Union of India v. Rajeev Bansal

469 ITR 46Supreme Court of India2024#72 most cited

What is Union of India v. Rajeev Bansal authority for?

The legal fiction created by the Ashish Agarwal judgment stops the limitation clock for Section 148 notices from the date of the deemed notice. Orders issued without proper jurisdiction, or those inconsistent with statutory prescriptions, are a nullity, and there can be no waiver of such fundamental jurisdictional requirements.

713

judgments rely on this decision, according to BharatTax’s citation analysis of 366,416 Indian tax judgments — from 2023 to 2026.

Also referred to as

Union of India v. Rajeev Bansal · Section 148 notice limitation · Ashish Agarwal legal fiction · TOLA applicability · reassessment jurisdiction · time-barred notice · order without jurisdiction · Section 149 · Section 148A

Also reported as

167 Taxmann.com 70301 Taxmann 238

Sections most often in play

Section 148Section 147Section 148ASection 151Section 149Section 144BSection 250Section 144
Read the full judgment

Issues it is cited on

section 149a(c)section 149a(d)section 149asection 151(i)section 149(1)(a)section 3(1)section 148a(a)section 148 noticesection 151(ii)section 149(1)section 149(1)(b)order under section 148a(d)

Judgments citing Union of India v. Rajeev Bansal

Ess Gee Trendz Private Limited, Peeragarhi vs. Assisstant Commissioner of Income Tax, Rohtak

In the result, the appeals of the Assessee in ITA Nos

ITA 3013/DEL/2025[2016-17]Status: DisposedITAT Delhi28 Nov 2025AY 2016-17

Bench: Shri M. Balaganesh & Ms Madhumita Roy

For Appellant: Shri Anuj Tiwari, CAFor Respondent: Shri Om Parkash, Sr. DR
Section 143(3)Section 144Section 147Section 148Section 149Section 151Section 68

…made the re-assessment under the old law without following the decisions of Hon‟ble Supreme Court in the case of Ashish Agarwal reported in 444 ITR 1 (SC) and the decision of the Hon‟ble Supreme Court in the case of Union of India vs Rajeev Bansal reported in 469 ITR 46 (SC). This also makes the entire re-assessment bad in law and void abinitio. 8. For these invalid assumption of jurisdiction and incorrect recording of reasons, the competent authority had accorded sanction under section 151 of the Act, which makes the approval granted by the competent authority under section 151 of the Act also as a mechanical ap…

Ess Gee Trendz Private Limited, Peeragarhi vs. Assistant Commissioner of Income Tax, Rohtak

In the result, the appeals of the Assessee in ITA Nos

ITA 3012/DEL/2025[2015-16]Status: DisposedITAT Delhi28 Nov 2025AY 2015-16

Bench: Shri M. Balaganesh & Ms Madhumita Roy

For Appellant: Shri Anuj Tiwari, CAFor Respondent: Shri Om Parkash, Sr. DR
Section 143(3)Section 144Section 147Section 148Section 149Section 151Section 68

…made the re-assessment under the old law without following the decisions of Hon‟ble Supreme Court in the case of Ashish Agarwal reported in 444 ITR 1 (SC) and the decision of the Hon‟ble Supreme Court in the case of Union of India vs Rajeev Bansal reported in 469 ITR 46 (SC). This also makes the entire re-assessment bad in law and void abinitio. 8. For these invalid assumption of jurisdiction and incorrect recording of reasons, the competent authority had accorded sanction under section 151 of the Act, which makes the approval granted by the competent authority under section 151 of the Act also as a mechanical ap…

Ess Gee Trendz Private Limited, Peeragarhi vs. Assisstant Commissioner of Income Tax, Rohtak

In the result, the appeals of the Assessee in ITA Nos

ITA 3011/DEL/2025[2015-16]Status: DisposedITAT Delhi28 Nov 2025AY 2015-16

Bench: Shri M. Balaganesh & Ms Madhumita Roy

For Appellant: Shri Anuj Tiwari, CAFor Respondent: Shri Om Parkash, Sr. DR
Section 143(3)Section 144Section 147Section 148Section 149Section 151Section 68

