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“Principal Commissioner of Income-tax”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(34B) / Section 1171,805 judgments

RAMESHKUMAR KARSANBHAI PATEL,SURAT vs. ITO, WARD 2(3)(5), SURAT

Accordingly the estimated addition made of Rs.35,166/-[0.5% of 70,33,182/-] by the AC invoking provision of section 69C of the I.T Act stand deleted. Thus this ground is allowed

ITA 669/SRT/2025[2015-16]Status: DisposedITAT Surat09 Apr 2026AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 10(38)Section 115Section 115BSection 250Section 68Section 69C

conclusion. On this issue Hon'ble High Court of Calcutta has held: [2022] 139 taxmann.com 352 (Calcutta) HIGH COURT OF CALCUTTA Principal Commissioner of Income-tax Rameshkumar Karsanbhai Patel Vs. ITO Asst. Year : 2015-16 - 4– INCOME TAX DEPARTMENT Swati Bajaj T.S. SIVAGNANAM AND HIRANMAY BHATTACHARYYA, JJ. IA NO. GA/2/2022

DCIT, CENTRAL CIRCLE-14, NEW DELHI, JHANDEWALAN EXTN. vs. SHYAM SUNDER VERMA, MODEL TOWN-III

In the result, the appeal filed by the Department of Revenue is dismissed

ITA 8072/DEL/2025[2017-18]Status: DisposedITAT Delhi09 Apr 2026AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Vimal Kumardcit Vs. Shyam Sunder Verma Central Circle 14 R-66/2, Model Town-Iii New Delhi North West Delhi 110009 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acbpv 9328 D Appellant .. Respondent

For Appellant: Sh. Sandeep Goel, AdvFor Respondent: Ms. Monika Singh, CIT-DR
Section 127Section 132Section 142(1)Section 143(2)Section 143(3)Section 153BSection 153CSection 153DSection 250

finds no merit in these appeals; they are accordingly dismissed, without order on costs," Further, reliance is placed in the case of Principal Commissioner of Income-tax (Central- 1) vs. Ojjus Medicare (P.) Ltd. [2024] 161 taxmann.com 160 (Delhi)/[2024] 465 ITR 101 (Delhi) [03-04-2024]wherein

GYAN PRAKASH GUPTA,NEW DELHI vs. ITO WARD-10(4), NEW DELHI

In the result, appeal filed by the assessee is allowed

ITA 6271/DEL/2019[2015-16]Status: DisposedITAT Delhi09 Apr 2026AY 2015-16

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarlate Gyan Prakash Gupta Vs. Ito Through Legal Heir Raj Ward 10(4) Kumari Gupta New Delhi Plot No.6 & 7, Defence Enclave, Laxmi Nagar, East Delhi 110092 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Adupg 2697 N Appellant .. Respondent

For Appellant: Sh. Ajit Gandhi, AdvFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 10Section 10(38)Section 143(2)Section 143(3)Section 250Section 68

support filed by appellant. - [2023] 153 taxmann.com 579 (SC) Principal Commissioner of Income Tax Vs. Renu Aggarwal - [2024] 162 taxmann.com 700 (SC) Principal Commissioner of Income-tax Vs. Genuine Finance (P.) Ltd. - [2021] 126 taxmann.com 80 (Delhi) Principal Commissioner of Income-tax-12 Vs. Smt. Krishna Devi - [2025] 170 taxmann.com ... Kumari Vs. Income Tax Officer - [2024] 158 taxmann.com 506 (Delhi-Trib.) Sarika Binal Vs. Income Tax Officer - [2024] 162 taxmann.com 892 (Gujarat) Principal Commissioner of Income-tax Vs. Shri Ambalal Chimanlal Patel - [2023] 152 taxmann.com 330 (Gujarat) Principal Commissioner of Income-tax Vs. Genuine Finance P. Ltd - [2024] 161 taxmann.com

VIDYA SHANKER JAISWAL, SARGUJA,SARGUJA vs. ITO, WARD-2, AMBIKAPUR, AMBIKAPUR

The appeals of the assessee are allowed

ITA 142/RPR/2026[2014-15]Status: DisposedITAT Raipur24 Mar 2026AY 2014-15

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.141 & 142/Rpr/2026 "नधा"रण वष" /Assessment Years : 2013-14 & 2014-15

