JAKSON LIMITED,DELHI vs. DCIT, CC-4, DELHI

In the result, the appeal of the assessee is allowed and both the appeals of revenue are dismissed

Bench: Ms. Madhumita Roy & Mrs. Renu Jauhri

151 is mechanical approval as the same has been granted by PCIT/CIT instead of PCCIT/PDGIT/ CCIT/ DGIT. (e) That on the facts and in the circumstances of the case, the initiation of reassessment proceedings is not valid and void ab initio as the same is time barred in accordance with the latest judgement of Hon'ble Apex Court issued

ACIT, NEW DELHI vs. JAKSON LIMITED, DELHI

In the result, the appeal of the assessee is allowed and both the appeals of revenue are dismissed

Bench: Ms. Madhumita Roy & Mrs. Renu Jauhri

151 is mechanical approval as the same has been granted by PCIT/CIT instead of PCCIT/PDGIT/ CCIT/ DGIT. (e) That on the facts and in the circumstances of the case, the initiation of reassessment proceedings is not valid and void ab initio as the same is time barred in accordance with the latest judgement of Hon'ble Apex Court issued

CRICKET SOUTH AFRICA (NPC),SOUTH AFRICA vs. ACIT, CIRCLE 1(2)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, appeal is allowed as indicated above

Bench: Shri Saktijit Dey, Vice- & Dr. B.R.R. Kumarassessment Year: 2013-14

TDS returns filed by them.” [Emphasis by us] 12. Thus, facts on record clearly reveal that the Assessing Officer has reopened the assessment under Section 147 of the Act on complete non- application of mind. Unfortunately, the higher authorities while granting approval under Section 151

CRICKET AUSTRALIA,AUSTRALIA vs. DCIT, INT, TAXATION CIRCLE-1(2)(1), NEW DELHI

In the result, appeal is allowed as indicated above

Bench: Shri Saktijit Dey, Vice- & Dr. B.R.R. Kumarassessment Year: 2013-14

TDS returns filed by them.” [Emphasis by us] 11. Thus, facts on record clearly reveal that the Assessing Officer has reopened the assessment under Section 147 of the Act with complete non-application of mind. Unfortunately, the higher authorities while granting approval under Section 151

DHARAMVIR KHOSLA ,. vs. DCIT CC-5, NEW DELHI , .

The appeals are allowed for statistical purposes and ld

TDS deducted from the amount paid/credited by various\nparties i.e. at S.No.4 Corp Code India Infra Limited Rs.11,185/- was not\ndeposited. Magical Building Solution Pvt. Ltd. Rs.15,658/- was not deposited,\nMVS Gymkhana Limited has not deposited Rs.4,350/-, Royal Golf Link City\nProjects Private Limited has not deposited Rs.8,51,251/- and Shipra Estate\nLimited and Jaikishan

KGL NETWORK (P) LTD.,DELHI vs. ACIT, CIRCLE- 14(2), NEW DELHI

Bench: Shri Bhavnesh Saini & Shri L.P. Sahu

section 133(6) from ITO, TDS, Ward- (International Taxation), Dated 17.02.2010 along with submissions of the assessee-company and details, in which, the assessee-company similarly explained that assessee-company handled Cargo imported by Indian manufacturer, for which, freight is paid and assessee-company is not liable to deduct TDS. No action have been taken by the Department against

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:

151 of the Act for initiation of reassessment proceedings accorded in a mechanical manner. The aforesaid contentions are elaborated hereunder: Re (a): Reassessment proceedings barred as per provisions to section 147- No failure on part of the assessee to fully and truly disclose material facts In terms of proviso to section 147 of the Act, the assessing officer can initiate

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:

151 of the Act for initiation of reassessment proceedings accorded in a mechanical manner. The aforesaid contentions are elaborated hereunder: Re (a): Reassessment proceedings barred as per provisions to section 147- No failure on part of the assessee to fully and truly disclose material facts In terms of proviso to section 147 of the Act, the assessing officer can initiate

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:

151 of the Act for initiation of reassessment proceedings accorded in a mechanical manner. The aforesaid contentions are elaborated hereunder: Re (a): Reassessment proceedings barred as per provisions to section 147- No failure on part of the assessee to fully and truly disclose material facts In terms of proviso to section 147 of the Act, the assessing officer can initiate

