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“Section 11(3)”

Section References (mined)Section 11Section 11(3)255 judgments

RAI SAHAB BHAIYALAL DUBEY EDUCATIONAL AND MEDICAL CHARITABLE TRUST,JABALPUR vs. INCOME TAX OFFICER (EXEMPTION), JABALPUR

In the result, the appeal is partly allowed for statistical purposes

ITA 186/JAB/2024[2020-21]Status: DisposedITAT Jabalpur10 Mar 2026AY 2020-21

Bench: Shri Anadee Nath Misshra

Section 11Section 11(2)Section 11ASection 12ASection 143(1)

holding that the assessee's right to accumulate 25% of the total income of the previous year extended to the deemed income under Section 11(3) of the Income-tax Act, 1961, added therein in the circumstances mentioned above?" 2. The facts found by the Tribunal as stated ... entire deemed income. 3. The Tribunal in agreeing with the decision of the Appellate Assistant Commissioner observed: The legal fiction contained in section 11(3) of the Income-tax Act, 1961, should be allowed to play to the fullest extent and there is no warrant to take a restricted view

NARROTAM MORARJEE INSTITUTE OF SHIPPING,MUMBAI vs. ITO (EXEMPTION)WARD 2(1), MUMBAI

In the result, appeal of the assessee is allowed

ITA 5559/MUM/2025[2018-19]Status: DisposedITAT Mumbai16 Feb 2026AY 2018-19

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2018-19 Narrotam Morarjee Institute Of National Faceless Shipping, Mumbai Assessment Appeal Centre 76 – Jolly Maker, Chambers – 2, (Nfac) Office Of The Vs. Vivek Shah, Mumbai, Nariman Commissioner Of Income Point S.O.-400021 Tax, Appeal, Addl/Jcit(A) Delhi (Pan : Aaatn0042R) (Appellant) (Respondent) Present For: Assessee : Shri Nishit Gandhi, Advocate Revenue : Shri Leyaqat Ali Afaqui, Sr. Dr Date Of Hearing : 18.11.2025 Date Of Pronouncement : 16.02.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Commissioner Of Income Tax (Appeal), National Faceless Appeal Centre (Nfac), Delhi Vide Order No. Itba/Nfac/S/250/2025- 26/1078465227(1) Dated 14.07.2025 Passed Against The Penalty Order U/S. 270A Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), For Ay 2018-19. 2. Grounds Taken By The Assessee Are Reproduced As Under: 1. In The Facts & Circumstances Of The Case & In Law, The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeals Centre, Delhi ["The Cit (A)") U/S 250 Of The Income Tax Act, 1961 ["The Act For Short Erred In Confirming The Penalty U/S 270A Of The Act Passed

For Appellant: Shri Nishit Gandhi, AdvocateFor Respondent: Shri Leyaqat Ali Afaqui, Sr. DR
Section 11Section 11(1)(a)Section 11(2)Section 12ASection 250Section 270A

that assessee had duly reported the unutilized amount on the expiry of five years which is deemed to be income as per section 11(3), in the return of income filed by it. Ld. AO has acknowledged this reporting of income by the assessee and thus, there is no suppression

ASST. DIRECTOR OF IT (EXEMP)-II,, HYDERABAD vs. ACTION FOR WELFARE AND AWAKENING IN RURAL ENVIRONMENT (AWARE), HYDERABAD

In the result, the C.O. filed by the assessee is partly allowed for statistical purposes

ITA 709/HYD/2012[1995-96]Status: DisposedITAT Hyderabad13 Feb 2026AY 1995-96

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.709/Hyd/2012 ("नधा"रण वष"/Assessment Year:1995-96) Asst. Director Of Income Tax Vs. Action For Welfare & (Exemptions)-Ii, Awakening In Rural Hyderabad. Environment (Aware), Shantivanam, Nagarjuna Sagar Road, Hyderabad. Pan: Aaata2338R (Appellant) (Respondent) C.O. No.138/Hyd/2012 (In आ.अपी.सं /Ita No.709/Hyd/2012) ("नधा"रण वष"/Assessment Year:1995-96) Asst. Director Of Income Tax Vs. Action For Welfare & (Exemptions)-Ii, Awakening In Rural Hyderabad. Environment (Aware), Pragati Bhavan, D.No.5-9- 24/78, Lake Hill Road, Adarshnagar, Hyderabad- 500463. Pan: Aaata2338R (Respondent/Cross Objector) (Appellant In Appeal) "नधा"रती "वारा/Assessee By: Shri S. Rama Rao, Advocate राज" व "वारा/Revenue By:: Ms. U. Mini Chandran, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing: 08/01/2026 घोषणा क" तार"ख/Pronouncement: 13/02/2026

