 205, 2Nd Floor, V-4, Mayur Noida Plaza -2, Local Shopping Centre, Mayur Vihar, Phase-1, East Delhi, Delhi Pan :Aaccm8173H (Appellant) (Respondent) With Assessment Year: 2022-23 Dcit/Acit, Vs. Montage Enterprises Pvt. Ltd., Central Circle-Ii, 205, 2Nd Floor, V-4, Mayur Noida Plaza -2, Local Shopping Centre, Mayur Vihar, Phase-1, East Delhi, Delhi Pan: Aaccm8173H (Appellant) (Respondent) Assessee By Sh. Rohit Kapoor, Adv. Sh. Veersen Aggarwal, Itp Department By Sh. Siddharth Bhim Singh Meena, Cit(Dr) Date Of Hearing 08.12.2025 Date Of Pronouncement 29.12.2025

Section 132Section 133ASection 143(3)Section 148Section 148B

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘G’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER Assessment Year: 2022-23 Montage Enterprises Pvt. Vs. DCIT/ACIT, Ltd., Central Circle-II, 205, 2nd Floor, V-4, Mayur Noida Plaza -2, Local shopping Centre, Mayur Vihar, Phase-1, East Delhi, Delhi PAN :AACCM8173H (Appellant) (Respondent) With Assessment Year: 2022-23 DCIT/ACIT, Vs. Montage Enterprises Pvt. Ltd., Central Circle-II, 205, 2nd Floor, V-4, Mayur Noida Plaza -2, Local shopping Centre, Mayur Vihar, Phase-1, East Delhi, Delhi PAN: AACCM8173H (Appella…

MONTAGE ENTERPRISES PRIVATE LIMITED,MAYUR VIHAR PHASE-I, EAST DELHI vs. DCIT/ACIT CEN CIR-II, NOIDA, CENTRAL CIRCLE-II, NOIDA

ITA 5458/DEL/2025[2022-23]Status: DisposedITAT Delhi29 Dec 2025AY 2022-23

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2022-23 Montage Enterprises Pvt. Vs. Dcit/Acit, Ltd., Central Circle-Ii, 205, 2Nd Floor, V-4, Mayur Noida Plaza -2, Local Shopping Centre, Mayur Vihar, Phase-1, East Delhi, Delhi Pan :Aaccm8173H (Appellant) (Respondent) With Assessment Year: 2022-23 Dcit/Acit, Vs. Montage Enterprises Pvt. Ltd., Central Circle-Ii, 205, 2Nd Floor, V-4, Mayur Noida Plaza -2, Local Shopping Centre, Mayur Vihar, Phase-1, East Delhi, Delhi Pan: Aaccm8173H (Appellant) (Respondent) Assessee By Sh. Rohit Kapoor, Adv. Sh. Veersen Aggarwal, Itp Department By Sh. Siddharth Bhim Singh Meena, Cit(Dr) Date Of Hearing 08.12.2025 Date Of Pronouncement 29.12.2025

Section 132Section 133ASection 143(3)Section 148Section 148B

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘G’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER Assessment Year: 2022-23 Montage Enterprises Pvt. Vs. DCIT/ACIT, Ltd., Central Circle-II, 205, 2nd Floor, V-4, Mayur Noida Plaza -2, Local shopping Centre, Mayur Vihar, Phase-1, East Delhi, Delhi PAN :AACCM8173H (Appellant) (Respondent) With Assessment Year: 2022-23 DCIT/ACIT, Vs. Montage Enterprises Pvt. Ltd., Central Circle-II, 205, 2nd Floor, V-4, Mayur Noida Plaza -2, Local shopping Centre, Mayur Vihar, Phase-1, East Delhi, Delhi PAN: AACCM8173H (Appella…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. PIONEER BUILDERS, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

ITA 64/HYD/2024[2019-20]Status: DisposedITAT Hyderabad29 Aug 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

…the Income Tax Act. What is chargeable to tax under the Income Tax Act is not the gross receipt but the income under the Income Tax Act. The tax is on income but not on gross receipts." · The Hon'ble Punjab & Haryana High Court in the case of Telelinksys.CIT [377 ITR 158, P&H HC] held that discretion to determine net profit vested in authorities must be exercised on basis of relevant factors which are past tax history of assessee, an appraisal of value of contract, price of raw material, labor etc. · We would like to humbly submit that in the case of a sub-contractor undertaking construction works, the Hon'ble Co…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. PIONEER BUILDERS, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

ITA 57/HYD/2024[2020-21]Status: DisposedITAT Hyderabad29 Aug 2024AY 2020-21

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

…the Income Tax Act. What is chargeable to tax under the Income Tax Act is not the gross receipt but the income under the Income Tax Act. The tax is on income but not on gross receipts." · The Hon'ble Punjab & Haryana High Court in the case of Telelinksys.CIT [377 ITR 158, P&H HC] held that discretion to determine net profit vested in authorities must be exercised on basis of relevant factors which are past tax history of assessee, an appraisal of value of contract, price of raw material, labor etc. · We would like to humbly submit that in the case of a sub-contractor undertaking construction works, the Hon'ble Co…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. PIONEER BUILDERS, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

ITA 56/HYD/2024[2019-20]Status: DisposedITAT Hyderabad29 Aug 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

