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“Section 139(1)”

Section References (mined)Section 139Section 139(1)7,818 judgments

The decision most relied on for Section 139(1) is CIT v. Manjunatha Cotton & Ginning Factory (359 ITR 565), cited in 2,590 judgments on BharatTax.

Leading authorities on Section 139(1)

CIT v. Manjunatha Cotton & Ginning Factory
359 ITR 565 · 2013 · High Court
2,590
citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify whether the penalty proceedings are initiated for concealment of income or for furnishing inaccurate particulars of income. This non-specification vitiates the penalty proceedings.

Goetze (India) Ltd. v. CIT
284 ITR 323 · 2006 · Supreme Court
1,842
citing judgments

An assessee cannot raise a new claim or a claim not made in the original or revised return of income for the first time directly before the Assessing Officer during assessment proceedings.

CIT v. Kelvinator of India Ltd.
320 ITR 561 · 2010 · Supreme Court
1,673
citing judgments

An Assessing Officer cannot initiate reassessment proceedings under Section 147 of the Income Tax Act based on a mere change of opinion. Reassessment is permissible only when there is fresh tangible material leading to the belief of income escapement, not merely a review of existing facts.

CIT v. AIMIL Ltd.
321 ITR 508 · 2010 · High Court
1,629
citing judgments

Employee contributions to PF and ESIC, deposited beyond the due date under the respective Acts but within the due date for filing the income tax return under Section 139(1), are allowable deductions under Section 36(1)(va). Such disallowance cannot be made during processing under Section 143(1).

Checkmate Services Pvt. Ltd. v. CIT
143 Taxmann.com 178 · 2022 · Supreme Court
1,392
citing judgments

Employee contributions to provident fund and ESI deposited by an employer beyond the due dates prescribed under the respective special Acts are not allowable as a deduction under section 36(1)(va) of the Income-tax Act, 1961. Such disallowance can be made during processing under section 143(1).

CIT v. Gujarat State Road Transport Corporation
366 ITR 170 · 2014 · High Court
1,158
citing judgments

Employees' contributions to welfare funds, such as provident fund, are not allowable as a deduction under section 36(1)(va) if deposited beyond the due date prescribed under the respective welfare statutes, even by a single day. Such delayed deposits are not cured even if made before the income-tax return filing due date.

CIT v. Pruthvi Brokers & Shareholders
349 ITR 336 · 2012 · High Court
956
citing judgments

Appellate authorities can entertain fresh claims or revised computations of income made by an assessee, even if these were not submitted through a revised return of income.

CIT v. SSA’s Emerald Meadows
73 Taxmann.com 241 · 2016 · High Court
791
citing judgments

A penalty notice under section 271(1)(c) read with section 274 of the Income Tax Act is invalid if it fails to specify whether the penalty is for concealment of income or for furnishing incorrect particulars of income.

Judgments citing Section 139(1)

Surender Gupta, Delhi vs. DCIT, Central Circle-30, Delhi

In the result, the appeal of the assessee is partly allowed and of the Revenue is dismissed as discussed hereinabove

ITA 1672/DEL/2025[2020-21]Status: DisposedITAT Delhi24 Dec 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita Nos.1670 To 1672/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Surender Gupta, Dy. Cit, A-27, Phase-1, Ashok Vihar, Central Circle-30, H.O. North West Delhi-110052. Vs. Delhi. Pan-Aaopg2234J (Appellant) (Respondent) Ita Nos.2871 To 2873/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Dy. Cit, Surender Gupta, Central Circle-1, A-27, Phase-1, Ashok Vihar, Noida. Vs. H.O. North West Delhi-110052. Pan-Aaopg2234J (Appellant) (Respondent) Assessee By Shri Mayank Patwari, Adv. & Shri Aakash Ojha, Adv. Department By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 20.11.2025 Date Of Pronouncement 24.12.2025 O R D E R Per Manish Agarwal, Am: The Captioned Cross Appeals Are Filed By The Assessee & Revenue Against Three Separate Orders Of Ld. Commissioner Of Income Tax (Appeals)-30, New Delhi [“Ld. Cit(A) In Short”] U/S 250 Of The Income Tax Act, 1961 [“The Act In Short”], All Are Dated 24.02.2025 Against The Orders Of The Assessing Officer U/S 153A R.W.S Ita Nos.2871 To 2873/Del/2025 Surender Gupta Vs. Dcit 143(3) Of The Income Tax Act, 1961 (“The Act” For Short) For Assessment Years 2018-19, 2019-20 & 2020-21 Respectively.