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: : Ms. U. Mini Chandran, CIT-DR
Section 11Section 11(2)Section 11(3)Section 143(3)Section 147

assessing the total income of the assessee at Rs.13,76,58,674/-, mainly by invoking section 11(3) of the Act. 3. Aggrieved with the order of the Ld. AO, the assessee filed an appeal before the Ld. CIT(A). The Ld. CIT(A), after considering the submissions ... addition of Rs.13,76,58,674/-, holding that there was no accumulation under section 11(2) of the Act available for taxation under section 11(3) of the Act in the year under consideration. 4. Aggrieved by the order of the Ld. CIT(A), the Revenue is in appeal before

NAVALMAL FIRODIA MEMORIAL HOSPITAL TRUST,PUNE vs. INCOME TAX OFFICER, EXEMPTION WARD 1(2), PUNE

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

ITA 2460/PUN/2025[2023-24]Status: DisposedITAT Pune10 Feb 2026AY 2023-24

Bench: the learned CIT(A), the same has neither been taken note of or distinguished in any manner. Not following the binding Judicial precedent of the Jurisdictional ITAT Pune is gross impropriety in law. Ground No. 2: The Appellant craves leave to add, alter, amend or withdraw all or any of the Grounds of Appeal herein and to submit such statements, documents and papers as may be considered necessary either at or before the appeal hearing.”

For Appellant: Shri Shrenik GandhiFor Respondent: Shri Manish Sinha (Virtual)
Section 11Section 11(2)(a)Section 11(3)Section 11(3)(c)Section 12ASection 143(1)

adding back Rs.6,00,000 to the total income of the Appellant by invoking the 2 provisions of sub clause (c) of Section 11(3) r.w.s 115BBI of the Act. b) The learned CIT-A and CPC grossly misinterpreted the provisions of Section 11(3 ... hence the accumulations made in F.Y. 2016-2017 are out of the ambit of the amendment made to Section 11(3) of the Act and cannot be applied retrospectively. d) Without prejudice to the above, the order confirming the action of learned CPC is bad in law even

EMAAR INDIA LIMITED,NEW DELHI vs. ACIT, CENTRAL CIRCLE 2, NEW DELHI

In the result, appeal of the Assessee is allowed

ITA 4501/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayemaar India Limited Vs Acit 306-308, 3Rd Floor, Square One, C-2, Central Circle 2 Disrict Centre, Saket, New Delhi- New Delhi 110017, Pan: Aabce4308B Appellant Respondent Assessee By Sh. Sh. Neeeraj Jain, Adv, Sh. Ramit Katiyar, Ar & Ms. Mansha Bhalla, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 28/01/2026 Date Of Pronouncement 30/01/2026

Section 143(3)Section 144BSection 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

cannot be grappled with appropriately unless timely assessment is completed. In several taxing statutes, even in a situation like this, where assessment under Section 11(3) or 28(3) of the respective Acts is contemplated, a period of limitation is provided. Until by statute, such a limitation is provided

FEDERAL-MOGUL IGNITION PRODUCTS INDIA LIMITED,GURUGRAM vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 7(1), RANGE - 40, DELHI

In the result, appeal of the Assessee is allowed

ITA 4440/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayfederal Mogul Ignition Products Vs Dcit India Ltd. 10Th Floor, Towr B, Paras Circle 7(1) Twin Towers, Golf Course Road, New Delhi Sesctor-54 Gurugram, Haryana, Pan: Aaacf4128M Appellant Respondent Assessee By Ms. Nandita Singhal, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 28/01/2026 Date Of Pronouncement 30 /01/2026

Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 153Section 153(1)Section 153(4)

cannot be grappled with appropriately unless timely assessment is completed. In several taxing statutes, even in a situation like this, where assessment under Section 11(3) or 28(3) of the respective Acts is contemplated, a period of limitation is provided. Until by statute, such a limitation is provided

QUALCOMM INDIA PRIVATE LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, NEW DELHI

In the result, appeals of the Assessees are allowed

ITA 4412/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahay

Section 143(3)Section 144BSection 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

cannot be grappled with appropriately unless timely assessment is completed. In several taxing statutes, even in a situation like this, where assessment under Section 11(3) or 28(3) of the respective Acts is contemplated, a period of limitation is provided. Until by statute, such a limitation is provided

REFOP INDIA COMPANY ,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, appeal of the Assessee is allowed

ITA 4409/DEL/2024[AY 2020-21]Status: DisposedITAT Delhi30 Jan 2026

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayrefop India Company Vs Dcit Office No. 6, 2Nd Floor, Sector-8, Circle 19(1) Pocket-7, Plot No. 11, Vasant Kunj, Delhi South West Delhi Pan: Aaacr3007K Appellant Respondent Assessee By Ms.Taranjeet Kaur, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 28/01/2026 Date Of Pronouncement 30/01/2026 Order Per Yogesh Kumar, U.S. Jm: The Captioned Appeal Is Filed By The Assessee Challenging The Final

Section 143(3)Section 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

cannot be grappled with appropriately unless timely assessment is completed. In several taxing statutes, even in a situation like this, where assessment under Section 11(3) or 28(3) of the respective Acts is contemplated, a period of limitation is provided. Until by statute, such a limitation is provided

PERSOLKELLY INDIA PRIVATE LIMITED,GURGAON vs. DEPUTY COMMISSIONER, DELHI

In the result, appeal of the Assessee is allowed

ITA 4390/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahaypersolkelly India Private Limited Vs Dcit Unit No. 1202, 1203, 1204, 12Th Circle 19(1), Floor, Tower C, Unitech Cyber Park, C. R. Building, Sector 29, Gurgaon, Haryana Delhi Pan: Aabck6665K Appellant Respondent Assessee By Ms. Taranjeet Kaur, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 28/01/2026 Date Of Pronouncement 30/01/2026

Section 143(3)Section 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

cannot be grappled with appropriately unless timely assessment is completed. In several taxing statutes, even in a situation like this, where assessment under Section 11(3) or 28(3) of the respective Acts is contemplated, a 12 Persolkelly India Pvt. Ltd. Vs. DCIT period of limitation is provided. Until

INTERCONTINENTAL HOTELS GROUP (INDIA) PRIVATE LIMITED,GURUGRAM vs. DCIT, GURUGRAM

In the result, appeal of the Assessee is allowed

ITA 4302/DEL/2024[AY 2020-21]Status: DisposedITAT Delhi30 Jan 2026

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayintercontinental Hotels Group (India) Vs Dcit Private Limited, 11Th Floor, Building Ao Type-C, Range Code- 10, Tower, C, Fld Cyber City Phase- 53, A.O Number-C, Circle- Ii, Gurugram, Haryana 1(1), Gurugram, Haryana Pan: Aagcs7613G Appellant Respondent Assessee By Sh. Ajin Kumar Jain, Ca, Ms. Nikhila Bhalla, Ca & Ms. Shreyanshi Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 28/01/2026 Date Of Pronouncement 30/01/2026

Section 143(3)Section 144BSection 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

cannot be grappled with appropriately unless timely assessment is completed. In several taxing statutes, even in a situation like this, where assessment under Section 11(3) or 28(3) of the respective Acts is contemplated, a 12 Inter Continental Hotels period of limitation is provided. Until by statute, such

