NATIONAL OILWELL VARCO PTE. LTD.,MUMBAI vs. DCIT (INTERNATIONAL TAXATION), CI9RCLE-2, DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

reassessment cannot be read into Section 144C more particularly when the provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the proceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels appearing for the respondent(s)/assessees that the outer time limit under Section

NATIONAL OILWELL VARCO PTE LTD.,MUMBAI vs. DCIT (INTERNATIONAL TAXATION), DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

reassessment cannot be read into Section 144C more particularly when the provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the proceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels appearing for the respondent(s)/assessees that the outer time limit under Section

NATIONAL OIL WELL VARCO PTE. LTD (FORMERLY KNOWN AS VARCO INTERNATIONAL PTE. LTD),MAHARASHTRA vs. THE DEPUTY DIRECTOR OF INCOME TAX CIRCLE-1( INTERNATIONAL TAXATION ), DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

reassessment cannot be read into Section 144C more particularly when the provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the proceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels appearing for the respondent(s)/assessees that the outer time limit under Section

SIME DARBY ENGINEERING SDN BHD,DELHI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRCLE-1, DEHRADUN

In the result, appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

reassessment cannot be read into Section 144C more particularly when the provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the proceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels appearing for the respondent(s)/assessees that the outer time limit under Section

SIME DARBY ENGINEERING SDN BHD,GURGAON vs. DCIT (INTERNATIONAL TAXATION), CIRCLE-2, DEHRADUN

In the result, appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

reassessment cannot be read into Section 144C more particularly when the provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the proceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels appearing for the respondent(s)/assessees that the outer time limit under Section

SIME DARBY ENGINEERING SDNBHD,MALAYSIA vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION ) CIRCLE-1, DEHRADUN

In the result, appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

reassessment cannot be read into Section 144C more particularly when the provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the proceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels appearing for the respondent(s)/assessees that the outer time limit under Section

BABU LAL PATWARI ,UTTARAKHAND vs. DCIT CIRCLE-2(1)(), UTTARAKHAND

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

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

reassessment notice. Section 151 of the new regime does not prescribe a time limit within which a specified authority has to grant sanction. Rather, it links up the time limits with the jurisdiction of the authority to grant sanction. Section 151(ii) of the new regime prescribes a higher level of authority if more than three years have elapsed from

SHRI VIBHU GROVER,KOTDWARA vs. PCIT, DEHRADUN

In the result appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalvibhu Grover, Pcit, M/S Grover Sales Corporation, Dehradun. Garage Road, Kotdwara, Vs. Pauri-246169 Pan:Agdpg5842R (Appellant) (Respondent) Assessee By Shri Anil Jain, Adv. Department By Shri S.K. Chaterjee, Cit-Dr

reassessment order under Section 148 read with Section 143(3) of the 1961 Act was passed. Addition was not made for the first reason. In the given facts, the assertion by the Revenue that inquiry and verification in re the bank account was not made is ex-facie incorrect. This being the position, this is not a case of failure

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), DEHRADUN, DEHRADUN vs. CHAKRATA FIRST AND ASSOCIATES, JAIPUR

Appeal is dismissed

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh(Through Video Conferencing) Assessment Year: 2017-18 Acit, Vs. Chakrata First & Circle-1(1)(1), Associates, C/O- Amit Tak 41 Dehradun Sanjay Marg, Hathori Fort, Jaipur, Rajasthan Pan: Aalfc2896B (Appellant) (Respondent) Assessee By Sh. S.K. Ahuja, Ar Department By Sh. Amar Pal Singh, Sr. Dr

section 145(3) to reassess it’s net profit “NP” @ 10% on turnover of Rs. 16,61,28,493/-; coming

MASCOT FASTNERS PRIVATE LIMITED,UTTARAKHAND vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI, -

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

Bench: Shri M. Balaganesh & Shri Satbeer Singh Godara(Through Video Conferencing) M/S. Mascot Fastners Pvt. Vs. National Faceless Ltd, Assessment Centre, Plot No. B-155, Eldeco, Sidcul, Delhi Industrial Park, Sitarganj, Udham Singh Nagar, 262 403 (Appellant) (Respondent) Pan: Aabcm4504H Assessee By : Shri Atul Ninawat, Partner Revenue By: Shri A. S. Rana, Sr. Dr Date Of Hearing 18/03/2025 Date Of Pronouncement 02/04/2025

28-3-2021. Further we find that the Learned AO had sought to reopen the assessment only on perusal of the assessment records. This itself goes to prove that there was absolutely no tangible material available with the Learned AO which would enable him to form a belief that income of the assessee had escaped assessment. The Learned

SHRI KRISHNA EDUCATIONAL TRUST,KURUKSHETRA vs. DCIT CENTRAL CIRCLE, DEHRADUN

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

28 draft assessment orders for 4 assessees were sent for approval by the Ld. AO in Dehradun to the Ld. Addl. CIT in Meerut on 30.03.2015 and the Ld. Addl. CIT had granted approval for all the cases on the very same day, i.e., on 30.03.2015. 8. The ld AR reiterated the fact that 95 draft assessment orders u/s 153A