Section 127Section 139(1)Section 153ASection 153DSection 250

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘G’: NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI

Surender Gupta, Delhi vs. DCIT, Central Circle-30, Delhi

In the result, the appeal of the assessee is partly allowed and of the Revenue is dismissed as discussed hereinabove

ITA 1671/DEL/2025[2019-20]Status: DisposedITAT Delhi24 Dec 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita Nos.1670 To 1672/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Surender Gupta, Dy. Cit, A-27, Phase-1, Ashok Vihar, Central Circle-30, H.O. North West Delhi-110052. Vs. Delhi. Pan-Aaopg2234J (Appellant) (Respondent) Ita Nos.2871 To 2873/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Dy. Cit, Surender Gupta, Central Circle-1, A-27, Phase-1, Ashok Vihar, Noida. Vs. H.O. North West Delhi-110052. Pan-Aaopg2234J (Appellant) (Respondent) Assessee By Shri Mayank Patwari, Adv. & Shri Aakash Ojha, Adv. Department By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 20.11.2025 Date Of Pronouncement 24.12.2025 O R D E R Per Manish Agarwal, Am: The Captioned Cross Appeals Are Filed By The Assessee & Revenue Against Three Separate Orders Of Ld. Commissioner Of Income Tax (Appeals)-30, New Delhi [“Ld. Cit(A) In Short”] U/S 250 Of The Income Tax Act, 1961 [“The Act In Short”], All Are Dated 24.02.2025 Against The Orders Of The Assessing Officer U/S 153A R.W.S Ita Nos.2871 To 2873/Del/2025 Surender Gupta Vs. Dcit 143(3) Of The Income Tax Act, 1961 (“The Act” For Short) For Assessment Years 2018-19, 2019-20 & 2020-21 Respectively.

Section 127Section 139(1)Section 153ASection 153DSection 250

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘G’: NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI

Surender Gupta, Delhi vs. DCIT, Central Circle-30, Delhi

In the result, the appeal of the assessee is partly allowed and of the Revenue is dismissed as discussed hereinabove

ITA 1670/DEL/2025[2018-19]Status: DisposedITAT Delhi24 Dec 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita Nos.1670 To 1672/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Surender Gupta, Dy. Cit, A-27, Phase-1, Ashok Vihar, Central Circle-30, H.O. North West Delhi-110052. Vs. Delhi. Pan-Aaopg2234J (Appellant) (Respondent) Ita Nos.2871 To 2873/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Dy. Cit, Surender Gupta, Central Circle-1, A-27, Phase-1, Ashok Vihar, Noida. Vs. H.O. North West Delhi-110052. Pan-Aaopg2234J (Appellant) (Respondent) Assessee By Shri Mayank Patwari, Adv. & Shri Aakash Ojha, Adv. Department By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 20.11.2025 Date Of Pronouncement 24.12.2025 O R D E R Per Manish Agarwal, Am: The Captioned Cross Appeals Are Filed By The Assessee & Revenue Against Three Separate Orders Of Ld. Commissioner Of Income Tax (Appeals)-30, New Delhi [“Ld. Cit(A) In Short”] U/S 250 Of The Income Tax Act, 1961 [“The Act In Short”], All Are Dated 24.02.2025 Against The Orders Of The Assessing Officer U/S 153A R.W.S Ita Nos.2871 To 2873/Del/2025 Surender Gupta Vs. Dcit 143(3) Of The Income Tax Act, 1961 (“The Act” For Short) For Assessment Years 2018-19, 2019-20 & 2020-21 Respectively.