…the Income Tax Act. What is chargeable to tax under the Income Tax Act is not the gross receipt but the income under the Income Tax Act. The tax is on income but not on gross receipts." · The Hon'ble Punjab & Haryana High Court in the case of Telelinksys.CIT [377 ITR 158, P&H HC] held that discretion to determine net profit vested in authorities must be exercised on basis of relevant factors which are past tax history of assessee, an appraisal of value of contract, price of raw material, labor etc. · We would like to humbly submit that in the case of a sub-contractor undertaking construction works, the Hon'ble Co…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. DSR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

ITA 54/HYD/2024[2020-21]Status: DisposedITAT Hyderabad29 Aug 2024AY 2020-21

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

…the Income Tax Act. What is chargeable to tax under the Income Tax Act is not the gross receipt but the income under the Income Tax Act. The tax is on income but not on gross receipts." · The Hon'ble Punjab & Haryana High Court in the case of Telelinksys.CIT [377 ITR 158, P&H HC] held that discretion to determine net profit vested in authorities must be exercised on basis of relevant factors which are past tax history of assessee, an appraisal of value of contract, price of raw material, labor etc. · We would like to humbly submit that in the case of a sub-contractor undertaking construction works, the Hon'ble Co…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. DSR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

ITA 53/HYD/2024[2019-20]Status: DisposedITAT Hyderabad29 Aug 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

…the Income Tax Act. What is chargeable to tax under the Income Tax Act is not the gross receipt but the income under the Income Tax Act. The tax is on income but not on gross receipts." · The Hon'ble Punjab & Haryana High Court in the case of Telelinksys.CIT [377 ITR 158, P&H HC] held that discretion to determine net profit vested in authorities must be exercised on basis of relevant factors which are past tax history of assessee, an appraisal of value of contract, price of raw material, labor etc. · We would like to humbly submit that in the case of a sub-contractor undertaking construction works, the Hon'ble Co…

D S R INFRASTRUCTURE PRIVATE LIMITED ,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(4), HYDERABAD

In the result, the appeals of Revenue in ITA Nos

ITA 51/HYD/2024[2020-21]Status: DisposedITAT Hyderabad29 Aug 2024AY 2020-21

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

…the Income Tax Act. What is chargeable to tax under the Income Tax Act is not the gross receipt but the income under the Income Tax Act. The tax is on income but not on gross receipts." · The Hon'ble Punjab & Haryana High Court in the case of Telelinksys.CIT [377 ITR 158, P&H HC] held that discretion to determine net profit vested in authorities must be exercised on basis of relevant factors which are past tax history of assessee, an appraisal of value of contract, price of raw material, labor etc. · We would like to humbly submit that in the case of a sub-contractor undertaking construction works, the Hon'ble Co…

DCIT., CENTRAL CIRCLE-1(4), HYDERABAD vs. DSR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

ITA 50/HYD/2024[2019-20]Status: DisposedITAT Hyderabad29 Aug 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

…the Income Tax Act. What is chargeable to tax under the Income Tax Act is not the gross receipt but the income under the Income Tax Act. The tax is on income but not on gross receipts." · The Hon'ble Punjab & Haryana High Court in the case of Telelinksys.CIT [377 ITR 158, P&H HC] held that discretion to determine net profit vested in authorities must be exercised on basis of relevant factors which are past tax history of assessee, an appraisal of value of contract, price of raw material, labor etc. · We would like to humbly submit that in the case of a sub-contractor undertaking construction works, the Hon'ble Co…

D S R INFRASTRUCTUREPRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE- 1(4), HYDERABAD

In the result, the appeals of Revenue in ITA Nos

ITA 49/HYD/2024[2019-20]Status: DisposedITAT Hyderabad29 Aug 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

…the Income Tax Act. What is chargeable to tax under the Income Tax Act is not the gross receipt but the income under the Income Tax Act. The tax is on income but not on gross receipts." · The Hon'ble Punjab & Haryana High Court in the case of Telelinksys.CIT [377 ITR 158, P&H HC] held that discretion to determine net profit vested in authorities must be exercised on basis of relevant factors which are past tax history of assessee, an appraisal of value of contract, price of raw material, labor etc. · We would like to humbly submit that in the case of a sub-contractor undertaking construction works, the Hon'ble Co…

SHRI RAJ KUMAR,GURGAON vs. ITO, GURGAON

ITA 1681/DEL/2017[2012-13]Status: DisposedITAT Delhi20 Feb 2020AY 2012-13

Bench: Shri O.P. Kant & Shri Kuldip Singh

For Appellant: NoneFor Respondent: Shri Satish Kumar Gupta, Senior DR
Section 145Section 32Section 68

…s of the case, whether the Ld CIT(A)-l Gurgaon, was justified in confirming the estimation of net profit @12% of the turnover ignoring the guidelines 2 ITA No.1681/Del./2017 prescribed by Hon'ble Punjab and Haryana High Court in the case of Telelinks v. CIT 377 ITR 158? 2. In the facts and circumstances of the case, whether the Ld. CIT(A)-l Gurgaon, was justified in confirming the addition of outstanding sundry of Rs.2,13,58,136/- as on 31.03.2012 u/s 68 of the Income Tax Act, 1961? 3. In the facts and circumstances of the case, whether the Ld. CIT(A)-l Gurgaon, was justified in not allowing the depreciation u/…