For Appellant: S/shri Yash Dhariwal &For Respondent: Dr. Priyanka Patel, Sr. DR
Section 143Section 143(2)Section 143(3)Section 148

observation of the aforesaid judgment are culled out as follows: 10. The aforesaid view came to be reiterated by the Court in Principal Commissioner of Income-Tax vs. Dart Infrabuild Pvt Ltd, as would be evident from the following observations which appear in that decision:- "15.2 The absence of notice ... observation of the aforesaid judgment are culled out as follows: 10. The aforesaid view came to be reiterated by the Court in Principal Commissioner of Income-Tax vs. Dart Infrabuild Pvt Ltd5, as would be evident from the following observations which appear in that decision:- "15.2 The absence of notice

VIDYA SHANKER JAISWAL, SARGUJA,SARGUJA vs. ITO, WARD-2, AMBIKAPUR, AMBIKAPUR

The appeals of the assessee are allowed

ITA 141/RPR/2026[2013-14]Status: DisposedITAT Raipur24 Mar 2026AY 2013-14

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.141 & 142/Rpr/2026 "नधा"रण वष" /Assessment Years : 2013-14 & 2014-15

For Appellant: S/shri Yash Dhariwal &For Respondent: Dr. Priyanka Patel, Sr. DR
Section 143Section 143(2)Section 143(3)Section 148

observation of the aforesaid judgment are culled out as follows: 10. The aforesaid view came to be reiterated by the Court in Principal Commissioner of Income-Tax vs. Dart Infrabuild Pvt Ltd, as would be evident from the following observations which appear in that decision:- "15.2 The absence of notice ... observation of the aforesaid judgment are culled out as follows: 10. The aforesaid view came to be reiterated by the Court in Principal Commissioner of Income-Tax vs. Dart Infrabuild Pvt Ltd5, as would be evident from the following observations which appear in that decision:- "15.2 The absence of notice

TECHPARK HOTELS PVT LTD,GURGAON vs. ADDI. CIT SPECIAL RANGE-9, NEW DELHI

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

ITA 9450/DEL/2019[2015-16]Status: DisposedITAT Delhi20 Mar 2026AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumartechpark Hotels Pvt. Ltd., Addl. Cit, Ground Floor, Central Wing, Special Range-9, Thapar House 124, Janpath, Vs. New Delhi. New Delhi-110001. Pan-Aabce5833H (Appellant) (Respondent) Assessee By Shri Neeraj Jain, Adv. & Shri Tavish Verma, Adv. Ms. Harpreet Kaur Hansra Sr. Dr Department By Date Of Hearing 20.01.2026 Date Of Pronouncement 20.03.2026 O R D E R Per Vimal Kumar, Jm: The Appeal Filed By The Assessee Is Against Order Dated 11.09.2019 Of The Learned Commissioner Of Income Tax (Appeals), New Delhi [Hereinafter Referred To As ‘The Ld. Cit(A)’] Passed U/S 250 Of The Income Tax Act, 1961, [Hereinafter Referred To As ‘The Act’] Arising Out Of Assessment Order Dated 30.12.2017 Of The Ld. Assessing Officer U/S 143(3) Of The Act For Assessment Year 2015-16. 2. Brief Facts Of The Case Are That The Assessee Filed Return Declaring Loss Of Rs.23,06,28,106/- On 30.11.2015. Notice U/S 143(2) Dated 22.09.2016 Was Issued. Notices U/S 142(1) Were Issued. Sh. Nikhil Agarwal & Shri Nirmal Malpani, Ca Appeared & Filed Details. On Completion Of Proceedings, Ld. Ao Vide Order Dated Techpark Hotels Pvt. Ltd. Vs. Acit

Section 142(1)Section 143(2)Section 143(3)Section 154Section 234DSection 250Section 56(2)Section 56(2)(viib)

Caddie Hotels Pvt. Ltd. ITA 470/2024, however following its own order passed in the case of Agra Portfolio (P.) Ltd. vs. Principal Commissioner of Income-tax: IT Appeal No.1385 of 2018 remitted the matter to the file of Ld. AO with directions and liberty to undertake an exercise of valuation ... Caddie Hotels Pvt. Ltd. ITA 470/2024, however following its own order passed in the case of Agra Portfolio (P.) Ltd. vs. Principal Commissioner of Income-tax: IT Appeal No.1385 of 2018 remitted the matter to the file of Ld. AO with directions and liberty to undertake an exercise of valuation