Section 127Section 139(1)Section 153ASection 153DSection 250

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘G’: NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI

Income Tax Officer, Ward-1(1)(3), Dehradun, Aaykar Bhawan, Subhash Road vs. Uttarakhand Purv Sainik Kalyan Nigam Limited, Station Sub Area

In the result, appeal of the assessee is allowed

ITA 92/DDN/2024[2015-16]Status: DisposedITAT Dehradun23 Dec 2025AY 2015-16

Bench: Sh. Yogesh Kumar U.S. & Sh. Manish Agarwal

For Appellant: Sh. Tarandeep Singh, AdvFor Respondent: Sh. Amar Pal Singh, JCIT-DR
Section 10Section 139Section 139(1)Section 139(4)Section 143(3)Section 148Section 149Section 617

till 30.09.2016. 5. Learned DR before us vehemently argued that since the assessee had not filed the original return of income under section 139(1) of the Act, the learned Assessing Officer was duly justified in 4 ITA No. 3129/Del/2018 AY: 2014-15 reopening the assessment under section ... learned DR in view of the fact that when the return of income is not filed within the due date prescribed under section 139(1) of the Act, learned Assessing Officer is entitled as per the statute to issue notice under section 142(1) of the Act calling

Ms Kalamandir Jewellers Ltd., Surat vs. The Asst. Commissioner of Income Tax- Circle 1(1)(1), Surat

In the result, appeal of the assessee is allowed for statistical

ITA 1069/SRT/2024[2020-21]Status: DisposedITAT Surat23 Dec 2025AY 2020-21

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant ()

For Appellant: Mr. Sapnesh Sheth, AdvFor Respondent: Mr. Ajay Uke, Sr-DR
Section 143(1)Section 143(3)Section 36Section 36(1)(iii)Section 37

statutory dues and taxes relating to employees’ salaries, which had been paid on or before the due date of filing of return under section 139(1) of the Act, as extended up to 31.01.2021 for the relevant assessment year. It was further submitted that the amounts relating to Employees’ State

Mahendra Kumar Pandya, Indore vs. DCIT/ACIT 1(1), Ind, Indore

ITA 343/IND/2025[2019-20]Status: DisposedITAT Indore23 Dec 2025AY 2019-20

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Ms. Shreya Jain, A.RFor Respondent: Shri Ashish Porwal, Sr. DR
Section 139(1)Section 143Section 143(1)Section 90Section 91

assessee under section 90 of the Act on the ground that Form No. 67 was not filed within the due date prescribed under section 139(1) of the Act. According to the Assessing Officer, in view of Rule 128 of the Income-tax Rules, filing of Form No. 67 within ... Rules, Form No. 67 was required to be furnished on or before the due date of filing of return of income under section 139(1) of the Act and since the assessee failed to comply with this requirement, the Centralised Processing Centre was justified in denying the foreign tax credit

Kamal Singh, Indore vs. Income Tax Officer, Indore

ITA 284/IND/2025[2015-16]Status: DisposedITAT Indore23 Dec 2025AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Shri S. S. Solanki, C.AFor Respondent: Shri Ashish Porwal, Sr. DR
Section 139(1)Section 147Section 54bSection 54f

total consideration of ₹1,08,50,000/- but did not file his return of income within the time prescribed under section 139(1) of the Income-tax Act, 1961 (“the Act”). Based on information available with the Assessing Officer regarding the sale of the property, the assessment was reopened under