…made the re-assessment under the old law without following the decisions of Hon‟ble Supreme Court in the case of Ashish Agarwal reported in 444 ITR 1 (SC) and the decision of the Hon‟ble Supreme Court in the case of Union of India vs Rajeev Bansal reported in 469 ITR 46 (SC). This also makes the entire re-assessment bad in law and void abinitio. 8. For these invalid assumption of jurisdiction and incorrect recording of reasons, the competent authority had accorded sanction under section 151 of the Act, which makes the approval granted by the competent authority under section 151 of the Act also as a mechanical ap…

Vipulkumar Parbhubhai Patel, Surat vs. ITO, Ward 2(3)(4), Surat

In the result, appeal of the assessee is allowed

ITA 741/SRT/2025[2016-17]Status: DisposedITAT Surat27 Nov 2025AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Prusethआयकर अपील सं./Ita No.741/Srt/2025 Assessment Year: (2016-17) (Hybrid Hearing) Vipulkumar Parbhubhai Patel, Vs. Ito, 378/1/2, Nishar Faliya, Puna Gam, Nr. Ward – 2(3)(4), Police Chowki, Surat - 395010 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Coipp7919F (Appellant) (Respondent) Appellant By Shri Suresh K. Kabra, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 27/11/2025 Date Of Pronouncement 24/12/2025

Section 144Section 147Section 148Section 148ASection 250Section 251(1)(a)Section 253(3)Section 69

…, submitted that the notice issued by the AO u/s 148 of the Act on 27.07.2022 is time barred. The notice should have been issued on or before 13.06.2022 in view of the decisions of the Hon’ble Supreme Court in cases of Union of India vs. Rajeev Bansal, (2024) 469 ITR 46 (SC) and Union of India & Others vs. Ashish Agarwal, Civil Appeal No.3005/2022. He, therefore, submitted that the notice u/s 148 of the Act may be quashed and the consequential order u/s 147 r.w.s. 144 r.w.s. 144B of the Act should be set aside. 9. On the other hand, the learned Senior Departmental Representative (ld. Sr. DR) of the revenue suppor…

Kusum Mittal, Sangrur vs. Income Tax Officer, Ward - Sangrur, Sangrur

In the result, the appeal of the assessee is allowed

ITA 941/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh27 Nov 2025AY 2015-16

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 147Section 148Section 151Section 69

…issued by National Faceless Assessment Centre and as such the proceedings initiated are illegal, arbitrary and unjustified. 2. That the notice issued u/s 148 is barred by limitation as held by the Hon'ble Supreme Court in Union of India v Rajeev Bansal(2023) 167 Taxmann.com 70(SC) WHARE the court held that for AY 2015-16, any notice issued after 01.04.2021 is not sustainable in as much as the same is issued beyond the prescribed period and as such the proceedings initiated are illegal, arbitrary and unjustified. 3. That the Ld. Commissioner of Income Tax (Appeals) has erred both in law and on facts in upholding…

Income-Tax Officer, Ward-4(1)(1), Ahmedabad vs. Shree Vishvamurte Trad Invest Private Limited, Ahmedabad

In the result, the appeal filed by the assessee in ITA No

ITA 432/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad27 Nov 2025AY 2017-18

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115BSection 143(1)Section 147Section 148Section 68Section 69C

…wherein the notice issued was to be treated as notice u/s. 148A(b) of the Act which has come into the statute with effect from 01-04-2021. 6.1. The Hon’ble Supreme Court in the later judgment in the case of Union of India Vs. Rajeev Bansal reported in (2024) 469 ITR 46 laid down the law to consider such notice as valid notice or invalid notice depending upon the surviving time left date of issuance of the notice u/s. 148 of the Act r.w.s. 3(1) of TOLA up to 30-06-2021 and the issuance of notice u/s.148 pursuant to the direction issued by the Apex Court in the case of Ashish Agarwal. 6.1. The above Supreme Court…

