JSP PROJECTS (P) LTD,DELHI vs. DCIT CENTRAL CIRCLE - 13, DELHI

In the result appeal of the assessee in ITA number 3646/Del/2025 and

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

2) of the Income-tax Act, 1961, which was carried out by an incompetent authority, rendering the assessment without proper jurisdiction. Non-compliance with Section 65B of Indian Evidence Act 1872/section 63 of BSA 2023 7. That on the facts and in the circumstances of the case, the Ld. CIT(A) erred on fact and in law in sustaining

JSP PROJECTS (P) LTD,DELHI vs. DCIT CENTRAL CIRCLE -13, DELHI

In the result appeal of the assessee in ITA number 3646/Del/2025 and

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

2) of the Income-tax Act, 1961, which was carried out by an incompetent authority, rendering the assessment without proper jurisdiction. Non-compliance with Section 65B of Indian Evidence Act 1872/section 63 of BSA 2023 7. That on the facts and in the circumstances of the case, the Ld. CIT(A) erred on fact and in law in sustaining

JSP PROJECTS (P) LTD,DELHI vs. DCIT CENTRAL CIRCLE - 13, DELHI

In the result appeal of the assessee in ITA number 3646/Del/2025 and

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

2) of the Income-tax Act, 1961, which was carried out by an incompetent authority, rendering the assessment without proper jurisdiction. Non-compliance with Section 65B of Indian Evidence Act 1872/section 63 of BSA 2023 7. That on the facts and in the circumstances of the case, the Ld. CIT(A) erred on fact and in law in sustaining

GULSHAN HOMES AND INFRASTRUCTURE (P) LTD,NEW DELHI vs. DR. MANOJ KUMAR, DCIT, CENTRAL CIRCLE-31, NEW DELHI

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

2 of assessment\norder) as below in his satisfaction note:-\ni. Para 4- Upon this corelation, various individuals were found and traced on\nInsight portal and other Income Tax database.\nii. Para 5- Sita Gupta was found to have received interest from Gulshan\nHomes along with TDS......\niii. Para 8- From the TDS analysis above, it is clear that

KARINA AIRLINES INTERNATIONAL LIMITED,NEW DELHI vs. ACIT CIRCLE-05, NEW DELHI

In the result appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri K.Narasimha Charykarina Airlines Intenational Vs. Acit, Circle- 5Dcit Limited, No. 11, Gali No. 5, New Delhi. Block-A, West Karawal Nagar, New Delhi.

section 153C of the Act. In response to the same, the assessee furnished return of income vide letter dated 15/12/2019. Learned Assessing Officer made an addition of Rs. 32,91,052 on account of Receipt of foreign inward remittance, Rs. 2,50,000 on account of non-deduction of TDs

ADITI INFRABUILD AND SERVICES LTD.,DELHI vs. DCIT, CENTRAL CIRCLE-30, DELHI

In the result, appeal of the assessee is allowed

153C\nread with section 153Aof the Income Tax Act, 1961 in the ease of\nM/s. DEEPAK BULDERS & ENGINEERS INDIA PVT. LTD.\nA search n/s 132 of Income Tax Act was conducted on an Entry operator\nSanjay Jain along with his facilitators and some of his beneficiaries who\nwere found to be generating cash against bogus billing of cement and other

KUBER FOOD PRODUCTS INDIA P.LTD,NEW DELHI vs. ACIT, CENTRAL CIRCLE-30, NEW DELHI

In the result, both these appeals are partly allowed

Bench: Shri Kuldip Singh & Shri Prashant Maharishikuber Khanpan Udyog Pvt. Ltd, Vs. Acit, 1/8, West Patel Nagar, New Central Circle-30, Delhi New Delhi (Appellant) (Respondent) Kuber Food Products India Pvt. Vs. Acit, Ltd, Central Circle-30, C/O. Ravi Gupta, Advocate, E- New Delhi 6A, Kailash Colony, New Delhi (Appellant) (Respondent)

153C are non obstantive and will over ride the provisions of section 147. It is relevant to point out that this ground was very much raised before the CIT(A) see Page No17 of the CIT(A) order Para-4. However the CIT(A) has decided the issue subsilentio means without adjudicating the same Ground number-2 Page

KUBER KHANPAN UDYOG PVT. LTD.,DELHI vs. ACIT, CENTRAL CIRCLE- 30, NEW DELHI

In the result, both these appeals are partly allowed

Bench: Shri Kuldip Singh & Shri Prashant Maharishikuber Khanpan Udyog Pvt. Ltd, Vs. Acit, 1/8, West Patel Nagar, New Central Circle-30, Delhi New Delhi (Appellant) (Respondent) Kuber Food Products India Pvt. Vs. Acit, Ltd, Central Circle-30, C/O. Ravi Gupta, Advocate, E- New Delhi 6A, Kailash Colony, New Delhi (Appellant) (Respondent)