M/S. Swabhumi Vintrade Pvt. Ltd., Kolkata vs. D.C.I.T., Circle - 7(1), Kolkata

In the result, appeal of the assessee is allowed

ITA 1839/KOL/2025[2017-2018]Status: DisposedITAT Kolkata23 Dec 2025AY 2017-2018

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita No.1839/Kol/2025 (निर्धारणवर्ा/Assessment Years :2017-2018) M/S Swabhumi Vintrade Pvt. Vs Dcit, Circle-7(1), Kolkata Ltd. 5Th Floor, Hmp House, 4 Fairlie Place, Kolkata, West Bengal-700001 Pan No. :Aancs 9035 P (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्धाररतीकीओरसे /Assessee By : Shri Sunil Surana, Fca रधजस्वकीओरसे /Revenue By : Shri Sandip Sarkar, Jcit, Sr.Dr सुनवाई की तारीख / Date Of Hearing : 09/12/2025 घोषणा की तारीख/Date Of Pronouncement : 23.12.2025 आदेश / O R D E R Per Rajesh Kumar, Am: This Is An Appeal Filed By The Assessee Against The Order Passed By The Ld. National Faceless Appeal Centre (Nfac), Delhi, Dated 28.07.2025For The Assessment Year2017-2018. 2. At The Time Of Hearing, The Assessee Raised Additional Ground Which Is Extracted Below: In This Connection It Is Submitted That The Addition Has Been Made Outside The Issues For Which The Case Was Selected For Limited Scrutiny Which Is Bad In Law & Therefore The Entire Addition Is Liable To Be Deleted. Therefore, The Assessee Is Filing Herewith An Additional Ground Which Goes To The Root Of The Issue & No Fresh Investigation Of Facts Is Required. In View Of The Judgment Of The Hon'Ble Supreme Court In The Case Of Jute Corporation Of India Reported In 187 Itr Page 688 & National Thermal Power Corporation Reported In 229 Itr 383 The Additional Ground May Be Admitted. It Is Requested To Kindly Admit The Additional Grounds Which Are Enclosed Herewith.

For Appellant: Shri Sunil Surana, FCAFor Respondent: Shri Sandip Sarkar, JCIT, Sr.DR
Section 139(1)Section 143(2)Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, ACCOUNTANT MEMBER AND SHRI PRADIP KUMAR CHOUBEY

Soumik Chatterjee, Kolkata vs. ITO, Ward 33(2), Kolkata

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

ITA 1508/KOL/2025[2024-2025]Status: DisposedITAT Kolkata23 Dec 2025AY 2024-2025

Bench: the Ld. CIT(A), the appellant filed statement of computation of income claiming tax relief of Rs.2,20,926/- (foreign tax credit) instead of Rs.5,22,964/- as claimed in his revised return of income. However, the Ld. CIT(A) dismissed the appeal of the assessee on the ground that the Form 67 was not filed in time. In our opinion the foreign tax credit cannot be denied mere for the reason of late filing of form 67. We note that the case is squarely covered by the decision of coordinate Benches

Section 139Section 139(1)Section 143(1)Section 154Section 250Section 90Section 90(2)

IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH,KOLKATA SHRI RAJESH KUMAR, ACCOUNTANT MEMBER I.T.A. No.1508/Kol/2025 (Assessment Year 2024-25

Aalekha Supply Pvt. Ltd., Kolkata vs. I.T.O., Ward - 4(3), Kolkata

Appeal of the assessee is allowed

ITA 1286/KOL/2025[2013-2014]Status: DisposedITAT Kolkata23 Dec 2025AY 2013-2014

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 139(1)Section 147Section 148Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH,KOLKATA SHRI RAJESH KUMAR, ACCOUNTANT MEMBER I.T.A. No.1286/Kol/2025 (Assessment Year 2013-14

Deputy Commissioner of Income Tax, Central Circle-4(3), Kolkata vs. Gaurang Alloys and Iron Limited, Kolkata

In the result, the appeal of the revenue is dismissed

ITA 1257/KOL/2025[2020-21]Status: DisposedITAT Kolkata23 Dec 2025AY 2020-21

Bench: Shri Rajesh Kumar, Accountantmember & Shri Pradip Kumar Choubey, Judicialmember Assessment Year: 2020-21 Dcit, Central Circle-4(3), Kolkata…....………..............................……….……Appellant Vs. Gaurang Alloys & Iron Ltd...………….……………………...……...…..…..Respondent 402A, Mangalam, 24/26, Hemanta Basu Sarani, Kol-1.. [Pan: Aaccg1485A] Appearances By: Dr. Anup Biswas, Cit-Dr,Appeared On Behalf Of The Appellant. Shri S. Jhajharia, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 30, 2025 Date Of Pronouncing The Order :December 23, 2025 Order Per Rajesh Kumar: This Is An Appeal Preferred By The Revenue Against The Order Of The Cit(Appeals)-27, Kolkata (Hereinafter Referred To As The “Ld. Cit(A)”] Dated 25.02.2025Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’)For The Ay 2020-21. 2. The Only Issue Raised By The Revenue In This Appeal Is Against The Order Of Ld. Cit(A) Treating The Undisclosed Cash Sales/Receipts Of Rs.7,54,07,283/- As Business Transaction & Directing The Ao To Apply G.P Rate @ 6.5% To Determine The Profit From The Undisclosed Sales/Receipts.