STEP LOGISTICS PRIVATE LIMITED,RAIPUR vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE 1(1), RAIPUR, RAIPUR

In the result, appeal of the assessee in ITA

ITA 636/RPR/2025[2017-18]Status: DisposedITAT Raipur19 Mar 2026AY 2017-18

Bench: Shri Partha Sarathi Chaudhury & Shri Avdhesh Kumar Mishraआयकर अपील सं. / Ita No.636/Rpr/2025 "नधा"रण वष" / Assessment Year : 2017-18 Step Logistics Private Limited A-1, Mahavir Gaushala Complex, K.K Road, Raipur (C.G.)-492 001 Pan: Aancs0382F

For Appellant: S/shri Praveen Khandelwal &For Respondent: Dr. Priyanka Patel, Sr. DR
Section 127Section 143(2)Section 143(3)Section 68

books of account by the AO. 20. The Division Bench of the High Court of Bombay in the case of Principal Commissioner of Income-tax v. Swananda Properties Pvt. Ltd. [2019 SCC OnLine Bom 13359] had an occasion to consider the said question and the same was accordingly answered ... appreciation of facts and it does not give rise for framing substantial question of law.” [Emphasis supplied] 22. In another case of Principal Commissioner of Income-tax v. Marg Ltd. [2017 SCC OnLine Mad 37852], the Division Bench of the High Court of Madras has held that the rejection

H K ISPAT PVT. LTD.,PANCHMAHAL vs. THE DY.CIT, CENTRAL CIRCLE-2, VADODARA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

ITA 1392/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad18 Mar 2026AY 2021-22

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblesn

Section 250Section 68

refer to ratios laid down by few Courts as under. (i) Decision of High Court of Gujarat in the case of Principal Commissioner of Income-tax v/s. Ambe Tradecorp (P.) Ltd vide 145taxmann.com27 dated 05.07.2022 wherein it was held as under: "Section 68 of the Income-tax Act, 1961 Cash

ACIT, CENTRAL CIRCLE-2, VADODARA, VADODARA vs. HK ISPAT PVT LTD, GODHRA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

ITA 1278/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad18 Mar 2026AY 2021-22

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblesn

Section 250Section 68

refer to ratios laid down by few Courts as under. (i) Decision of High Court of Gujarat in the case of Principal Commissioner of Income-tax v/s. Ambe Tradecorp (P.) Ltd vide 145taxmann.com27 dated 05.07.2022 wherein it was held as under: "Section 68 of the Income-tax Act, 1961 Cash

ACIT, CENTRAL CIRCLE-2, VADODARA, VADODARA vs. HK ISPAT PVT LTD, GODHRA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

ITA 1277/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad18 Mar 2026AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblesn

Section 250Section 68

refer to ratios laid down by few Courts as under. (i) Decision of High Court of Gujarat in the case of Principal Commissioner of Income-tax v/s. Ambe Tradecorp (P.) Ltd vide 145taxmann.com27 dated 05.07.2022 wherein it was held as under: "Section 68 of the Income-tax Act, 1961 Cash

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-20, DELHI , JHANDEWALAN vs. KRSKA CAPITAL PRIVATE LIMITED , DELHI

In the result the appeal of the Revenue is dismissed and the cross objection of the Assessee is allowed

ITA 4666/DEL/2025[2016-17]Status: DisposedITAT Delhi18 Mar 2026AY 2016-17

Bench: Shri Sudhir Kumar & Shri Manish Agarwalassessment Year: 2016-17

Section 132(4)Section 143(3)Section 147Section 148Section 68

from the Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General instead of Principal Commissioner of Income-tax-4 Delhi. (iii) Because the order appealed against (filed by revenue) to the extent mentioned above is contrary to law and facts of the case. 7. The assessee

MOHAMMED USMAN, BHILAI,DURG vs. INCOME TAX OFFICER-2(1), BHILAI, DURG

In the result, appeal of the assessee is allowed

ITA 180/RPR/2026[2011-12]Status: DisposedITAT Raipur17 Mar 2026AY 2011-12

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.180/Rpr/2026 "नधा"रण वष" /Assessment Year : 2011-12 Mohammed Usman C/25, Nandini Road, Power House, Bhilai-490 011, Dist. Durg Pan: Aafpu9292H

