ESSAR COMMUNICATIONS LIMITED,MAURITIUS vs. ACIT, CIRCLE-1 (2)(2), NEW DELHI

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI S. RIFAUR RAHMAN (Accountant Member)

u/s 144C of the Act. Vide letter dated 17.03.2021, the assessees informed the AO that they were not willing to approach the Dispute Resolution Panel and reserved the right to appeal before CIT(A) against the final assessment orders. Accordingly, final assessment orders were passed. Aggrieved by the assessment order, the assessees filed appeals before

DLF HOME DEVELOPERS LIMITED,NEW DELHI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI-1, NEW DELHI, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2019-20] Dlf Home Developers Limited, Vs Pr.Cit, 9Th Floor, Dlf Centre, Sansad Delhi-1, Marg, New Delhi-110001. New Delhi Pan-Aaccd0037H Appellant Respondent Appellant By Shri R.S.Singhvi, Ca & Shri Satyajeet Goel, Ca Respondent By Shri Surender Pal, Cit Dr Date Of Hearing 19.03.2025 Date Of Pronouncement 23.05.2025

revision jurisdiction on this issue u/s 263 of the Act is quashed.” 22. In view of the above findings and also looking to the fact that necessary enquiry was made by AO and duly replied by the assessee before the AO as well as before Ld. PCIT. Thus, it is clearly established that the AO has applied his mind before

ESSAR COM LIMITED,MAURITIUS vs. ACIT, CIRCLE 1(2)(2), NEW DELHI

revised consideration for VEL shares was\nagreed by the Assessee.\n9. Accordingly, the Assessee sold all the shares it held in VEL to Euro\nPacific Securities Limited (‘EPSL’) (a non-resident company nominated\nby Vodafone International Holdings B.V) for total consideration of USD\n3,02,05,21,511. The gross consideration was received by the Assessee\nafter deduction

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

capital gain offered by the assessee. PCIT accordingly set aside the assessment order passed by the AO u/s 143(3) dated 27.12.2017 and directed the AO to frame fresh assessment after considering the observations of PCIT in the order passed u/s 263 of the Act. 6. Aggrieved by the order of PCIT, Assessee is now in appeal and has raised

DCIT, CIRCLE 52(1), NEW DELHI vs. BHUPINDER SINGH BHALLA, NEW DELHI

Appeal of the revenue is dismissed

revised return which was not filed.\nTo support his contention, the appellant has claimed that in ITR has\nclaimed Indexed Cost at Rs 13,177,336/- which should have been Rs\n19,164,284/-. The appellant has filed purchase deeds for F.Y 1988-89 and\n1993-94 vide his submissions before the Ld. A.O. It has been contended by\nthe

SANDEEP HOODA,NEW DELHI vs. PR.CIT - 7, NEW DELHI

The appeal is allowed and the impugned order dated 30

Bench: Shri Anil Chaturvedi & Shri Anubhav Sharmasandeep Hooda, Vs. Pr. Cit-7, C/O. Rra Taxindia, D-28, South New Delhi Extension, Part-I, New Delhi (Appellant) (Respondent) Pan: Aacph5453J

revised u/s 263 of Income Tax Act, 1961, C) When the assessment record was not called and examined, D) When the issue was considered in the assessment proceeding & a view was taken by the assessing officer, E) When the action under section 263 was initiated & completed based on audit objection without application of mind, F) When the order passed u/s

SAIF PARTNERS INDIA IV LIMITED ,DELHI vs. ACIT INT. TAXATION-3(1)(2), DELHI

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

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

gain in India. The ld. CIT has clearly ignored the fact the assessee has neither claimed nor carried forward such capital loss in its return of income filed in India. 17. The Hon'ble Supreme Court in Malabar Industrial Co. Ltd., 243 ITR 83, has laid down the following ratio: "A bare reading of section 263 of the Income

ACIT, CIRCLE-46(1), NEW DELHI vs. DABUR INVEST CORP , DELHI

In the result, appeals of the Revenue are dismissed and appeal\nof the assessee for the AY 2017-18 is partly allowed as indicated\nabove and appeal of the assessee for the AY 2018-19 is dismissed

revision by\nThe Principal Commissioner of Income Tax - 16, New Delhi.\nOn appeal before the coordinate bench against that order,\nthe coordinate bench as per order dated 11 March 2019 has\nquashed assumption of jurisdiction by CIT u/s 263 of The\nIncome Tax Act. Further, for assessment year 2011 - 12 and\n2012 - 13 the action u/s 147/148 of the income

DABUR INVEST CORP,NEW DELHI vs. JCIT, RANGE-46, NEW DELHI

In the result, appeals of the Revenue are dismissed and appeal\nof the assessee for the AY 2017-18 is partly allowed as indicated\nabove and appeal of the assessee for the AY 2018-19 is dismissed

revision by\nThe Principal Commissioner of Income Tax - 16, New Delhi.\nOn appeal before the coordinate bench against that order,\nthe coordinate bench as per order dated 11 March 2019 has\nquashed assumption of jurisdiction by CIT u/s 263 of The\nIncome Tax Act. Further, for assessment year 2011 - 12 and\n2012 - 13 the action u/s 147/148 of the income

