VAKSONS METAPLAST PVT LTD,DELHI vs. PCIT(CENTRAL), DELHI

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

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

bogus transactions were held to be non-genuine, he observed that purchases should have been added back u/s 69C of the Act and taxed as per the provisions of Section 115BBE in the assessment order u/s 153C of the Act dated 21.03.2023. However, the AO had added back only 0.50% of the transaction value u/s

VAKSONS METAPLAST PVT LTD,DELHI vs. PCIT(CENTRAL), DELHI

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

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

bogus transactions were held to be non-genuine, he observed that purchases should have been added back u/s 69C of the Act and taxed as per the provisions of Section 115BBE in the assessment order u/s 153C of the Act dated 21.03.2023. However, the AO had added back only 0.50% of the transaction value u/s

CONE CRAFT PAPER PVT LTD,DELHI vs. PCIT-1, DELHI

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

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

revised return on 8th March, 2022 declaring total income of Rs. 82,84,260/- and the said return of income was processed by the CPC, Bangaluru, wherein notice u/s 143(2) of the Act dated 28.06.2022 was issued and thereafter notice u/s 142(1) of the Act dated 5th August, 2022 and 4th October, 2022 were issued but no reply

HALDIRAM SNACKS PRIVATE LIMITED,HARYANA vs. PCIT (CENTRAL), DELHI-3, NEW DELHI

In the result, appeal of the assessee is allowed

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2016-17] Haldiram Snacks Pvt. Ltd. Vs Pr. Cit (Central), Village- Kherki Daula, Delhi Delhi-3, Room No. Jaipur Highway Basai Road, 325, 3Rd Floor, Gurgaon, Haryana-122001. Jhandewalan Extn. Pan-Aaach0061R New Delhi-110055 Appellant Respondent Appellant By Shri Ajay Wadhwa, Adv., Shri Deepanshu Kaushik, Adv & Ms. Ragani Handa, Adv. Respondent By Ms. Sita Srivastava, Cit Dr Date Of Hearing 23.09.2025 Date Of Pronouncement 12.12.2025

bogus for which proceedings u/s 148 were initiated however, no enquiry or verification was made by the AO in the course of assessment proceedings u/s 153C though the AO was aware of this fact since the reassessment proceedings u/s 148 were initiated only for this issue. 4. After considering the submissions filed by assessee in this regard, PCIT vide impugned

SARENA PRIVATE LIMITED,DELHI vs. PCIT CENTRAL, DELHI-3, DELHI

Accordingly decided in favour of the assessee.\n\n13.\nConsequently the appeals succeed and same are allowed

bogus purchases, etc. A\nperusal of the same shows that after reproducing the whole of the content of the\nInvestigation Wing Report at page 135, it is mentioned that the assessee was\nfound to have received Rs.1,25,00,000/- from four different entities allegedly\ncontrolled by Shri Pradeep Kumar Jindal. It can be observed that by way of\nparas

SANDEEP KUMAR,NEW DELHI vs. ITO - WARD 1, PANIPAT, PANIPAT

In the result, appeal of the assessee is allowed

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2018-19] Sandeep Kumar, Vs Ito C/O-B-50, Lgf, South Ward-1 Extension Part-Ii, Panipat New Delhi -110049 Pan-Aueps5626A Appellant Respondent Appellant By Shri Shantanu Jain, Adv. Ms. Jahnavi Khanna, Adv. Shri Gurjeet Singh, Ca Respondent By Shri Khitesh Gupta, Sr.Dr Date Of Hearing 26.11.2025 Date Of Pronouncement 28.11.2025 Order

revised u/s 263 of the Act itself was invalid on various grounds and thus proceedings initiated u/s 263 of the Act against the invalid reassessment order is clearly bad in law. 6. That the appellant craves the leave to add, amend, modify, DLEETE any of the grounds of appeal before OR at the time of hearing and all the above

MANOJ KUMAR,PANIPAT vs. INCOME TAX OFFICER, WARD -1, PANIPAT, PANIPAT

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2018-19] Manoj Kumar Vs Ito Prop. Avitex India, Barsat Ward-1 Road, Opp.Kirpal Ashram, Panipat Panipat, Haryana-132103. Pan-Aaepo2553J Appellant Respondent Assessee By Shri Suresh Kumar Gupta, Ca Revenue By Ms. Amisha S.Gutpa, Cit Dr Date Of Hearing 27.11.2025 Date Of Pronouncement 29.01.2026 Order Per Manish Agarwal, Am : The Captioned Appeal Is Filed By Assessee Against The Order Dated 27.03.2025 Passed By Ld. Pr. Commissioner Of Income Tax, Rohtak [“Ld. Pr. Cit”] U/S 263 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 24.02.2023 Passed U/S 147 R.W.S. 144B Of The Act Pertaining To Assessment Year 2018-19. 2. Brief Facts Of The Case Are That The Assessee Filed His Return Of Income On 18.10.2018, Declaring Total Income Of Inr 5,12,820/-. Based On The Available That The Assessee Had Accepted Accommodation Entries In The Form Of Bogus Purchases From M/S. Soni Textiles Of Inr 11,47,500/-, Case Was Re-Opened By Issue Of Notice U/S 148 On 29.03.2022. In Response To The Notice, Assessee Filed Return Of Income On 25.11.2022, Declaring Total Income Of Inr 5,12,820/-. Thereafter, Various Notices Were Issued From Time To Time However, Were Remained Uncompiled With. Thereafter, Ao Vide Order Dated 24.02.2023 Passed U/S 147 R.W.S. 144B Of The Act Assessed The Income Of The Assessee At Inr 16,60,320/- By Making Addition Of Alleged Bogus Purchases.