Shree Vishvamurte Tradinvest Private Limited, Ahmedabad vs. ITO Ward 4 (1) (1), Ahmedabad

In the result, the appeal filed by the assessee in ITA No

ITA 103/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad27 Nov 2025AY 2017-18

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115BSection 143(1)Section 147Section 148Section 68Section 69C

…wherein the notice issued was to be treated as notice u/s. 148A(b) of the Act which has come into the statute with effect from 01-04-2021. 6.1. The Hon’ble Supreme Court in the later judgment in the case of Union of India Vs. Rajeev Bansal reported in (2024) 469 ITR 46 laid down the law to consider such notice as valid notice or invalid notice depending upon the surviving time left date of issuance of the notice u/s. 148 of the Act r.w.s. 3(1) of TOLA up to 30-06-2021 and the issuance of notice u/s.148 pursuant to the direction issued by the Apex Court in the case of Ashish Agarwal. 6.1. The above Supreme Court…

Ravindra Kumar Vishwanath Yadav, Mumbai vs. ITO Ward 28(2)(1), Mumbai

In the result, the assessee’s appeal is allowed

ITA 4960/MUM/2025[2015-16]Status: DisposedITAT Mumbai27 Nov 2025AY 2015-16

Bench: Shri Narender Kumar Choudhryassessment Year: 2015-16 Mr. Ravindrakumar Vishwanath The Ito, Ward 28 (2)(1), Yadav, Tower 6, Vashi Railway Room No.1118, Samta Nagar Vs. Station Commercial Sector 1A, Airoli, Navi, Complex, Vashi, Mumbai – 400708 Navi Mumbai – 400703. Pan – Acbpy0748G. (Appellant) (Respondent) Present For: Assessee By : Shri Dharan Gandhi. Revenue By : Shri Sunil Mathews, Ld. Sr. D.R. Date Of Hearing : 13.11.2025 Date Of Pronouncement : 27.11.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 11.03.2024, Impugned Herein, Passed By The National Faceless Appeal Centre (Nfac)/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. 2015-16. 2. In This Case, The Assessing Officer (A.O.) Vide Assessment Order 11.03.2024 U/S. 147 R.W.S. 144 R.W.S. 144 B Of The Act, Has Made The Addition Of Rs. 14,75,000/- Being Variation In Respect Of Unexplained Investment U/S. 69 Of The Act.

For Appellant: Shri Dharan GandhiFor Respondent: Shri Sunil Mathews, Ld. Sr. D.R
Section 147Section 148Section 149Section 149(1)(b)Section 250Section 3Section 69

…Writ Petition (L) No. 32774 of 2025 decided on 13th October, 2025), wherein the Hon’ble Jurisdictional High Court by considering the judgment of the Hon’ble Apex Court in the case of 3 Mr. Ashwinkmar Krishnala Thanawala Union of India Vs. Rajeev Bansal (2024) 469 ITR 46 (SC) ultimately quashed such notice dated 5.12.2022 u/s 148 of the Act and consequently assessment order, notice of demand, penalty notices/orders as well as the recovery notices, by observing and holding as under: - “6. We have heard the learned counsel for the parties. It is not in dispute that the present petition relates to A.Y.2015-16. Furth…

Devender, Alwar vs. Income Tax Officer, Rewari

Appeal is allowed

ITA 4363/DEL/2025[2015-2016]Status: DisposedITAT Delhi27 Nov 2025AY 2015-2016

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

For Appellant: Sh. Pradeep Dang, CAFor Respondent: Sh. Khitesh Gupta, Sr. DR
Section 131Section 132Section 132ASection 133ASection 147Section 148Section 148ASection 149(1)Section 153ASection 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’, NEW DELHI Before Sh. Satbeer Singh Godara, Judicial Member & Sh. Manish Agarwal, Accountant Member ITA No. 4363/Del./2025 : Asstt. Year : 2015-16 Devender, Vs Income Tax Officer, Village Salarpur, PO Salarpur, Ward-2, Silarpur, B.O. Salarpur, Alwar, Rewari, Haryana Rajasthan-301018 (APPELLANT) (RESPONDENT) PAN No. BLBPD9303G Assessee by: Sh. Pradeep Dang, CA Revenue by: Sh. Khitesh Gupta, Sr. DR Date of Hearing: 27.11.2025 Date of Pronouncement: 27.11.2025 ORDER Per Satbeer Singh Godara, Judicial Member: This assessee’s appeal for Assessment Year 2015-16, aris…