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:

151 of the Act for initiation of reassessment proceedings accorded in a mechanical manner. The aforesaid contentions are elaborated hereunder: Re (a): Reassessment proceedings barred as per provisions to section 147- No failure on part of the assessee to fully and truly disclose material facts In terms of proviso to section 147 of the Act, the assessing officer can initiate

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:

151 of the Act for initiation of reassessment proceedings accorded in a mechanical manner. The aforesaid contentions are elaborated hereunder: Re (a): Reassessment proceedings barred as per provisions to section 147- No failure on part of the assessee to fully and truly disclose material facts In terms of proviso to section 147 of the Act, the assessing officer can initiate

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:

151 of the Act for initiation of reassessment proceedings accorded in a mechanical manner. The aforesaid contentions are elaborated hereunder: Re (a): Reassessment proceedings barred as per provisions to section 147- No failure on part of the assessee to fully and truly disclose material facts In terms of proviso to section 147 of the Act, the assessing officer can initiate

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:

151 of the Act for initiation of reassessment proceedings accorded in a mechanical manner. The aforesaid contentions are elaborated hereunder: Re (a): Reassessment proceedings barred as per provisions to section 147- No failure on part of the assessee to fully and truly disclose material facts In terms of proviso to section 147 of the Act, the assessing officer can initiate

ACIT, CENTRAL CIRCLE- 30, NEW DELHI vs. PRAKASH INDUSTRIES LTD., HISAR

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

Section 153 C of the Act but in relation to Section 153A of the Act as well.Consequently, this Court does not find any error having been committed by the ITAT in accepting the plea of the Assessee that there is no 64 I.T.As. No.4039, 4040, 4041, 4042, 4043, 4064, 4065, 4066, 4067, 4068, 4069, 4070/DEL/2017 incriminating document which was seized

ACIT, CENTRAL CIRCLE- 30, NEW DELHI vs. PARKASH INDUSTRIES LTD, HISAR

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

Section 153 C of the Act but in relation to Section 153A of the Act as well.Consequently, this Court does not find any error having been committed by the ITAT in accepting the plea of the Assessee that there is no 64 I.T.As. No.4039, 4040, 4041, 4042, 4043, 4064, 4065, 4066, 4067, 4068, 4069, 4070/DEL/2017 incriminating document which was seized

PRAKASH INDUSTRIES LTD.,NEW DELHI vs. ACIT, CC- 30,, NEW DELHI

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

Section 153 C of the Act but in relation to Section 153A of the Act as well.Consequently, this Court does not find any error having been committed by the ITAT in accepting the plea of the Assessee that there is no 64 I.T.As. No.4039, 4040, 4041, 4042, 4043, 4064, 4065, 4066, 4067, 4068, 4069, 4070/DEL/2017 incriminating document which was seized

ACIT, CENTRAL CIRCLE- 30, NEW DELHI vs. PRAKASH INDUSTRIES LTD., HISAR

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

Section 153 C of the Act but in relation to Section 153A of the Act as well.Consequently, this Court does not find any error having been committed by the ITAT in accepting the plea of the Assessee that there is no 64 I.T.As. No.4039, 4040, 4041, 4042, 4043, 4064, 4065, 4066, 4067, 4068, 4069, 4070/DEL/2017 incriminating document which was seized

ACIT, CENTRAL CIRCLE- 30, NEW DELHI vs. PARKASH INDUSTRIES LTD, HISAR

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

Section 153 C of the Act but in relation to Section 153A of the Act as well.Consequently, this Court does not find any error having been committed by the ITAT in accepting the plea of the Assessee that there is no 64 I.T.As. No.4039, 4040, 4041, 4042, 4043, 4064, 4065, 4066, 4067, 4068, 4069, 4070/DEL/2017 incriminating document which was seized

ACIT, CENTRAL CIRCLE- 30, NEW DELHI vs. PARKASH INDUSTRIES LTD, HISAR

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

Section 153 C of the Act but in relation to Section 153A of the Act as well.Consequently, this Court does not find any error having been committed by the ITAT in accepting the plea of the Assessee that there is no 64 I.T.As. No.4039, 4040, 4041, 4042, 4043, 4064, 4065, 4066, 4067, 4068, 4069, 4070/DEL/2017 incriminating document which was seized