ASSISTANT COMMISSIONER OF INCOME TAX, DELHI vs. THE INDURE PRIVATE LIMITED, DELHI

In the result, the appeal filed by the Department of Revenue is dismissed

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2013-14 Assistant Commissioner Of Vs. The Indure Private Limited, Income Tax, Indure House, Greater Kailash Part Ii, Delhi South Delhi 1100 48 Pan :Aaact0121C (Appellant) (Respondent)

148A(d) and notice under Section 148 of the Act dated 28.07.2022 were issued. Notices under Section 143(2) of the Act copies under Section 142(1) of the Act as well as show-cause- notice were issued. The assessee filed reply. Notices under Section 142(1) dated 27.12.2022 and 11.02.2023 were issued asking various details. The assessee filed part

INCOME TAX OFFICER, WARD 46(1), NEW DELHI, NEW DELHI vs. MAM RAJ CHUNNI LAL EXIM, NEW DELHI

In the result the appeal of the Revenue is dismissed and the cross objection of the assessee is partly allowed

Bench: Sh. Sudhir Kumar & Sh. Manish Agarwalassessment Year: 2016-17 Income Tax Officer, Vs Mam Raj Chunni Lal Exim Ward- 46 (1) Shop No. 5183, Ground New Delhi Floor, Lahori Gate, Naya Bazar, Delhi -110006 Pan No.Aaxfm0533B (Appellant) (Respondent)

148A(d) of the Act after the due approval. According to AO the assessee had claimed bogus purchases from M/s Parth International and declared bogus sales to M/s Gunn Enterprises. The Ld. assessing Officer made the addition of Rs.1,44,15,042/- on account of bogus purchases and Rs.44,66,376/- on account of unexplained credit

INCOME TAX OFFICER, ROHTAK vs. PANKAJ JAIN, ROHTAK

In the result, the appeal filed by the Revenue is dismissed

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmaincome Tax Officer, Vs. Pankaj Jain, Rohtak. 123/34, Vishwakarma Kathmandi, Rohtak – 124 001 (Haryana). (Pan : Azupj6345A) (Appellant) (Respondent) Assessee By : Shri Shri Naveen Gupta, Advocate Shri Nakul Gupta, Advocate Revenue By : Shri Ajay Kumar Arora,Sr. Dr Date Of Hearing : 06.11.2025 Date Of Order : 30.12.2025 Order Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Cit(A)”, For Short] Dated 04.02.2025 For The Assessment Year 2018-19 Raising Following Grounds Of Appeal :- “1. The Learned Cit(A) Has Erred In Law & On Facts In Not Upholding The Validity Of The Notice Issued Under Section 148 Of The Income Tax Act, 1961 (The Act) Without The Proper & Mandatory Compliance With The Provisions Of Section 148A(B). 2. The Learned Cit(A) Has Further Erred In Law & On Facts By Failing To Consider That The Then Ao Has Given Notice U/S 148A(B) To Assessee On 31.03.2022

bogus purchase and disallowed the same u/s 37(1) of the Act. The AO completed the assessment u/s 147 r.w.s 144B of the Act on 25.03.2024 by assessing the total income at Rs.5,41,69,809/-. 4. Aggrieved with the above order, assessee preferred an appeal before the NFAC, Delhi and filed grounds of appeal and detailed submissions. Before

HARISH NARANG,PANIPAT vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, ROHTAK, ROHTAK

In the result, the appeal of the assessee is dismissed

Bench: Shri Anubhav Sharma& Shri Amitabh Shukla[Assessment Year: 2018-19] Harish Narang, The Principal Commissioner Of H. No.238, Ward No.8, Income Tax, Rohtak, Panipat, Haryana-132103 Vs Aayakar Bhawan, Opp. Mansarover Park, Rohtak, Haryana-124001 Pan:Acvpn4090J Appellant Respondent Assessee By Shri Amit Kaushik, Adv. Revenue By Ms. Amisha S. Gupt, Cit(Dr) Date Of Hearing 16.10.2025 Date Of Pronouncement 31.12.2025

148A(d), of the impugned entities from whom purchases were allegedly made by the assessee were bogus entities and mere paper concerns created to provide accommodation entries, are correct. It has been noted that the ld. AO conducted pain staking minute enquiries to identify serious anomalies, deficiencies in the invoices of Shri Balaji Wooltex and Shri Rameshwaram International (supra

HONEYWELL EXIM PRIVATE LIMITED,NEW DELHI vs. ACIT, CIRCLE-10(1), DELHI

In the result the appeal of the assessee is allowed”

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2015-16 Honeywell Exim Private Vs. Acit, Limited, House No. 121, Circle-10(1), A Pkt., B-04, Keshavpuram. Delhi New Delhi-1100 35 1100 07 Pan: Aadch3719B (Appellant) (Respondent)