Mohd. Alam Quershi, Moradabad vs. ITO Ward-1(1), Moradabad

In the result, the appeal of the assesse is allowed

ITA 3986/DEL/2025[2015-16]Status: DisposedITAT Delhi27 Nov 2025AY 2015-16

Bench: Shri Mahavir Singh & Shri Manish Agarwalmohd. Alam Quershi, Income Tax Officer, 0, Gol Kothi, Depduty Ganj, Ward-1(1), Moradabad-244001, Vs. Moradabad. Uttar Pradesh. Pan-Aadpq4002B (Appellant) (Respondent) Assessee By Shri Neeraj Jain, Ca & Shri P.K. Mishra, Ca Department By Shri Manish Gupta, Sr. Dr 19.11.2025 Date Of Hearing Date Of Pronouncement 19.11.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A) In Short], Dated 17.02.2025 In Appeal No. Nfac/2014-15/10282979 Arising Out Of The Assessment Order Passed U/S 147 R.W.S. 144 Dated 19.05.2023 For Assessment Year 2015-16. 2. Brief Facts Of The Case Are That Case Of The Assessee Was Reopened On The Basis Of Information Received That There Were Larger Credits In The Bank Account Of The Assessee & There Is Mismatch In The Income Declared By The Assessee & Credits In The Bank Account & Accordingly, Notice U/S 148 Was Issued On 06.04.2021. Mohd. Alam Qureshi Vs. Ito Thereafter, In Terms Of The Order Of Hon’Ble Supreme Court In The Case Of Union Of India Vs. Ashish Agarwal & Ors. In Civil Appeal No. 3005/2002, The Said Notice Was Treated As Notice U/S 148A(2) Of The Act. After Passing The Order U/S 148A(D) Of The Act, A Fresh Notice U/S 148 Was Issued On 29.07.2022. In Response, The Assessee Filed The Return On 28.08.2022 Declaring Total Income Of Rs. 3,90,230/-. The Assessment Was Completed U/S 147 R.W.S. 144B At An Income Of Rs. 58,64,382/- By Making Addition Of Rs. 54,74,132/-.

Section 147Section 148Section 148ASection 148A(2)

…. Ashish Agarwal (supra), the said notice was treated as the notice issued u/s 148A(b) of the Act. Thereafter the order u/s 148A(d) was passed and fresh notice u/s 148 was issued on 29.07.2022. In the case of Rajiv Bansal vs. Union of India reported in [2024] 469 ITR 46 (SC), the Hon’ble Supreme Court in para 19 has observed that the Revenue has accepted that no notice was issued for reopening for Assessment Year 2015-16, however, the case of the assessee was reopened, accordingly, it is prayed that the notice issued u/s 148 is contrary to the undertaking given by the government before the Hon’ble Supreme Court a…

Epam Systems India Private Limited, Hyderabad vs. DCIT, Circle -8 (1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 83/HYD/2022[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.83 & 498/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Epam Systems India The Dcit & The Acit, Private Limited, Vs. Circle-8(1), Hyderabad – 500 081 Hyderabad. Pan Aaacw2012R (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Shreyas Sardesai राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: CA Shreyas SardesaiFor Respondent: MS U Mini Chandran, CIT-DR
Section 143(3)