DENTSPLY INDIA PRIVATE LIMITED,DELHI vs. NFAC, NEW DELHI

In the result, appeal of the Assessee is allowed

ITA 4261/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahaydentsply India Private Limited V National Faceless Khasra No. 6/20 & 66/11/2, Gali S Assessment Centre, No. 2 Main Rohtak Road Mundka Lok Nayak Bhawan, Industrial Area, New Delhi Khan Market, New Delhi Pan: Aaacd3171E Appellant Respondent Assessee By Sh. Pranay Gandhi, Adv (Virtual) Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 30/01/2026

Section 143(3)Section 144BSection 144CSection 144C(13)Section 153Section 153(1)Section 153(4)Section 92C

assessment is completed. In 12 Dentsply India Pvt. Ltd. Vs. NFAC several taxing statutes, even in a situation like this, where assessment under Section 11(3) or 28(3) of the respective Acts is contemplated, a period of limitation is provided. Until by statute, such a limitation is provided

LONZA INDIA PRIVATE LIMITED,GURUGRAM vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1), GURGAON, GURGAON

In the result, appeal of the Assessee is allowed

ITA 4155/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahaylonza India Pirvate Limited Vs Dcit Novus Tower, Ground Floor, Plot No. Circle 1(1), Hsiidc 18, Sector 18, Palam Road, Building, Vanijyanikunj, Gurgaon, Haryana, 122015 Udyogvihar, Phase-V, Pan: Aaacc8679A Gurgaon, Haryana

Section 143(3)Section 144CSection 144C(13)Section 153Section 153(1)Section 153(4)Section 5

cannot be grappled with appropriately unless timely assessment is completed. In several taxing statutes, even in a situation like this, where assessment under Section 11(3) or 28(3) of the respective Acts is contemplated, a period of limitation is provided. Until by statute, such a limitation is provided

G-MOBILE DEVICES PRIVATE LIMITED,NOIDA vs. DCIT CIRCLE 5(1)(1), NOIDA

In the result, appeal of the Assessee is allowed

ITA 3883/DEL/2024[AY 2020-21]Status: DisposedITAT Delhi30 Jan 2026

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayg-Mobile Devices Pvt. Ltd. Vs Dcit Unit No. B-301, Third Floor, Tower- Circle-5(1)(1), Gautam B, Plot No. 7, Advant Iet Park, Buddha Nagar, Nodia, Sector 142, Noida, 201301 201301, Uttar Pradesh Pan: Aagcg5071N Appellant Respondent Assessee By Ms. Taranjeet Kaur, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 28/01/2026 Date Of Pronouncement 30/01/2026

Section 143(3)Section 144BSection 144CSection 144C(13)Section 153Section 153(1)Section 153(4)Section 5

cannot be grappled with appropriately unless timely assessment is completed. In several taxing statutes, even in a situation like this, where assessment under Section 11(3) or 28(3) of the respective Acts is contemplated, a period of limitation is provided. Until by statute, such a limitation is provided

FUJITSU CONSULTING INDIA PRIVATE LIMITED,DELHI vs. THE DEPUTY COMMISSIONER OF INCOME-TAX , DELHI

In the result, appeals of the Assessees are allowed

ITA 3878/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahay

Section 143(3)Section 144BSection 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

cannot be grappled with appropriately unless timely assessment is completed. In several taxing statutes, even in a situation like this, where assessment under Section 11(3) or 28(3) of the respective Acts is contemplated, a period of limitation is provided. Until by statute, such a limitation is provided

MIH INTERNET SEA PTE LTD,SINGAPORE vs. ACIT, CIRCLE 2(2)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, appeal of the Assessee is allowed

ITA 1683/DEL/2023[2017-18]Status: DisposedITAT Delhi30 Jan 2026AY 2017-18

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahaymih Internet Sea Pte Ltd. Vs The Assessing Officer 1 Scotts Roas,# 21-07, Shaw Centre, Regional E-Assessment Singapore, Unit, National E- Pan:Aakcm7136N Assessment Centre, (Nwr/C/53/1, Jurisdiction Circle 1(1), Gurgaon Appellant Respondent Assessee By Sh. Percy Pardiwala, Sr. Adv (Virtual, Ms. Ananya Kapoor, Adv & Ms. Shruti Khimta, Ar Revenue By Sh. Shlock Chandra, Special Counsel & Sh. Udit Dad, Adv Date Of Hearing 29/01/2026 Date Of Pronouncement 30/01/2026