1 to section 148] with the assessing officer which suggests that income chargeable to tax in the case of assessee for the relevant assessment year has escaped assessment. 6. On the facts and circumstances of the case, the CIT(A), NFAC has erred both on facts and in law in confirming the assessment, despite the fact that the reassessment proceedings

MAMRAJ AGGARWAL,DELHI SADAR BAZAR, DELHI vs. INCOME TAX OFFICER WARD 47(1), DELHI, DELHI

In the result the appeal of the assessee is allowed

1) without\nconducting any independent investigation.\n6.That on the facts and circumstances of the case the Ld. CIT(A) has erred in\nconfirming the addition made by Ld. AO both on facts and in law in deciding the\nquantum of addition on account of bogus purchases without discrediting the\ncorresponding sales making the disallowance arbitrary and unsustainable.\n7. That

ANIL KUMAR JAIN,NEW DELHI vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-26, JHANDEWALAN, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

purchases. 4.4. On the facts and circumstances of the case, the CIT(A) erred in upholding the addition made by the AO on account of bogus purchases/commission despite the fact that Appellant brought on record the evidence and material to prove the identity, creditworthiness and genuineness of the transaction even part of the transaction does not pertain to the Appellant

INCOME TAX OFFICER, INCOME TAX OFFICE vs. RITU BALA, FARIDABDA

In the result, the appeal of Revenue is dismissed

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2018-19 Income Tax Officer, Ritu Bala, Vs. Faridabad 4237 Indra Prashtha Colony, Haryana Faridabad – 121 001 Haryana Pan :Bdhpb1495B (Appellant) (Respondent)

148A(d) of the Act dated 31.03.2022 was passed with approval of specified authority along with notice under Section 148 of the Act. In case of assessee, specific information was flagged as per Risk Management Strategy formulated by the CBDT under clause (i) to explanation (1) to section 148 of the Act. As per the specific information, Assessee has taken

DEEPAK AGARWAL,DELHI vs. DCIT,CENTRAL CIRCLE- 13, DELHI

Bench: Shri S Rifaur Rahman, Accountnat Member & Shri Anubhav Sharma

purchase amount of Rs.21,05,78,920/- and Rs.10,44,42,381/-, respectively @ 1%, of this addition of Rs.31,50,213/- was made u/s 68 of the Act. In AY 2018- 19, addition of Rs.1,91,80,846/- was made as commission for providing accommodation entries. In AY 2021-22, addition of Rs.15,25,45,445/- was also made

DEEPAK AGARWAL,DELHI vs. DCIT, CENTRAL CIRCLE- 25 , DELHI

Bench: Shri S Rifaur Rahman, Accountnat Member & Shri Anubhav Sharma

purchase amount of Rs.21,05,78,920/- and Rs.10,44,42,381/-, respectively @ 1%, of this addition of Rs.31,50,213/- was made u/s 68 of the Act. In AY 2018- 19, addition of Rs.1,91,80,846/- was made as commission for providing accommodation entries. In AY 2021-22, addition of Rs.15,25,45,445/- was also made

DEEPAK AGARWAL,DELHI vs. DCIT, CENTRAL CIRCLE-25, DELHI

Bench: Shri S Rifaur Rahman, Accountnat Member & Shri Anubhav Sharma

purchase amount of Rs.21,05,78,920/- and Rs.10,44,42,381/-, respectively @ 1%, of this addition of Rs.31,50,213/- was made u/s 68 of the Act. In AY 2018- 19, addition of Rs.1,91,80,846/- was made as commission for providing accommodation entries. In AY 2021-22, addition of Rs.15,25,45,445/- was also made

DEEPAK AGARWAL,DELHI vs. DCIT, CENTRAL CIRCLE- 25, DELHI

Bench: Shri S Rifaur Rahman, Accountnat Member & Shri Anubhav Sharma

purchase amount of Rs.21,05,78,920/- and Rs.10,44,42,381/-, respectively @ 1%, of this addition of Rs.31,50,213/- was made u/s 68 of the Act. In AY 2018- 19, addition of Rs.1,91,80,846/- was made as commission for providing accommodation entries. In AY 2021-22, addition of Rs.15,25,45,445/- was also made