153C are non obstantive and will over ride the provisions of section 147. It is relevant to point out that this ground was very much raised before the CIT(A) see Page No17 of the CIT(A) order Para-4. However the CIT(A) has decided the issue subsilentio means without adjudicating the same Ground number-2 Page

GAUTAM CHOPRA,NEW DELHI vs. DCIT, JHANDEWALLAN EXTENSION

In the result, appeal of the assessee is allowed

153C\nproceedings herein reading as under:\n“Satisfaction Note for initiating proceedings under section\n153C read with section 153Aof the Income Tax Act, 1961 in\nthe ease of M/s. DEEPAK BULDERS & ENGINEERS INDIA PVT.\nLTD.\nA search n/s 132 of Income Tax Act was conducted on an Entry\noperator Sanjay Jain along with his facilitators and some of his\nbeneficiaries

MB POWER (MADHYA PRADESH) LIMITED ,SOUTH EAST DELHI vs. DCIT, CENTRAL CIRCLE-20, DELHI, DELHI

In the result, appeal of the Revenue is dismissed

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

section 153C of the Act, based on the loose sheets/diaries are contrary to law, which require to be set aside in these writ petitions, as the same are void and illegal.” Thus, legal position is settled that the satisfaction must be based on incriminating seized material and the same must pertain to the assessment year in question. The statements without

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-20, DELHI vs. M. B. POWER (MADHAYA PRADESH) LTD, DELHI

In the result, appeal of the Revenue is dismissed

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

section 153C of the Act, based on the loose sheets/diaries are contrary to law, which require to be set aside in these writ petitions, as the same are void and illegal.” Thus, legal position is settled that the satisfaction must be based on incriminating seized material and the same must pertain to the assessment year in question. The statements without

JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-20, DELHI vs. M B POWER (MADHYA PRADESH) LTD., DELHI

In the result, appeal of the Revenue is dismissed

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

section 153C of the Act, based on the loose sheets/diaries are contrary to law, which require to be set aside in these writ petitions, as the same are void and illegal.” Thus, legal position is settled that the satisfaction must be based on incriminating seized material and the same must pertain to the assessment year in question. The statements without

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 20, DELHI vs. M.B. POWER (MADHAYA PRADESH) LTD, DELHI

In the result, appeal of the Revenue is dismissed

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

section 153C of the Act, based on the loose sheets/diaries are contrary to law, which require to be set aside in these writ petitions, as the same are void and illegal.” Thus, legal position is settled that the satisfaction must be based on incriminating seized material and the same must pertain to the assessment year in question. The statements without

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-20, DELHI vs. MB POWER (MADHYA PRADESH) LIMITED, DELHI

In the result, appeal of the Revenue is dismissed

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

section 153C of the Act, based on the loose sheets/diaries are contrary to law, which require to be set aside in these writ petitions, as the same are void and illegal.” Thus, legal position is settled that the satisfaction must be based on incriminating seized material and the same must pertain to the assessment year in question. The statements without

MB POWER (MADHYA PRADESH) LIMITED,DELHI vs. DCIT, CENTRAL CIRCLE-20, DELHI

In the result, appeal of the Revenue is dismissed

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

section 153C of the Act, based on the loose sheets/diaries are contrary to law, which require to be set aside in these writ petitions, as the same are void and illegal.” Thus, legal position is settled that the satisfaction must be based on incriminating seized material and the same must pertain to the assessment year in question. The statements without

DCIT, GHAZIABAD vs. M/S. DEVIDAYAL ALUMINIUM INDUSTRIES PVT. LTD., GHAZIABAD

In the result, appeal of the Revenue is dismissed

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

section 153C of the Act, based on the loose sheets/diaries are contrary to law, which require to be set aside in these writ petitions, as the same are void and illegal.” Thus, legal position is settled that the satisfaction must be based on incriminating seized material and the same must pertain to the assessment year in question. The statements without

DY. COMMISSIONER OF INCOME TAX, NOIDA vs. M/S ACE MEGA STRUCTURE PRIVATE LIMITED, NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

TDS as per section 194I of the Act. However, the deal could be materialized and were got cancelled by the buyer M/s Hallow Securities Pvt. Ltd. and part of the advances were repaid also. All these agreements and cancelled agreement were found and seized during the course of search and are available in the paper book filed by the assessee

ACE MEGA STRUCTURES PRIVATE LIMITED,UTTAR PRADESH vs. DCIT/ACIT CEN CIR, NOIDA, NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

TDS as per section 194I of the Act. However, the deal could be materialized and were got cancelled by the buyer M/s Hallow Securities Pvt. Ltd. and part of the advances were repaid also. All these agreements and cancelled agreement were found and seized during the course of search and are available in the paper book filed by the assessee