For Appellant: Shri Veekaas S Sharma, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 148

observation of the aforesaid judgment are culled out as follows: 10. The aforesaid view came to be reiterated by the Court in Principal Commissioner of Income-Tax vs. Dart Infrabuild Pvt Ltd, as would be evident from the following observations which appear in that decision:- "15.2 The absence of notice ... observation of the aforesaid judgment are culled out as follows: 10. The aforesaid view came to be reiterated by the Court in Principal Commissioner of Income-Tax vs. Dart Infrabuild Pvt Ltd5, as would be evident from the following observations which appear in that decision:- "15.2 The absence of notice

ACIT,CIRCLE -20(1),MUMBAI, MUMBAI vs. UTKARSHA VIVEK PARKAR, MUMBAI

In the result appeal filed by the Revenue is dismissed

ITA 6513/MUM/2025[2011-12]Status: DisposedITAT Mumbai16 Mar 2026AY 2011-12

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokaracit Circle-20(1), Utkarsha Vivek Mumbai Parkar, Room No. 305, 3Rd Vs. 108, A-Wing, Byculla Floor, Piramal Service Industrial Chambers, Parel, Estate, D. K. Cross Mumbai – 400 012. Road, Byculla, Mumbai-400 027 Pan/Gir No. Agjpp4377J (Applicant) (Respondent) Revenue By Shri Nayanjyoti Nath, Ld. Dr Assessee By Ms. Dinkle Hariya, Ld. Ar Date Of Hearing 11.03.2026 Date Of Pronouncement 16.03.2026

Section 133(6)Section 143(1)Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 69C

purchases were not proved. In this regard, the DR relied upon the recent judgments of the Hon’ble Bombay High Court in Principal Commissioner of Income-tax v. Kanak Impex (India) Ltd.[2025] 172 taxmann.com 283 (Bombay) andPrincipal Commissioner of Income-tax v. Drisha Impex (P.) Ltd.[2025] 173 taxmann.com ... learned Departmental Representative has placed reliance on the recent judgments of the Hon’ble Bombay High Court in the case of Principal Commissioner of Income-tax v. Kanak Impex (India) Ltd. (supra) and Principal Commissioner of Income-tax v. Drisha Impex (P.) Ltd.(Supra) to contend that the entire purchases

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), AHMEDABAD, AHMEDABAD vs. SAFAL ENGINEERS AND REALTIES LLP, AHMEDABAD

In the result, the appeal of the assessee is partly allowed while the appeal\nof the Revenue is dismissed

ITA 1731/AHD/2024[2022-23]Status: DisposedITAT Ahmedabad13 Mar 2026AY 2022-23
Section 143(3)

suggesting the receipt of on-money in the sale\ntransactions. The case laws referred by the ld. A.R. as follows:\n\n1. Principal Commissioner of Income-tax v. Nishant Construction (P.) Ltd\nSupreme Court of India [2019] 101taxmann.com 180 (SC)\n2.\nPrincipal Commissioner of Income-tax-3, Ahmedabad v. Nishant

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), AHMEDABAD, AHMEDABAD vs. SAFAL ENGINEERS AND REALTIES LLP, AHMEDABAD

In the result, the appeal of the assessee is partly allowed while the appeal\nof the Revenue is dismissed

ITA 1730/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad13 Mar 2026AY 2021-22
Section 143(3)

suggesting the receipt of on-money in the sale\ntransactions. The case laws referred by the ld. A.R. as follows:\n\n1. Principal Commissioner of Income-tax v. Nishant Construction (P.) Ltd\nSupreme Court of India [2019] 101taxmann.com 180 (SC)\n\n2. Principal Commissioner of Income-tax-3, Ahmedabad

SAFAL ENGINEERS AND REALTIES LLP,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-1(4), AHMEDABAD

The appeal of the assessee is partly allowed while the appeal\nof the Revenue is dismissed

ITA 1700/AHD/2024[2022-23]Status: DisposedITAT Ahmedabad13 Mar 2026AY 2022-23
Section 143(3)

suggesting the receipt of on-money in the sale\ntransactions. The case laws referred by the ld. A.R. as follows:\n\n1. Principal Commissioner of Income-tax v. Nishant Construction (P.) Ltd\nSupreme Court of India [2019] 101taxmann.com 180 (SC)\n\n2. Principal Commissioner of Income-tax-3, Ahmedabad

SAFAL ENGINEERS AND REALTIES LLP,AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-1(4), AHMEDABAD

In the result, the appeal of the assessee is partly allowed while the appeal\nof the Revenue is dismissed