DCIT, CENTRAL CIRCLE, GHAZIABAD vs. SUSHIL TYAGI, DELHI

Accordingly, Ground No. 2 raised by the revenue is dismissed

Bench: Shri M. Balaganesh & Shri Vimal Kumardcit, Vs. Sushil Tyagi, Central Circle, A-2, Ganpati Ghaziabad Apartments, Civil Lines, New Delhi (Appellant) (Respondent) Pan:Aejpt6739A Dcit, Vs. Yogender Singh, Central Circle, J-6A, Sector-23, Ghaziabad Sanjay Nagar, Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Yogender Singh, Vs. Dcit, J-6A, Sector-23, Central Circle, Sanjay Nagar, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Naveen Tyagi, Vs. Dcit, G-302, Vvip Central Circle, Addresses, Raj Nagar Ghaziabad Extention, Ghaziabad (Appellant) (Respondent) Pan:Admpt6420A Sarika Tyagi, Vs. Dcit, H-100, Patel Nagar,- Central Circle, 3, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Afapt5986P Assessee By : Shri Rajeev Khandelwal, Ca Shri Gagan Khandelwal, Adv Shri Jaind Jaiswal, Adv Revenue By: Ms. Sapna Bhatia, Cit Dr Date Of Hearing 23/08/2024 Date Of Pronouncement /10/2024

148A(d) of the Act has to be quashed and set aside. Ordered accordingly. Consequently, the notice issued under Section 148 of the Act and the assessment order also are quashed and set aside. 14. In view of the above, Ms. Agarwal states they shall immediately take steps to withdraw the appeal filed. Statement accepted. 15. Petition disposed. No order

YOGENDER SINGH,GHAZIABAD vs. DCIT, CENTRAL CIRCLE, GHAZIABAD

Accordingly, Ground No. 2 raised by the revenue is dismissed

Bench: Shri M. Balaganesh & Shri Vimal Kumardcit, Vs. Sushil Tyagi, Central Circle, A-2, Ganpati Ghaziabad Apartments, Civil Lines, New Delhi (Appellant) (Respondent) Pan:Aejpt6739A Dcit, Vs. Yogender Singh, Central Circle, J-6A, Sector-23, Ghaziabad Sanjay Nagar, Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Yogender Singh, Vs. Dcit, J-6A, Sector-23, Central Circle, Sanjay Nagar, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Naveen Tyagi, Vs. Dcit, G-302, Vvip Central Circle, Addresses, Raj Nagar Ghaziabad Extention, Ghaziabad (Appellant) (Respondent) Pan:Admpt6420A Sarika Tyagi, Vs. Dcit, H-100, Patel Nagar,- Central Circle, 3, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Afapt5986P Assessee By : Shri Rajeev Khandelwal, Ca Shri Gagan Khandelwal, Adv Shri Jaind Jaiswal, Adv Revenue By: Ms. Sapna Bhatia, Cit Dr Date Of Hearing 23/08/2024 Date Of Pronouncement /10/2024

148A(d) of the Act has to be quashed and set aside. Ordered accordingly. Consequently, the notice issued under Section 148 of the Act and the assessment order also are quashed and set aside. 14. In view of the above, Ms. Agarwal states they shall immediately take steps to withdraw the appeal filed. Statement accepted. 15. Petition disposed. No order

NAVEEN TYAGI,GHAZIABAD vs. DCIT, CENTRAL CIRCLE , GHAZIABAD

Accordingly, Ground No. 2 raised by the revenue is dismissed

Bench: Shri M. Balaganesh & Shri Vimal Kumardcit, Vs. Sushil Tyagi, Central Circle, A-2, Ganpati Ghaziabad Apartments, Civil Lines, New Delhi (Appellant) (Respondent) Pan:Aejpt6739A Dcit, Vs. Yogender Singh, Central Circle, J-6A, Sector-23, Ghaziabad Sanjay Nagar, Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Yogender Singh, Vs. Dcit, J-6A, Sector-23, Central Circle, Sanjay Nagar, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Naveen Tyagi, Vs. Dcit, G-302, Vvip Central Circle, Addresses, Raj Nagar Ghaziabad Extention, Ghaziabad (Appellant) (Respondent) Pan:Admpt6420A Sarika Tyagi, Vs. Dcit, H-100, Patel Nagar,- Central Circle, 3, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Afapt5986P Assessee By : Shri Rajeev Khandelwal, Ca Shri Gagan Khandelwal, Adv Shri Jaind Jaiswal, Adv Revenue By: Ms. Sapna Bhatia, Cit Dr Date Of Hearing 23/08/2024 Date Of Pronouncement /10/2024

148A(d) of the Act has to be quashed and set aside. Ordered accordingly. Consequently, the notice issued under Section 148 of the Act and the assessment order also are quashed and set aside. 14. In view of the above, Ms. Agarwal states they shall immediately take steps to withdraw the appeal filed. Statement accepted. 15. Petition disposed. No order