bogus purchases. 3. Thereafter, ld. PCIT has initiated the revision proceedings u/s 263 of the Act vide issue of show

ALKA AGARWAL,DELHI vs. PCIT(CENTRAL)-3, DELHI

In the result, appeal of the assessee is allowed

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2015-16] Alka Agarwal Vs Pr. Cit (Central), 56, Sfs Flats, Ashok Vihar, Delhi-3 Phase-Iv, Delhi-110052. Pan-Aajpa1281C Appellant Respondent Appellant By Shri Sumit Lalchandani, Adv. & Shri Shivam Yadav, Adv. Respondent By Ms. Sita Srivastava, Cit Dr Date Of Hearing 23.09.2025 Date Of Pronouncement 12.12.2025

bogus LTCG. Besides, an addition of INR 3,66,59,000/- was made towards cash payment in purchase of the properties u/s 69A of the Act and further addition of commission income of INR 74,45,917/- was made. 3. Against the said order, an appeal is filed by the assessee before Ld. CIT(A) which was decided in terms

ASHOK KUMAR JAIN,DELHI vs. PR, CIT 20, NEW DELHI

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year : 2018-19 Ashok Kumar Jain, Vs. Pr. Cit-20, C/O Kapil Goel, Advocate, New Delhi. F-26/124, Sector-7, Rohini, Delhi – 110 085. Pan: Aakpj1872B

bogus purchase as unexplained expenditure u/s 69C to the returned income. 3. On the aforesaid reasons, the assessee was show caused u/s 263 of the Act and, thereafter, the impugned order dated 29.03.2025 was passed for which the assessee is in appeal and now, before us, the assessee is not merely challenging the impugned order u/s 263

JOGINDER KUMAR & SONS HUF,PANIPAT vs. PCIT ROTAK, ROTAK

In the result, the appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwaljoginder Kumar & Sons Huf Pcit, 352/6, Near S D Modern School, Rohtak. Panipat-132103. Vs. Pan- Aachj6257L (Appellant) (Respondent) Assessee By Shri Dhurv Goel, Ca Department By Shri Pradumna Kumar Singh, Sr. Dr Date Of Hearing 04.09.2025 Date Of Pronouncement 27.11.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of The Ld. Principal Commissioner Of Income Tax, Rohtak (‘The Pcit’ In Short) Passed U/S 263 Of The Income Tax Act, 1961 Dated 21.03.2025 Wherein The Ld. Pcit Held The Assessment Order As Erroneous & Prejudicial To The Interest Of The Revenue In Terms Of Explanation 2 Of Section 263 & Direct The Ao To Conduct Fresh Enquiries & Passed The Speaking Order.

bogus purchase. The Ld. PCIT in terms of the show cause notice dated 29.07.2024, based on the audit objection by the ITO, issued the show cause notice which reads as under: NOTICE FOR THE HEARING M/s/Mr/Ms Subject: Notice for Hearing in respect of Revision proceedings u/s 263

SANJAY SINGH RANA,DELHI vs. PCIT, DELHI-20, DELHI

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

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

revised u/s 263 of the Act by the PCIT, Delhi-20 wherein she held that the assessment made is erroneous and prejudicial to the interest of the Revenue in so far as the AO, on the one hand held that the entire transaction of purchase/sale of share is bogus and yet he allowed the benefit of cost of purchase

NARENDRA AGGARWAL,NEW DELHI vs. PR. CIT- 7, DELHI

In the result, appeal of the assessee is allowed

Bench: Sh. Anil Chaturvedi & Sh. Kuldip Singh

263 of the Act was liable to be quashed in the absence of material indicated therein. He thereafter submitted that in the case of CIT vs. G. K. Kabra 211 ITR 336, 339-341 (AP) it has been held that it is necessary for CIT to point out the exact error in the order which he proposed to revise