…mitation for passing the assessment order was extended by the Hon’ble Supreme Court. We further note that even the Hon’ble Supreme Court in the case of Union of India vs., Ashish Agarwal [2022] 444 ITR 1 (SC) and Union of India & Ors. vs. Rajeev Bansal [2024] 469 ITR 46 (SC) has considered the extension of limitation only to the extent of TOLA Notification. We further note that an identical issue has been considered by this Tribunal in the case of Aveva Solutions India LLP, Hyderabad vs., ITO, Ward-8(1), Hyderabad in ITA.No.1170/Hyd./2024 vide Order dated 19.11.2025 in Paras-7 to 14 as under : 19 ITA.Nos.83 and…

Epam Systems India Private Limited, Hyderabad vs. ACIT, Circle-8(1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 498/HYD/2022[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.83 & 498/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Epam Systems India The Dcit & The Acit, Private Limited, Vs. Circle-8(1), Hyderabad – 500 081 Hyderabad. Pan Aaacw2012R (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Shreyas Sardesai राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: CA Shreyas SardesaiFor Respondent: MS U Mini Chandran, CIT-DR
Section 143(3)

…mitation for passing the assessment order was extended by the Hon’ble Supreme Court. We further note that even the Hon’ble Supreme Court in the case of Union of India vs., Ashish Agarwal [2022] 444 ITR 1 (SC) and Union of India & Ors. vs. Rajeev Bansal [2024] 469 ITR 46 (SC) has considered the extension of limitation only to the extent of TOLA Notification. We further note that an identical issue has been considered by this Tribunal in the case of Aveva Solutions India LLP, Hyderabad vs., ITO, Ward-8(1), Hyderabad in ITA.No.1170/Hyd./2024 vide Order dated 19.11.2025 in Paras-7 to 14 as under : 19 ITA.Nos.83 and…

Repal Renewables Private Limited, Hyderabad vs. DCIT Circle -3(1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 481/HYD/2022[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.116 & 481/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Repal Renewables Private Limited, The Dcit, Circle-3(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aagcr9762B (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Harsh R Shah, Advocate & Ca Karan Jain राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: Sri Harsh R Shah, Advocate &For Respondent: MS U Mini Chandran, CIT-DR
Section 115JSection 143(3)Section 153Section 234Section 234BSection 234DSection 270A

…mitation for passing the assessment order was extended by the Hon’ble Supreme Court. We further note that even the Hon’ble Supreme Court in the case of Union of India vs., Ashish Agarwal [2022] 444 ITR 1 (SC) and Union of India & Ors. vs. Rajeev Bansal [2024] 469 ITR 46 (SC) has considered the extension of limitation only to the extent of TOLA Notification. We further note that an identical issue has been considered by this Tribunal in the case of Aveva Solutions India LLP, Hyderabad vs., ITO, Ward-8(1), Hyderabad in ITA.No.1170/Hyd./2024 vide Order dated 19.11.2025 in Paras-7 to 14 as under : “7. We have consid…

Repal Green Power Private Limited, Hyderabad vs. DCIT Circle -3(1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 474/HYD/2022[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.125/Hyd/2022 Assessment Year 2017-2018 Repal Green Power Private Limited, The Dcit, Circle-8(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aahcr2187F (Appellant) (Respondent) आ.अपी.सं /Ita No.474/Hyd/2022 Assessment Year 2018-2019 Repal Green Power Private Limited, The Dcit, Circle-3(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aahcr2187F (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Harsh R Shah, Advocate & Ca Karan Jain राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: Sri Harsh R Shah, Advocate &For Respondent: MS U Mini Chandran, CIT-DR
Section 143(3)Section 234Section 234DSection 270ASection 32Section 32A

…mitation for passing the assessment order was extended by the Hon’ble Supreme Court. We further note that even the Hon’ble Supreme Court in the case of Union of India vs., Ashish Agarwal [2022] 444 ITR 1 (SC) and Union of India & Ors. vs. Rajeev Bansal [2024] 469 ITR 46 (SC) has considered the extension of limitation only to the extent of TOLA Notification. We further note that an identical issue has been considered by this Tribunal in the case of Aveva Solutions India LLP, Hyderabad vs., ITO, Ward-8(1), Hyderabad in ITA.No.1170/Hyd./2024 vide Order dated 19.11.2025 in Paras-7 to 14 as under : 19 ITA.Nos.125 & 4…

