INCOME TAX OFFICER, HISAR vs. AJAY KUMAR, HISAR

In the result, the appeal filed by the Revenue for AY 2022-23 is dismissed

TDS on freight payments. The assessee had provided documentary evidence for purchases, and the sales were accepted by the AO.", "held": "The Tribunal held that the non-response of third parties to notices issued under Section 133(6

ASSISTANT COMMISSIONER OF INCOME TAX, NEW DELHI vs. JAIPUR GOLDEN TRANSPORT CO PRIVATE LIMITED, NEW DELHI

In the result, appeal of the Revenue is partly allowed

Bench: Shri Anubhav Sharma& Shri Amitabh Shukla[Assessment Year:2012-13] Assistant Commissioner, Of Jaipur Golden Transport Co. Income Tax, Private Limited, Room No.316A, C.R. Vs 4741, Roshananra Road, Building, I.P Estate, Malkaganj, North Delhi, New New Delhi-110002 Delhi-110007 Pan Aaacj4124B Appellant Respondent Revenue By Shri Om Prakash, Sr. Dr Assessee By Shri Y.K. Mehan, Ca, Shri Dheeraj Kumar, Ca Date Of Hearing 11.12.2025 Date Of Pronouncement 19.12.2025

TDS which the appellant company has been regularly deducting on those payments. For reasons already given while disposing off Ground of Appeal No. 2, ad hoc additions cannot be upheld in law and neither can those additions be sustained which have been made merely because notices under section 133(6

ACIT, MEERUT vs. M/S. PIONEER FABRICATORS PVT. LTD., MEERUT

In the result ground No. 6 of the appeal of the assessee is allowed

Bench: Shri I.C.Sudhir & Shri Prashant Maharishiacit, Vs. Pioneer Fabricators Pvt. Ltd, Circle-2, Meerut B-2, Saraswati Industrial Estate, Partapur, Meerut Pan:Aabcp3296R (Appellant) (Respondent) Pioneer Fabricators Pvt. Ltd, Acit, Vs. B-2, Saraswati Industrial Estate, Circle-2, Meerut Pioneer Partapur, Meerut Fabricators Pvt. Ltd, Pan:Aabcp3296R B-2, Saraswati Industrial Estate, Partapur, Meerut Pan:Aabcp3296R (Appellant) (Respondent)

section 133 (6) of the income tax act. Many of such letters could not be served but no fault can be found of assessee in that when the address appearing in the bills are provided by the assessee. Furthermore, M/s Shiv Das and sons private limited as well as the Bengal rebates and bolts assessee has shown proper reconciliation, which

DCIT, CENTRAL CIRCLE-20, DELHI vs. LOTUS HERBALS PVT. LTD, DELHI

In the result, appeal of the Revenue in appeal No

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:

TDS is not deducted with reasons thereof” Vide reply dated 24.09.2015/ page 133 of the paper book], the assessee furnished before the assessing officer, copies of audited balance sheet and profit and loss account, tax audit report as well as income tax return and computation for the relevant assessment year. Vide reply dated 08.10.2015 [filed on 09.10.2015] @ pages

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

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:

TDS is not deducted with reasons thereof” Vide reply dated 24.09.2015/ page 133 of the paper book], the assessee furnished before the assessing officer, copies of audited balance sheet and profit and loss account, tax audit report as well as income tax return and computation for the relevant assessment year. Vide reply dated 08.10.2015 [filed on 09.10.2015] @ pages

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

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:

TDS is not deducted with reasons thereof” Vide reply dated 24.09.2015/ page 133 of the paper book], the assessee furnished before the assessing officer, copies of audited balance sheet and profit and loss account, tax audit report as well as income tax return and computation for the relevant assessment year. Vide reply dated 08.10.2015 [filed on 09.10.2015] @ pages

DCIT, CENTRAL CIRCLE-20, NEW DELHI vs. LOTUS HERBALS P.LTD, DELHI

In the result, appeal of the Revenue in appeal No

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:

TDS is not deducted with reasons thereof” Vide reply dated 24.09.2015/ page 133 of the paper book], the assessee furnished before the assessing officer, copies of audited balance sheet and profit and loss account, tax audit report as well as income tax return and computation for the relevant assessment year. Vide reply dated 08.10.2015 [filed on 09.10.2015] @ pages

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

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:

TDS is not deducted with reasons thereof” Vide reply dated 24.09.2015/ page 133 of the paper book], the assessee furnished before the assessing officer, copies of audited balance sheet and profit and loss account, tax audit report as well as income tax return and computation for the relevant assessment year. Vide reply dated 08.10.2015 [filed on 09.10.2015] @ pages

COSMIC INFORMATICS PVT. LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE - 2, NEW DELHI

In the result, appeal of the Revenue in appeal No

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:

TDS is not deducted with reasons thereof” Vide reply dated 24.09.2015/ page 133 of the paper book], the assessee furnished before the assessing officer, copies of audited balance sheet and profit and loss account, tax audit report as well as income tax return and computation for the relevant assessment year. Vide reply dated 08.10.2015 [filed on 09.10.2015] @ pages

COSMIC INFORMATICS PVT. LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE - 2, NEW DELHI

In the result, appeal of the Revenue in appeal No

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:

TDS is not deducted with reasons thereof” Vide reply dated 24.09.2015/ page 133 of the paper book], the assessee furnished before the assessing officer, copies of audited balance sheet and profit and loss account, tax audit report as well as income tax return and computation for the relevant assessment year. Vide reply dated 08.10.2015 [filed on 09.10.2015] @ pages

M/S R.K. JAIN INFRA PROJECTS P LTD,DELHI vs. PR COMMISSIONER OF INCOME TAX, DELHI-7, DELHI

The appeal of the assessee is allowed

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar(Through Video Conferencing)

Section 133(6) of the Act from these parties and in absence of such enquiry it cannot be said that the Assessing Officer has made any adequate and proper enquiry. Accordingly, he set aside the assessment order to make fresh assessment on this issue. 11. Before us, the ld. Counsel for the assessee referred to the various questionnaires and replies

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

133(6) or did not file their ITR, the same cannot be ground for drawing adverse inference in the case of the assessee. It is humbly submitted that it is not a case of receipt of any loan/ share capital/ gift or any other form of cash credit. It is a case, where the assessee has incurred expenses during

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

133(6) or did not file their ITR, the same cannot be ground for drawing adverse inference in the case of the assessee. It is humbly submitted that it is not a case of receipt of any loan/ share capital/ gift or any other form of cash credit. It is a case, where the assessee has incurred expenses during

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT CENTRAL CIRCLE -05 , DELHI

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

133(6) or did not file their ITR, the same cannot be ground for drawing adverse inference in the case of the assessee. It is humbly submitted that it is not a case of receipt of any loan/ share capital/ gift or any other form of cash credit. It is a case, where the assessee has incurred expenses during

DCIT, NEW DELHI vs. M/S. MICROMAX INFORMATICS LTD., GURGAON

The appeal of the Revenue is dismissed and that of the assessee is partly allowed

Bench: Shri I. C. Sudhir & Shri B. P. Jain

133(6), he was duly bound to take it to the logical end. He cannot shift the onus on the appellant when it had discharged its obligation. Further the appellant submitted the confirmation giving all the details. These details were sufficient to establish the identity of the share applicant and to conduct further enquiries. Moreover, the original assessment

M/S. MICROMAX INFORMATICS LTD.,NEW DELHI vs. DCIT, NEW DELHI

The appeal of the Revenue is dismissed and that of the assessee is partly allowed

Bench: Shri I. C. Sudhir & Shri B. P. Jain

133(6), he was duly bound to take it to the logical end. He cannot shift the onus on the appellant when it had discharged its obligation. Further the appellant submitted the confirmation giving all the details. These details were sufficient to establish the identity of the share applicant and to conduct further enquiries. Moreover, the original assessment

ACIT, NEW DELHI vs. M/S. VARUN BEVERAGES LTD., NEW DELHI

In the result, appeal filed by Revenue is dismissed

Bench: Shri H.S. Sidhu & Shri Anadee Nath Misshra

TDS has been made on such expenses as per the questionnaire dated 23.10.2013 The assessee was also requested to prove the Identity, genuineness and creditworthiness of parties along with their reconciliation in the books of accounts. In spite of hearing on various dates, the assessee could not furnish the said details. The assessee was requested to furnish the said details

ITO, NEW DELHI vs. SAHASRA ELECTRONICS (P) LTD., NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri Anil Chaturvedi & Ms. Astha Chandraassessment Year: 2006-07

133(6) of the Act could not be issued to foreign parties and that the assessee did not file copy of FIRC or Form No.2 which could have established payment details. The Ld. CIT(A) deleted the impugned addition. On consideration of the submission of the parties and perusal of the material on record, we do not find any reason