AXIS INFOLINE P LTD,DELHI vs. PCIT-1, DELHI

In the result, appeal of the assessee is allowed

Bench: Shri Mahavir Singh, Hon’Ble & Shri Sanjay Awasthiआ.अ.सं/.I.T.A No.2613/Del/2025 िनधा"रणवष"/Assessment Year: 2021-22 बनाम Axis Infoline P. Ltd., Principal Commissioner Of Income 196/16B, 2Nd Floor, Vs. Tax, Ramesh Market, East Of Kailash, Income Tax Office, Delhi-1. Nehru Nagar, South Delhi. Delhi. Pan No.Aadca9862C अपीलाथ" Appellant ""यथ"/Respondent

u/s 263 of the Act. The Ld. PCIT based himself on the judgments in the case of N.K. Proteins of the Hon’ble Gujarat High Court, the SLP againstwhich was dismissed by the Hon’ble Supreme Court [84 taxmann.com 195 (SC)]. Ld. PCIT has also relied on the case of Kanak Impex reported

SARENA PRIVATE LIMITED,DELHI vs. PR,CIT CENTRE DELHI-3, DELHI

Accordingly, ground no.1 raised by\nthe Revenue is dismissed

bogus purchases, etc. A\nperusal of the same shows that after reproducing the whole of the content of the\nInvestigation Wing Report at page 135, it is mentioned that the assessee was\nfound to have received Rs.1,25,00,000/- from four different entities allegedly\ncontrolled by Shri Pradeep Kumar Jindal. It can be observed that by way of\nparas

MANMOHAN SINGH SEHGAL,DELHI vs. PR, CIT DELHI -10, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Sh. C. M. Gargdr. B. R. R. Kumarita No. 791/Del/2021 : Asstt. Year : 2011-12 Manmohan Singh Sehgal, Vs Pcit, C/O Ajay Arun Mehta & Associates, Delhi-10, Chartered Accountants, Shop No. 25, Dda Market, B Block, Preet Vihar, Delhi-110092 (Appellant) (Respondent) Pan No. Abaps6153M Assessee By : Sh. C. S. Anand, Adv. Revenue By : Sh. Subhra J. Chakraborty, Cit-Dr Date Of Hearing: 20.07.2023 Date Of Pronouncement: 14.09.2023 Order Per Dr. B. R. R. Kumar:

bogus purchases could had been made. 9. That the learned PCIT Delhi-10 had failed to appreciate that during the first round of assessment proceedings (which travelled upto ITAT), the sources of the funds were thoroughly examined.” 3 Manmohan Singh Sehgal 3. The pertinent facts of the appeal are as under:  Assessment u/s 143(3) has been completed

VANDANA JAIN,SONIPAT vs. PCIT(CENTRAL)-1, DELHI

In the result, appeals of the Assessee are allowed

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.2341 To 2343/Del/2025 िनधा"रणवष"/Assessment Years: 2017-18 To 2019-20 बनाम Vandana Jain Pcit (Central), Veersons Building, Gohana Road, Vs. Delhi-1. Fazilpur B.O. Barwasni (202), Sonipat, Haryana, India. Pan No.Aampj6134E अपीलाथ" Appellant ""यथ"/Respondent

bogus purchases also, enhancement will lead to double taxation of the same income. 6. (i) On the facts and circumstances of the case, the Ld. PCIT has erred both on facts and in law in directing the Assessing Officer to re-compute the interest u/s 234A of the Act. (ii) That the re-computation of interest u/s 234A

VANDANA JAIN,SONIPAT vs. PCIT(CENTRAL)-1, DELHI

In the result, appeals of the Assessee are allowed

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.2341 To 2343/Del/2025 िनधा"रणवष"/Assessment Years: 2017-18 To 2019-20 बनाम Vandana Jain Pcit (Central), Veersons Building, Gohana Road, Vs. Delhi-1. Fazilpur B.O. Barwasni (202), Sonipat, Haryana, India. Pan No.Aampj6134E अपीलाथ" Appellant ""यथ"/Respondent

bogus purchases also, enhancement will lead to double taxation of the same income. 6. (i) On the facts and circumstances of the case, the Ld. PCIT has erred both on facts and in law in directing the Assessing Officer to re-compute the interest u/s 234A of the Act. (ii) That the re-computation of interest u/s 234A

VANDANA JAIN,SONIPAT vs. PCIT(CENTRAL)-1, DELHI

In the result, appeals of the Assessee are allowed

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.2341 To 2343/Del/2025 िनधा"रणवष"/Assessment Years: 2017-18 To 2019-20 बनाम Vandana Jain Pcit (Central), Veersons Building, Gohana Road, Vs. Delhi-1. Fazilpur B.O. Barwasni (202), Sonipat, Haryana, India. Pan No.Aampj6134E अपीलाथ" Appellant ""यथ"/Respondent

bogus purchases also, enhancement will lead to double taxation of the same income. 6. (i) On the facts and circumstances of the case, the Ld. PCIT has erred both on facts and in law in directing the Assessing Officer to re-compute the interest u/s 234A of the Act. (ii) That the re-computation of interest u/s 234A