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
…n of Hon‘ble Gauhati High Court in the case of Ram Narayan Sahvs Union of India reported in 163 Taxmann.com 478 (Gau HC) and after considering the decision of Hon‘ble Calcutta High Court in the case of Triton Overseas Private Ltd vs Union of India reported in 156 Taxmann.com 318(Cal HC) [which has been heavily relied upon by the Learned DR before us], held Tayal sons Pvt. Ltd. Vs. DCIT that notice under section 148 of the Act issued by the Jurisdictional Assessing Officer to be bad in law as it is not in consonance with the provisions of section 151A read with Clause 3(b) of CBDT Notification dated 29-3-2022 an…