ITA 1699/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad13 Mar 2026AY 2021-22
Section 143(3)

suggesting the receipt of on-money in the sale\ntransactions. The case laws referred by the ld. A.R. as follows:\n\n1. Principal Commissioner of Income-tax v. Nishant Construction (P.) Ltd\nSupreme Court of India [2019] 101taxmann.com 180 (SC)\n\n2.\nPrincipal Commissioner of Income-tax-3, Ahmedabad

DCIT, CIRCLE-1(1)(1), AHMEDABAD, AHMEDABAD vs. AMNEAL PHARMACEUTICALS PRIVATE LIMITED, AHMEDABAD

In the result, the appeal of the Department is dismissed

ITA 2139/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad12 Mar 2026AY 2022-23

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Dhinal Shah, ARFor Respondent: Shri Dhinal Shah, AR
Section 135Section 37(1)Section 80GSection 80G(5)

deduction cannot be denied merely because the payment formed part of CSR expenditure. 11. Further, in Gujarat Mineral Development Corporation Ltd. vs. Principal Commissioner of Income-tax-1 [2025] 176 taxmann.com 227 (Ahmedabad - Trib.), the Ahmedabad Tribunal held that Explanation 2 to section 37(1) of the Act operates independently ... Year –2022-23 - 6– 12. A similar principle was reiterated by the Ahmedabad Tribunal in TTEC India Customer Solutions (P.) Ltd. vs. Principal Commissioner of Income-tax-3 [2025] 176 taxmann.com 289 (Ahmedabad - Trib.), where the Tribunal observed that CSR expenditure disallowed under section 37(1) of the Act does

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, BENGALURU vs. ANALOG DEVICES INDIA PRIVATE LIMITED, BENGALURU

In the result, the Cross Objection is dismissed as infructuous

ITA 2074/BANG/2024[2011-12]Status: DisposedITAT Bangalore12 Mar 2026AY 2011-12
Section 250

Software\nPrivate Limited 111 taxmann.com 221, Commscope Networks (India)\nPvt. Ltd. v. ITO reported in [2017] 83 taxmann.com 418 (Bangalore\nTrib.), Principal Commissioner of Income-tax v. Saxo India (P.) Ltd.\nreported in [2016] 74 taxmann.com 88 (Delhi), Finastra Software,\nAspect Technologies and Blue Yonder. The Revenue has not brought

SWD INDUSTRIES,MUMBAI vs. PCIT (CENTRAL), MUMBAI-1, MUMBAI

In the result, all the appeals filed by the assessee for the respective assessment years are allowed, and the impugned orders passed by the learned PCIT under section 263 of the Act are set aside

ITA 9012/MUM/2025[2020-2021]Status: DisposedITAT Mumbai12 Mar 2026AY 2020-2021

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 9007/Mum/2025 (Assessment Year: 2014-15) 2. Ita No. 9008/Mum/2025 (Assessment Year: 2015-16) 3. Ita No. 9009/Mum/2025 (Assessment Year: 2016-17) 4. Ita No. 9010/Mum/2025 (Assessment Year: 2017-18) 5. Ita No. 9011/Mum/2025 (Assessment Year: 2019-20) & 6. Ita No. 9012/Mum/2025 (Assessment Year: 2020-21) Swd Industries, Pcit (Central), 1402, South Tower 25, Mumbai-1, South Prabhadevi, Vs. R. No. 1001, 10Th Mumbai-400 025 Floor, Pratistha Bhavan, Old Cgo Annexe, Maharshi Karve Road, Mumbai-400 020 Pan/Gir No. Aaofs8319L (Applicant) (Respondent) Assessee By Shri Salil Kapoor A/W Shri Sumit Lalchandani, Shri Shivam Yadav, Shri Shri Vinod Gupta, Ld. Ars Revenue By Shri Vivek Perampurna, Ld. Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026

Section 132Section 143(3)Section 153CSection 153DSection 263

revenue. 16. This principle has been consistently recognised in judicial precedents relied upon by the assessee. In Devender Kumar Gupta v. Principal Commissioner of Income-tax (supra) the Delhi Bench of the Tribunal, while examining an identical issue, observed as under: 8. The assessment orders make it categorical that ... erroneous so far as prejudicial to the interest of the Revenue. 17. The Hon’ble Madhya Pradesh High Court in Principal Commissioner of Income-tax v. Prakhar Developers (P.) Ltd.(supra)after referring various judicial precedents such as the Pune Bench of Tribunal in the case of Dhariwal Industries

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