DCIT CENTRAL CIRCLE , GHAZIABAD vs. YOGENDER SINGH , GHAZIABAD

Accordingly, Ground No. 2 raised by the revenue is dismissed

Bench: Shri M. Balaganesh & Shri Vimal Kumardcit, Vs. Sushil Tyagi, Central Circle, A-2, Ganpati Ghaziabad Apartments, Civil Lines, New Delhi (Appellant) (Respondent) Pan:Aejpt6739A Dcit, Vs. Yogender Singh, Central Circle, J-6A, Sector-23, Ghaziabad Sanjay Nagar, Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Yogender Singh, Vs. Dcit, J-6A, Sector-23, Central Circle, Sanjay Nagar, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Naveen Tyagi, Vs. Dcit, G-302, Vvip Central Circle, Addresses, Raj Nagar Ghaziabad Extention, Ghaziabad (Appellant) (Respondent) Pan:Admpt6420A Sarika Tyagi, Vs. Dcit, H-100, Patel Nagar,- Central Circle, 3, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Afapt5986P Assessee By : Shri Rajeev Khandelwal, Ca Shri Gagan Khandelwal, Adv Shri Jaind Jaiswal, Adv Revenue By: Ms. Sapna Bhatia, Cit Dr Date Of Hearing 23/08/2024 Date Of Pronouncement /10/2024

148A(d) of the Act has to be quashed and set aside. Ordered accordingly. Consequently, the notice issued under Section 148 of the Act and the assessment order also are quashed and set aside. 14. In view of the above, Ms. Agarwal states they shall immediately take steps to withdraw the appeal filed. Statement accepted. 15. Petition disposed. No order

SARIKA TYAGI,GHAZIBAD vs. DCIT, CENTRAL CIRCLE, GHAZAIBAD

Accordingly, Ground No. 2 raised by the revenue is dismissed

Bench: Shri M. Balaganesh & Shri Vimal Kumardcit, Vs. Sushil Tyagi, Central Circle, A-2, Ganpati Ghaziabad Apartments, Civil Lines, New Delhi (Appellant) (Respondent) Pan:Aejpt6739A Dcit, Vs. Yogender Singh, Central Circle, J-6A, Sector-23, Ghaziabad Sanjay Nagar, Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Yogender Singh, Vs. Dcit, J-6A, Sector-23, Central Circle, Sanjay Nagar, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Naveen Tyagi, Vs. Dcit, G-302, Vvip Central Circle, Addresses, Raj Nagar Ghaziabad Extention, Ghaziabad (Appellant) (Respondent) Pan:Admpt6420A Sarika Tyagi, Vs. Dcit, H-100, Patel Nagar,- Central Circle, 3, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Afapt5986P Assessee By : Shri Rajeev Khandelwal, Ca Shri Gagan Khandelwal, Adv Shri Jaind Jaiswal, Adv Revenue By: Ms. Sapna Bhatia, Cit Dr Date Of Hearing 23/08/2024 Date Of Pronouncement /10/2024

148A(d) of the Act has to be quashed and set aside. Ordered accordingly. Consequently, the notice issued under Section 148 of the Act and the assessment order also are quashed and set aside. 14. In view of the above, Ms. Agarwal states they shall immediately take steps to withdraw the appeal filed. Statement accepted. 15. Petition disposed. No order

ITO, NEW DELHI vs. RUPTEX MINERAL WATER PRIVATE LIMITED , NEW DELHI

In the result, the appeal filed by the Department of Revenue is dismissed and cross-objection filed by Assessee are allowed

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2017-18 Income Tax Officer, Vs. Ruptex Mineral Water Private New Delhi. Limited, K No. 799/1 Village Burari Jagatpur B.O. Jagatpur New Delhi. Pin: 1100 84, Delhi Pan :Aabcr0261Q (Appellant) (Respondent)

bogus sales amounting to Rs.4,11,56,500/-. The assessee, on 23.12.2021, filed objection to the reopening of the assessment u/s 147/148 and hence, notice issued u/s 148A(b) of the Act is bad in law and the same is liable to be dropped. An order under Section 148A(d) of the Act was passed on 30.07.2022, whereby the objections

DCIT, VIKASH BHAWAN vs. RAJAN KUMAR, DELHI

In the result, the Revenue’s appeal is dismissed

Bench: Shri Mahavir Singh & Shri Amitabh Shukladcit, Vs. Rajan Kumar Room No. 218, 2Nd Floor, 31, Vijay Block, D-Block, Vikas Bhawan, Laxmi Nagar, New Delhi Delhi (Pan: Caapk8381E) (Appellant) (Respondent)

1) to section 149 of the Act. 3. Brief facts of the case are that the assessee, an individual filed his return of income for the AY 2013-14 declaring total income of Rs. 40,48,410/-. As per the information available with the department AO noted that the assessee has made bogus purchases to the tune