Section 132(1)Section 139(1)Section 143(1)Section 153ASection 250Section 68

आयकर अपील"य अ"धकरण, कोलकाता पीठ, कोलकाता IN THE INCOMETAX APPELLATE TRIBUNAL “B”BENCH KOLKATA Before Shri Rajesh Kumar

Rahulkumar Bajaj Charitable Trust, Mumbai vs. Deputy Commissioner of Income Tax, Mumbai

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

ITA 1770/MUM/2025[2023-24]Status: DisposedITAT Mumbai23 Dec 2025AY 2023-24

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri R. R. Makwana, Addl. CIT
Section 11Section 12ASection 139(1)Section 143(1)Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SHRI OM PRAKASH KANT, AM AND MS. KAVITHA RAJAGOPAL, JM

Rahulkumar Bajaj Charitable Trust, Mumbai vs. Deputy Commissioner of Income Tax, Mumbai

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

ITA 1769/MUM/2025[2022-23]Status: DisposedITAT Mumbai23 Dec 2025AY 2022-23

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri R. R. Makwana, Addl. CIT
Section 11Section 12ASection 139(1)Section 143(1)Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SHRI OM PRAKASH KANT, AM AND MS. KAVITHA RAJAGOPAL, JM

Rahulkumar Bajaj Charitable Trust, Mumbai vs. Deputy Commissioner of Income Tax, Mumbai

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

ITA 1768/MUM/2025[2021-22]Status: DisposedITAT Mumbai23 Dec 2025AY 2021-22

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri R. R. Makwana, Addl. CIT
Section 11Section 12ASection 139(1)Section 143(1)Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SHRI OM PRAKASH KANT, AM AND MS. KAVITHA RAJAGOPAL, JM

Ashok Chaturvedi, Delhi vs. DCIT, Central Circle-2, Noida

In the result, the appeal of the assessee is allowed

ITA 5156/DEL/2025[2021-22]Status: DisposedITAT Delhi23 Dec 2025AY 2021-22

Bench: Shri Vimal Kumar & Ms Renu Jauhriashok Kumar Chaturvedi, Vs. Dcit, 305, 3Rd Floor, Pamposh Central Circle-2, Enclave, Greater Kailash- Noida 1, New Delhi (Appellant) (Respondent) Pan: Aacpc1661P

For Appellant: Shri Vir Sain Agarwal, AdvFor Respondent: Ms. Ankush Kalra, Sr. DR
Section 139(1)Section 143(1)Section 234ASection 234A(1)Section 250(6)

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “E”: NEW DELHI BEFORE SHRI VIMAL KUMAR, JUDICIAL MEMBER AND MS RENU JAUHRI, ACCOUNTANT

DCIT, Central Circle-20, Delhi vs. Lotus Herbals Pvt. Ltd, Delhi

In the result, appeal of the Revenue in appeal No

ITA 2445/DEL/2023[2016-17]Status: DisposedITAT Delhi23 Dec 2025AY 2016-17

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER AND SHRI MANISH

DCIT, CC-20, Delhi vs. Lotus Herbals Pvt. Ltd., Delhi

In the result, appeal of the Revenue in appeal No

ITA 2444/DEL/2023[2015-16]Status: DisposedITAT Delhi23 Dec 2025AY 2015-16

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER AND SHRI MANISH

DCIT, CC-20, Delhi vs. Lotus Herbals Pvt. Ltd., Delhi

In the result, appeal of the Revenue in appeal No

ITA 2443/DEL/2023[2014-15]Status: DisposedITAT Delhi23 Dec 2025AY 2014-15

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER AND SHRI MANISH

DCIT, CC-20, Delhi vs. Lotus Herbals Pvt. Ltd., Delhi

In the result, appeal of the Revenue in appeal No

ITA 2442/DEL/2023[2013-14]Status: DisposedITAT Delhi23 Dec 2025AY 2013-14

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER AND SHRI MANISH

DCIT, Central Circle-20, New Delhi vs. Lotus Herbals P.Ltd, Delhi

In the result, appeal of the Revenue in appeal No

ITA 200/DEL/2023[2019-20]Status: DisposedITAT Delhi23 Dec 2025AY 2019-20

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER AND SHRI MANISH