“section 153C proceedings”

VAAAN INFRA PRIVATE LIMITED,HARYANA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, NEW DELHI

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 1524/Del/2025 : Asstt. Year: 2019-20 Ita No. 1525/Del/2025 : Asstt. Year: 2020-21 Vaaan Infra Pvt. Ltd., Vs Dcit, Villa-8, Block-Ii, Eros Garden, Central Circle-30, Charmwood Village, Surajkund New Delhi-110055 Road, Faridabad-121009 (Appellant) (Respondent) Pan No. Aadcv5910G Assessee By : Sh. Shiv Kumar Lath, Ca, Sh. Harish Kumar Choudhary, Ca & Sh. Mohit Choudhary, Ca Revenue By : Ms. Amish S. Gupt, Cit-Dr Date Of Hearing: 28.01.2026 Date Of Pronouncement: 28.01.2026 Order Per Satbeer Singh Godara: These Assessee’S Twin Appeals For Assessment Years 2019- 20 & 2020-21 Arise Against The Cit(A)-30, New Delhi’S Din & Order Nos. Itba/Apl/M/250/2024-25/1072166771(1) & 1072172353(1) Both Dated 15.01.2025, In Proceedings U/S 153C R.W.S. 143(3) Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’, NEW DELHI Before Sh. Satbeer Singh Godara, Judicial Member & Sh. Manish

VAAAN INFRA PRIVATE LIMITED,FARIDABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, JHANDEWALAN EXTENSION

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 1524/Del/2025 : Asstt. Year: 2019-20 Ita No. 1525/Del/2025 : Asstt. Year: 2020-21 Vaaan Infra Pvt. Ltd., Vs Dcit, Villa-8, Block-Ii, Eros Garden, Central Circle-30, Charmwood Village, Surajkund New Delhi-110055 Road, Faridabad-121009 (Appellant) (Respondent) Pan No. Aadcv5910G Assessee By : Sh. Shiv Kumar Lath, Ca, Sh. Harish Kumar Choudhary, Ca & Sh. Mohit Choudhary, Ca Revenue By : Ms. Amish S. Gupt, Cit-Dr Date Of Hearing: 28.01.2026 Date Of Pronouncement: 28.01.2026 Order Per Satbeer Singh Godara: These Assessee’S Twin Appeals For Assessment Years 2019- 20 & 2020-21 Arise Against The Cit(A)-30, New Delhi’S Din & Order Nos. Itba/Apl/M/250/2024-25/1072166771(1) & 1072172353(1) Both Dated 15.01.2025, In Proceedings U/S 153C R.W.S. 143(3) Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’, NEW DELHI Before Sh. Satbeer Singh Godara, Judicial Member & Sh. Manish

MANJU GOYAL,DELHI vs. PR, CIT CENTRAL -3, DELHI

Appeal is allowed

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 3460/Del/2025 : Asstt. Year: 2016-17 Manju Goyal, Vs Pr. Cit (Central)-3, B-1/48, Phse-1, Ashok Vihar, New Delhi-110055 New Delhi-110052 (Appellant) (Respondent) Pan No. Aahpg9972E Assessee By : Ms. Rano Jain, Adv., Sh. Pranshu Singhal, Ca & Ms. Mansi Jain, Adv. Revenue By : Ms. Ankush Kalra, Sr. Dr Date Of Hearing: 27.01.2026 Date Of Pronouncement: 27.01.2026 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2016-17 Arises Against The Pcit(Central)-3, Delhi’S Din & Order No. Itba/Rev/F/Rev5/2024–25/1075213378(1) Dated 28.03.2025, In Proceedings U/S 263 Of The Income Tax Act, 1961 (In Short “The Act”).

that the learned departmental authorities had carried out the search in question in M/s Alankit Group on 18.10.2019 which led to initiation of section 153C proceedings against the assessee finally culminating in the Assessing Officer’s assessment order forming subject matter of revision proceedings herein. 5. That being the case

GEETANJALI BHAYANA,DELHI vs. DCIT CENTRAL CIRCLE-32 DELHI, NEW DELHI

opinion that the material is likely to be\nincriminating for more than a singular assessment year and thus\nwarranting the drawl of Section 153C proceedings for years in\naddition to those to which the material may be directly relatable.\nG. CONCLUSIONS\n63. On an overall consideration of the structure

GEETANJALI BHAYANA,DELHI vs. DCIT CENTRAL CIRCLE-32 DELHI, NEW DELHI

In the result, appeals of the assessee for AY 2019-20 and AY\n2020-21 are allowed

opinion that the material is likely to be\nincriminating for more than a singular assessment year and thus\nwarranting the drawl of Section 153C proceedings for years in\naddition to those to which the material may be directly relatable.\nG. CONCLUSIONS\n63.\nOn an overall consideration of the structure

GEETANJALI BHAYANA,DELHI vs. DCIT CENTRAL CIRCLE-32 DELHI, NEW DELHI

In the result, appeals of the assessee for AY 2019-20 and AY\n2020-21 are allowed

opinion that the material is likely to be\nincriminating for more than a singular assessment year and thus\nwarranting the drawl of Section 153C proceedings for years in\naddition to those to which the material may be directly relatable.\n\nG. CONCLUSIONS\n\n63. On an overall consideration

GAUTAM CHOPRA,NEW DELHI vs. DCIT, JHANDEWALLAN EXTENSION

In the result, appeal of the assessee is allowed

opinion that the material is likely to be\nincriminating for more than a singular assessment year and thus\nwarranting the drawl of Section 153C proceedings for years in addition\nto those to which the material may be directly relatable.\nG. CONCLUSIONS\n63. On an overall consideration of the structure ... learned assessing authority in the assessee's case\nhad erred in law and on facts in recording an improper satisfaction\nbefore initiating section 153C proceedings which vitiates the\nassessment itself in above terms. Ordered accordingly.\n8. As observed above, in the instant case, AO has recorded the\nsatisfaction that entries

ADITI INFRABUILD AND SERVICES LTD.,DELHI vs. DCIT, CENTRAL CIRCLE-30, DELHI

In the result, appeal of the assessee is allowed

opinion that the material is likely to be\nincriminating for more than a singular assessment year and thus\nwarranting the drawl of Section 153C proceedings for years in\naddition to those to which the material may be directly relatable.\nG. CONCLUSIONS\n63.\nOn an overall consideration of the structure ... learned assessing authority in the\nassessee's case had erred in law and on facts in recording an\nimproper satisfaction before initiating section 153C proceedings\nwhich vitiates the assessment itself in above terms. Ordered\naccordingly.\n8. As observed above, in the instant case, AO has recorded\nsatisfaction that the entries

NEHA GUPTA,DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 32, DELHI, DELHI

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

arising from assessment orders passed under Section 153C. The primary ground of appeal challenges the validity of the Section 153C proceedings as being time-barred.", "held": "The Tribunal held that the satisfaction note recorded by the AO and the notice issued under Section 153C fell outside the prescribed window

NISHAN INBUILD LIMITED,DELHI vs. PR,CIT CENTRAL KNP, MEERUT

Appeal is allowed

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI AMITABH SHUKLA (Accountant Member)

group of cases (including the assessee) wherein they allegedly came across the corresponding incriminating material triggering initiation of section 153C proceedings. All this finally culminated in the impugned assessment wherein the Assessing Officer added the corresponding section 68 unexplained cash credits and commission income @ 4% in the assessee’s hands