DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. HOMELIFE BUILDCON PVT. LTD., LUDHIANA

In the result, Revenue appeal is dismissed and appeal filed by the assessee is allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 880/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 Homelife Buildcon Private Limited Sunview Enclave, Ayali Kalan, Ludhiana, Punjab-142027 स्थायी लेखा सं./PAN NO: AABCH5690M अपीलार्थी/Appellant The DCIT Central Circle-1 Ludhiana, Punjab प्रत्यर्थी/Respondent आयकर अपील सं. / ITA No. 1036/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 Homelife Buildcon Private Limited Sunview Enclave, Ayali Kalan, Lu

147 would defeat the very purpose of the amendment and open the floodgates to arbitrary assessments. 26. The relevant extract Memorandum explaining the finance bill is reproduced as under:- ‘(ii) Assessments or reassessments or in re-computation in cases where search is initiated under section 132 or requisition is made under 132A, after 31st March 2021, shall be under

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2 LUDHIANA, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED , DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

reassessment order, as the case may be, is required to be passed by the\nAssessing Officer with the prior approval of the Principal Commissioner or\nCommissioner under sub-section (12) of section 144BA”\n10. In view of the above provision, the ld. Counsel for the Assessee stated that the\nCIT(A) has explained the procedure contained in Instruction No. F.No

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA , LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

reassessment order, as the case may be, is required to be passed by the\nAssessing Officer with the prior approval of the Principal Commissioner or\nCommissioner under sub-section (12) of section 144BA”\n10. In view of the above provision, the ld. Counsel for the Assessee stated that the\nCIT(A) has explained the procedure contained in Instruction No. F.No

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

reassessment order, as the case may be, is required to be passed by the\nAssessing Officer with the prior approval of the Principal Commissioner or\nCommissioner under sub-section (12) of section 144BA”\n10. In view of the above provision, the ld. Counsel for the Assessee stated that the\nCIT(A) has explained the procedure contained in Instruction No. F.No

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

reassessment order, as the case may be, is required to be passed by the\nAssessing Officer with the prior approval of the Principal Commissioner or\nCommissioner under sub-section (12) of section 144BA”\n10. In view of the above provision, the ld. Counsel for the Assessee stated that the\nCIT(A) has explained the procedure contained in Instruction No. F.No

M/S GENIUS EDUCATION SOCIETY,MANDI vs. ACIT, C-2, (E), CHANDIGARH

In the result, the appeal of the assessee is allowed in

Bench: Shri Sanjay Garg & Ms. Annapurna Guptam/S Genius Education Society, Vs. The A.C.I.T., Tanda Balt, Sadar, Mandi, Circle-2(Exemptions), Himachal Pradesh. Chandigarh. Pan: Aaajg1473H (Appellant) (Respondent)

reassessment framed u/s 147-148 itself is illegal, without proper sanction, void ab initio and without jurisdiction. 6. That the appellant craves leave to add or amend the ground of appeal before the appeal is finally heard and disposed off.” 3. Briefly facts relating to the case are that the assessee had applied for registration u/s10

MANDEEP KAUR,FATEHABAD vs. ITO, WARD - 1, FATEHABAD

The appeal stand allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.630/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2016-17) Ms. Mandeep Kaur Ito Ward -1 बनाम/ Vs. Vpo Museh Ali Hizrawan, Khurd, To Fatehabad Rohtak - 124001 Fatehabad, Haryana – 125050 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Datpk-9813-D (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Mukesh Kumar Jain (Ca) – Ld. Ar (Virtual) ""थ"कीओरसे/Respondent By : Sh. Dr. Ranjit Kaur (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 10.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 16.02.2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2016- 17 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Nfac [Cit(A)] Dated 17-02-2025 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S 147 R.W.S. 144Of The Act On30-04-2023. 2. The Ld. Ar, At The Outset, Urged Legal Ground No.4 To Assail The Jurisdiction Of Ld. Ao. In This Ground Of Appeal, It Has Been Pleaded That The Order Passed U/S 148A(D) As Well As Issue Of Notice U/S 148

147 r.w.s. 144of the Act on30-04-2023. 2. The Ld. AR, at the outset, urged legal ground no.4 to assail the jurisdiction of Ld. AO. In this ground of appeal, it has been pleaded that the order passed u/s 148A(d) as well as issue of notice u/s 148 2 Assessment Year: 2016-17 was without jurisdiction which make

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

160 Taxman 233 (Alld) • Kishanlal Agarwalla Vs. Collector of Land Customs (AIR 1967 Cal. 80) • Satellite Engineering Ltd. Vs. Union of India & Ors. (1983 ELT 2177 Bom) • Kanungo & Co. Vs. Collector of Central Excise (1983 ELT 1486 SC) • Union of India & Anr. Vs. Tulsiram Patel (AIR 85 SC 1416) • DCW Ltd. Vs. Collector of Central Excise • GTC Industries