Repal Green Power Private Limited, Hyderabad vs. DCIT, Circle 8(1), Hyderabad

ITA 125/HYD/2022[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.125/Hyd/2022

For Appellant: Sri Harsh R Shah, Advocate &For Respondent: MS U Mini Chandran, CIT-DR
Section 143(3)Section 234Section 234DSection 270ASection 32Section 32A

…mitation for passing the assessment order was extended by the Hon'ble Supreme Court. We further note that even the Hon'ble Supreme Court in the case of Union of India vs., Ashish Agarwal [2022] 444 ITR 1 (SC) and Union of India & Ors. vs. Rajeev Bansal [2024] 469 ITR 46 (SC) has considered the extension of limitation only to the extent of TOLA Notification. We further note that an identical issue has been considered by this Tribunal in the case of Aveva Solutions India LLP, Hyderabad vs., ITO, Ward-8(1), Hyderabad in ITA.No.1170/Hyd./2024 vide Order dated 19.11.2025 in Paras-7 to 14 as under : 19 ITA.Nos.125 & 47…

Repal Renewables Private Limited, Hyderabad vs. DCIT, Circle 8(1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 116/HYD/2022[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.116 & 481/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Repal Renewables Private Limited, The Dcit, Circle-3(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aagcr9762B (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Harsh R Shah, Advocate & Ca Karan Jain राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: Sri Harsh R Shah, Advocate &For Respondent: MS U Mini Chandran, CIT-DR
Section 115JSection 143(3)Section 153Section 234Section 234BSection 234DSection 270A

…mitation for passing the assessment order was extended by the Hon’ble Supreme Court. We further note that even the Hon’ble Supreme Court in the case of Union of India vs., Ashish Agarwal [2022] 444 ITR 1 (SC) and Union of India & Ors. vs. Rajeev Bansal [2024] 469 ITR 46 (SC) has considered the extension of limitation only to the extent of TOLA Notification. We further note that an identical issue has been considered by this Tribunal in the case of Aveva Solutions India LLP, Hyderabad vs., ITO, Ward-8(1), Hyderabad in ITA.No.1170/Hyd./2024 vide Order dated 19.11.2025 in Paras-7 to 14 as under : “7. We have consid…

Income Tax Officer, Ward-14(3), New Delhi vs. Kolahai Infotech Private Limited, Delhi

Accordingly, the cross objections for AY 2016-17 filed by the assessee is allowed

ITA 3554/DEL/2025[2017-18]Status: DisposedITAT Delhi26 Nov 2025AY 2017-18

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Ms. Amisha S. Gupt, CIT DR
Section 148Section 148ASection 151

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’: NEW DELHI BEFORE SHRIS.RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER ITA No.3554/DEL/2025 (Assessment Years : 2017-18) ITO, Ward 14 (3), vs. Kolahai Infotech Private Limited, Delhi. 129, First Floor, Transport Centre, Punjabi Bagh, New Delhi – 110 034. (PAN : AADCK3127C) CO No.138/Del/2025 (in ITA No.3553/DEL/2025) (Assessment Years : 2016-17) CO No.139/Del/2025 (in ITA No.3554/DEL/2025) (Assessment Years : 2017-18) Kolahai Infotech Private Limited, vs. ITO, Ward 14 (3), 129, First Floor, Delhi. Transport Centre, Punjabi Bagh, Ne…

Income Tax Officer, Ward-14(3), Delhi vs. Kolahai Infotech Private Limited, Delhi

Accordingly, the cross objections for AY 2016-17 filed by the assessee is allowed

ITA 3553/DEL/2025[2016-17]Status: DisposedITAT Delhi26 Nov 2025AY 2016-17

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Ms. Amisha S. Gupt, CIT DR
Section 148Section 148ASection 151