Section 143(3)Section 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

cannot be grappled with appropriately unless timely assessment is completed. In several taxing statutes, even in a situation like this, where assessment under Section 11(3) or 28(3) of the respective Acts is contemplated, a period of limitation is provided. Until by statute, such a limitation is provided

QUALCOMM INDIA PRIVATE LIMITED,NEW DELHI vs. ACIT, CIRCLE-19(1), NEW DELHI

In the result, appeals of the Assessees are allowed

ITA 537/DEL/2022[2017-18]Status: DisposedITAT Delhi30 Jan 2026AY 2017-18

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahay

Section 143(3)Section 144BSection 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

cannot be grappled with appropriately unless timely assessment is completed. In several taxing statutes, even in a situation like this, where assessment under Section 11(3) or 28(3) of the respective Acts is contemplated, a period of limitation is provided. Until by statute, such a limitation is provided

HEADSTRONG SERVICES INDIA PVT LTD,NEW DELHI vs. ACIT, CIRCLE 10(1) , NEW DELHI

In the result, appeal of the Assessee is allowed

ITA 2403/DEL/2022[2018-19]Status: DisposedITAT Delhi30 Jan 2026AY 2018-19

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayheadstrong Services India Pvt. Ltd. Vs Acit 12A, Ground Floor, Prakash Deep Circle 10(1) Building 7, Tolstoy Marg, New Delhi Delhi Pan: Aabct7650D Appellant Respondent Assessee By Ms. Snigdha Gautam, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 28/01/2026 Date Of Pronouncement 30/01/2026

Section 143(3)Section 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

completed. In 12 Headstrong Services India Pvt. Ltd. vs. ACIT several taxing statutes, even in a situation like this, where assessment under Section 11(3) or 28(3) of the respective Acts is contemplated, a period of limitation is provided. Until by statute, such a limitation is provided

QUALCOMM INDIA PVT LTD,NEW DELHI vs. ACIT CIRCLE 19 (1) , NEW DELHI

In the result, appeals of the Assessees are allowed

ITA 2374/DEL/2022[2018-19]Status: DisposedITAT Delhi30 Jan 2026AY 2018-19

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahay

Section 143(3)Section 144BSection 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

cannot be grappled with appropriately unless timely assessment is completed. In several taxing statutes, even in a situation like this, where assessment under Section 11(3) or 28(3) of the respective Acts is contemplated, a period of limitation is provided. Until by statute, such a limitation is provided

FUJITSU CONSULTING INDIA PVT LTD NEW DELHI,NEW DELHI vs. ACIT,CIRCLE 7,(1), DELHI, DELHI

In the result, appeals of the Assessees are allowed

ITA 1698/DEL/2022[2018-19]Status: DisposedITAT Delhi30 Jan 2026AY 2018-19

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahay

Section 143(3)Section 144BSection 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

cannot be grappled with appropriately unless timely assessment is completed. In several taxing statutes, even in a situation like this, where assessment under Section 11(3) or 28(3) of the respective Acts is contemplated, a period of limitation is provided. Until by statute, such a limitation is provided

ROLLS-ROYCE INDIA PRIVATE LIMITED,NEW DELHI vs. ACIT, CIRCLE-19(1), DELHI

In the result, appeal of the Assessee is allowed

ITA 1672/DEL/2022[2018-19]Status: DisposedITAT Delhi30 Jan 2026AY 2018-19

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayrolls-Royce India Private Limited Vs Acit 2Nd Floor, Birla Tower (West), 25 Circle 19(1), Barakhamba Road, New Delhi Delhi Pan: Aabcr5277Q Appellant Respondent Assessee By Sh. Nikhil Tiwary, Ca(Virtual) Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 28/01/2026 Date Of Pronouncement 30/01/2026

Section 143(3)Section 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

cannot be grappled with appropriately unless timely assessment is completed. In several taxing statutes, even in a situation like this, where assessment under Section 11(3) or 28(3) of the respective Acts is contemplated, a period of limitation is provided. Until by statute, such a limitation is provided

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