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

160 Taxman 233 (Alld) • Kishanlal Agarwalla Vs. Collector of Land Customs (AIR 1967 Cal. 80) • Satellite Engineering Ltd. Vs. Union of India & Ors. (1983 ELT 2177 Bom) • Kanungo & Co. Vs. Collector of Central Excise (1983 ELT 1486 SC) • Union of India & Anr. Vs. Tulsiram Patel (AIR 85 SC 1416) • DCW Ltd. Vs. Collector of Central Excise • GTC Industries

SH. SANJAY SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

160 Taxman 233 (Alld) • Kishanlal Agarwalla Vs. Collector of Land Customs (AIR 1967 Cal. 80) • Satellite Engineering Ltd. Vs. Union of India & Ors. (1983 ELT 2177 Bom) • Kanungo & Co. Vs. Collector of Central Excise (1983 ELT 1486 SC) • Union of India & Anr. Vs. Tulsiram Patel (AIR 85 SC 1416) • DCW Ltd. Vs. Collector of Central Excise • GTC Industries

SH. SANJAY SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

160 Taxman 233 (Alld) • Kishanlal Agarwalla Vs. Collector of Land Customs (AIR 1967 Cal. 80) • Satellite Engineering Ltd. Vs. Union of India & Ors. (1983 ELT 2177 Bom) • Kanungo & Co. Vs. Collector of Central Excise (1983 ELT 1486 SC) • Union of India & Anr. Vs. Tulsiram Patel (AIR 85 SC 1416) • DCW Ltd. Vs. Collector of Central Excise • GTC Industries

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

160 Taxman 233 (Alld) • Kishanlal Agarwalla Vs. Collector of Land Customs (AIR 1967 Cal. 80) • Satellite Engineering Ltd. Vs. Union of India & Ors. (1983 ELT 2177 Bom) • Kanungo & Co. Vs. Collector of Central Excise (1983 ELT 1486 SC) • Union of India & Anr. Vs. Tulsiram Patel (AIR 85 SC 1416) • DCW Ltd. Vs. Collector of Central Excise • GTC Industries

SH. SANJAY SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

160 Taxman 233 (Alld) • Kishanlal Agarwalla Vs. Collector of Land Customs (AIR 1967 Cal. 80) • Satellite Engineering Ltd. Vs. Union of India & Ors. (1983 ELT 2177 Bom) • Kanungo & Co. Vs. Collector of Central Excise (1983 ELT 1486 SC) • Union of India & Anr. Vs. Tulsiram Patel (AIR 85 SC 1416) • DCW Ltd. Vs. Collector of Central Excise • GTC Industries

SH. RANDHIR SINGH,SIRSA vs. PCIT ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

reassessment proceedings against the assessee is found to be invalid, bad in law, arbitrary and illegal, having no legal foundation and thus quashed. Ordered accordingly.” vii) 205 ITD 31 (Mum) Reuters Asia Pacific Ltd. v. DCIT viii) dated 3.7.2025 J Kumar Infraprojects Ltd. vs. DCIT 13. The requirement of signature on the notice or document issued is not merely formality

DHUNI CHAND HUF,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

reassessment proceedings against the assessee is found to be invalid, bad in law, arbitrary and illegal, having no legal foundation and thus quashed. Ordered accordingly.” vii) 205 ITD 31 (Mum) Reuters Asia Pacific Ltd. v. DCIT viii) dated 3.7.2025 J Kumar Infraprojects Ltd. vs. DCIT 13. The requirement of signature on the notice or document issued is not merely formality

SH. KASHMIR SINGH SANDHA,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

reassessment proceedings against the assessee is found to be invalid, bad in law, arbitrary and illegal, having no legal foundation and thus quashed. Ordered accordingly.” vii) 205 ITD 31 (Mum) Reuters Asia Pacific Ltd. v. DCIT viii) dated 3.7.2025 J Kumar Infraprojects Ltd. vs. DCIT 13. The requirement of signature on the notice or document issued is not merely formality

SH. ARVAIL SINGH,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

reassessment proceedings against the assessee is found to be invalid, bad in law, arbitrary and illegal, having no legal foundation and thus quashed. Ordered accordingly.” vii) 205 ITD 31 (Mum) Reuters Asia Pacific Ltd. v. DCIT viii) dated 3.7.2025 J Kumar Infraprojects Ltd. vs. DCIT 13. The requirement of signature on the notice or document issued is not merely formality

SH. PARAMJEET SINGH,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

reassessment proceedings against the assessee is found to be invalid, bad in law, arbitrary and illegal, having no legal foundation and thus quashed. Ordered accordingly.” vii) 205 ITD 31 (Mum) Reuters Asia Pacific Ltd. v. DCIT viii) dated 3.7.2025 J Kumar Infraprojects Ltd. vs. DCIT 13. The requirement of signature on the notice or document issued is not merely formality

SURJEET SINGH,SIRSA vs. PCIT, ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

reassessment proceedings against the assessee is found to be invalid, bad in law, arbitrary and illegal, having no legal foundation and thus quashed. Ordered accordingly.” vii) 205 ITD 31 (Mum) Reuters Asia Pacific Ltd. v. DCIT viii) dated 3.7.2025 J Kumar Infraprojects Ltd. vs. DCIT 13. The requirement of signature on the notice or document issued is not merely formality