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’: NEW DELHI BEFORE SHRIS.RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER ITA No.3554/DEL/2025 (Assessment Years : 2017-18) ITO, Ward 14 (3), vs. Kolahai Infotech Private Limited, Delhi. 129, First Floor, Transport Centre, Punjabi Bagh, New Delhi – 110 034. (PAN : AADCK3127C) CO No.138/Del/2025 (in ITA No.3553/DEL/2025) (Assessment Years : 2016-17) CO No.139/Del/2025 (in ITA No.3554/DEL/2025) (Assessment Years : 2017-18) Kolahai Infotech Private Limited, vs. ITO, Ward 14 (3), 129, First Floor, Delhi. Transport Centre, Punjabi Bagh, Ne…

ACIT Circle-28(1), New Delhi vs. Kuldeep Kaur, New Delhi

Accordingly, the cross objections filed by the assessee for AY 2016-17 is allowed

ITA 5978/DEL/2024[2016-17]Status: DisposedITAT Delhi26 Nov 2025AY 2016-17

Bench: Shris.Rifaur Rahman & Shri Vimal Kumaracit, Circle 28 (1), Vs. Kuldeep Kaur, New Delhi. S – 493, Greater Kailash Part Ii, New Delhi – 110 048. (Pan : Aigps1433B) Co No.95/Del/2025 (In Ita No.5978/Del/2024) (Assessment Years : 2016-17) Kuldeep Kaur, Vs. Acit, Circle 28 (1), S – 493, Greater Kailash Part Ii, New Delhi. New Delhi – 110 048. (Pan : Aigps1433B) (Appellant) (Respondent) Assessee By : Shri V.K. Sabharwal, Advocate Shri Rajiv Kumar, Advocate Shri S.S. Agarwal, Ca Revenue By : Shri Om Prakash, Sr. Dr Date Of Hearing : 06.11.2025 Date Of Order : 26.11.2025 O R D E R Per S.Rifaur Rahman: 1. The Revenue Has Filed Appeal Against The Order Of Ld. Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi

For Appellant: Shri V.K. Sabharwal, AdvocateFor Respondent: Shri Om Prakash, Sr. DR
Section 144BSection 147Section 148Section 151

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘C’: NEW DELHI BEFORE SHRIS.RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI VIMAL KUMAR, JUDICIAL MEMBER ACIT, Circle 28 (1), vs. Kuldeep Kaur, New Delhi. S – 493, Greater Kailash Part II, New Delhi – 110 048. (PAN : AIGPS1433B) CO No.95/Del/2025 (in ITA No.5978/DEL/2024) (Assessment Years : 2016-17) Kuldeep Kaur, vs. ACIT, Circle 28 (1), S – 493, Greater Kailash Part II, New Delhi. New Delhi – 110 048. (PAN : AIGPS1433B) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri V.K. Sabharwal, Advocate Shri Rajiv Kumar, Advocate Shri S.S. Agarwal, CA REVENUE BY : Shri Om Prakash, S…

Income Tax Officer, Ward-1(2)(1), Surat vs. Deepesh Vishnu Agarwal, Surat

In the result, the appeal of the revenue is dismissed

ITA 833/SRT/2024[2017-18]Status: DisposedITAT Surat25 Nov 2025AY 2017-18

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.833/Srt/2024

Section 144BSection 148Section 149Section 250

…ITA No.833/SRT/2024/AY 2017-18 Deepesh Vishnu Agarwal IN THE INCOME-TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER & SHRI BIJAYANANDA PRUSETH, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.833/SRT/2024 Assessment Year: (2017-18) (Physical hearing) ITO, Vs. Ward - 1(2)(1), Surat Deepesh Vishnu Agarwal, A/301, Surya Plaza, Surat City, Magdalla B.O., Surat - 395007 स्थायीलेखासं./जीआइआरसं./PAN/GIR No: AISPA2948P (Appellant) (Respondent) Appellant by Shri Ajay Uke, Sr. DR Respondent by Shri Ramesh Malpani, CA Date of Hearing 01/09/2025 Date of Pronouncement 15/11/2025 आदेश / ORDER…