SHRI KRISHNA EDUCATIONAL TRUST,KURUKSHETRA vs. DCIT CENTRAL CIRCLE, DEHRADUN

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

28 draft assessment orders for 4 assessees were sent for approval by the Ld. AO in Dehradun to the Ld. Addl. CIT in Meerut on 30.03.2015 and the Ld. Addl. CIT had granted approval for all the cases on the very same day, i.e., on 30.03.2015. 8. The ld AR reiterated the fact that 95 draft assessment orders u/s 153A

SHRI KRISHNA EDUCATIONAL TRUST,KURUKSHETRA vs. DCIT CENTRAL CIRCLE, DEHRADUN

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

28 draft assessment orders for 4 assessees were sent for approval by the Ld. AO in Dehradun to the Ld. Addl. CIT in Meerut on 30.03.2015 and the Ld. Addl. CIT had granted approval for all the cases on the very same day, i.e., on 30.03.2015. 8. The ld AR reiterated the fact that 95 draft assessment orders u/s 153A

SHRI KRISHNA EDUCATIONAL TRUST,KURUKSHETRA vs. DCIT CENTRAL CIRCLE, DEHRADUN

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

28 draft assessment orders for 4 assessees were sent for approval by the Ld. AO in Dehradun to the Ld. Addl. CIT in Meerut on 30.03.2015 and the Ld. Addl. CIT had granted approval for all the cases on the very same day, i.e., on 30.03.2015. 8. The ld AR reiterated the fact that 95 draft assessment orders u/s 153A

SHRI RAMESH BATTA,DEHRADUN vs. ACIT, DEHRADUN

In the result, appeal of the Assessee in both the cases are allowed and appeal filed by the Revenue in both the cases are dismissed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalacit, Shri Ramesh Batta Central Circle, 81/210, Kaulagarh Road, Vs. Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Shri Ramesh Batta Dy. Cit, 81/210, Kaulagarh Central Circle, Vs. Road, Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Acit, Shri Ramesh Batta, Central Circle, As Agent Of Smt. Kavita Vs. Dehradun. Ahuja, 81/210, Kaulagarh Road, Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent)

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the [Principal Commissioner or Commissioner] under sub-section (12) of Section 144-BA." 11. A plain reading of the aforesaid provision evinces an uncontrived position of law that the approval under Section 153D

SHRI RAMESH BATTA,DEHRADUN vs. ACIT, DEHRADUN

In the result, appeal of the Assessee in both the cases are allowed and appeal filed by the Revenue in both the cases are dismissed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalacit, Shri Ramesh Batta Central Circle, 81/210, Kaulagarh Road, Vs. Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Shri Ramesh Batta Dy. Cit, 81/210, Kaulagarh Central Circle, Vs. Road, Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Acit, Shri Ramesh Batta, Central Circle, As Agent Of Smt. Kavita Vs. Dehradun. Ahuja, 81/210, Kaulagarh Road, Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent)

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the [Principal Commissioner or Commissioner] under sub-section (12) of Section 144-BA." 11. A plain reading of the aforesaid provision evinces an uncontrived position of law that the approval under Section 153D

DCIT, DEHRADUN vs. SHRI RAMESH BATTA, DEHRADUN

In the result, appeal of the Assessee in both the cases are allowed and appeal filed by the Revenue in both the cases are dismissed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalacit, Shri Ramesh Batta Central Circle, 81/210, Kaulagarh Road, Vs. Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Shri Ramesh Batta Dy. Cit, 81/210, Kaulagarh Central Circle, Vs. Road, Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Acit, Shri Ramesh Batta, Central Circle, As Agent Of Smt. Kavita Vs. Dehradun. Ahuja, 81/210, Kaulagarh Road, Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent)

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the [Principal Commissioner or Commissioner] under sub-section (12) of Section 144-BA." 11. A plain reading of the aforesaid provision evinces an uncontrived position of law that the approval under Section 153D

DCIT, DEHRADUN vs. SH. RAMESH BATTA AS AGENT OF SMT. KAVITA AHUJA, DEHRADUN

In the result, appeal of the Assessee in both the cases are allowed and appeal filed by the Revenue in both the cases are dismissed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalacit, Shri Ramesh Batta Central Circle, 81/210, Kaulagarh Road, Vs. Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Shri Ramesh Batta Dy. Cit, 81/210, Kaulagarh Central Circle, Vs. Road, Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Acit, Shri Ramesh Batta, Central Circle, As Agent Of Smt. Kavita Vs. Dehradun. Ahuja, 81/210, Kaulagarh Road, Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent)

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the [Principal Commissioner or Commissioner] under sub-section (12) of Section 144-BA." 11. A plain reading of the aforesaid provision evinces an uncontrived position of law that the approval under Section 153D