SUNITA SAINI,HARYANA vs. INCOME TAX OFFICER, WARD 1(4), FARIDABAD, HARYANA

In the result, appeal of the Assessee is allowed

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A No.1877/Del/2024 िनधा"रणवष"/Assessment Year:2016-17 बनाम Sunita Saini, Income Tax Officer, House No.743P, Sector-38, Vs. Ward 1(4), Gurugram, Haryana. Faridabad. Pan No.Awmps2317Q अपीलाथ" Appellant ""यथ"/Respondent

revision under Section 263 of the Act. 6.1 Ld. Counsel further referring to show cause notice dated 21.04.2023 issued u/s 263 of the Act submitted that the grievance of the Assessee against the impugned order u/s 263 of IT Act is that the Ld Pr CIT in para 17 at page 16 therein has invoked Explanation 2 to sec 263

DABUR INVEST CORP,NEW DELHI vs. JCIT, RANGE-46, NEW DELHI

In the result, appeals of the Revenue are dismissed and appeal

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraिनधा"रणवष"/Assessment Year: 2017-18 बनाम Acit, Dabur Invest Corp., 4Th Floor, Punjab Bhawan, Circle-46(1), Room No.106, Vs. Drum Shape Building, I.P. Estate, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent िनधा"रणवष"/Assessment Year: 2018-19 बनाम Acit, Dabur Invest Corp., 4Th Floor, Punjab Bhawan, Circle-46(1), Room No.106, Vs. Drum Shape Building, I.P. Estate, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent िनधा"रणवष"/Assessment Year: 2017-18 बनाम Dabur Invest Corp., Jcit, 4Th Floor, Punjab Bhawan, Vs. Range-46, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent िनधा"रणवष"/Assessment Year: 2018-19 बनाम Dabur Invest Corp., Jcit, 4Th Floor, Punjab Bhawan, Vs. Range-46, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent

revision by The Principal Commissioner of Income Tax – 16, New Delhi. On appeal before the coordinate bench against that order, the coordinate bench as per order dated 11 March 2019 has quashed assumption of jurisdiction by CIT u/s 263 of The Income Tax Act. Further, for assessment year 2011 – 12 and 2012 – 13 the action u/s 147/148 of the income

ACIT, CIRCLE-46(1), NEW DELHI vs. DABUR INVEST CORP., DELHI

In the result, appeals of the Revenue are dismissed and appeal

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraिनधा"रणवष"/Assessment Year: 2017-18 बनाम Acit, Dabur Invest Corp., 4Th Floor, Punjab Bhawan, Circle-46(1), Room No.106, Vs. Drum Shape Building, I.P. Estate, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent िनधा"रणवष"/Assessment Year: 2018-19 बनाम Acit, Dabur Invest Corp., 4Th Floor, Punjab Bhawan, Circle-46(1), Room No.106, Vs. Drum Shape Building, I.P. Estate, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent िनधा"रणवष"/Assessment Year: 2017-18 बनाम Dabur Invest Corp., Jcit, 4Th Floor, Punjab Bhawan, Vs. Range-46, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent िनधा"रणवष"/Assessment Year: 2018-19 बनाम Dabur Invest Corp., Jcit, 4Th Floor, Punjab Bhawan, Vs. Range-46, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent

revision by The Principal Commissioner of Income Tax – 16, New Delhi. On appeal before the coordinate bench against that order, the coordinate bench as per order dated 11 March 2019 has quashed assumption of jurisdiction by CIT u/s 263 of The Income Tax Act. Further, for assessment year 2011 – 12 and 2012 – 13 the action u/s 147/148 of the income

DIPANKAR MOHAN GHOSH,NEW DELHI vs. CIT-1, NEW DELHI

In the result, both the appeals of the assessee are allowed

Capital Gains. 4. That the Ld CIT has wrongly and illegally held that the order passed by the Ld. AO is erroneous and prejudicial to the interest when no independent enquiry has been made by her. Hence the notice issued u/s 263 of the Act and the order passed u/s 263 of the Act is illegal

DIPANKAR MOHAN GHOSH,NEW DELHI vs. ITO, WARD-1(3)(2) INT. TAX., NEW DELHI

In the result, both the appeals of the assessee are allowed

Capital Gains. 4. That the Ld CIT has wrongly and illegally held that the order passed by the Ld. AO is erroneous and prejudicial to the interest when no independent enquiry has been made by her. Hence the notice issued u/s 263 of the Act and the order passed u/s 263 of the Act is illegal

SARVA CAPITAL LLC,NEW DELHI vs. ACIT CIRCLE INTERNATIONAL TAX 3(1)(2), NEW DELHI

In the result, appeal is partly allowed

Bench: Shri Kul Bharat & Dr. B. R. R. Kumar

263 ITR 706) and past accepted stand of the Department in assessment orders passed u/s 143(3) of the Act for AY 2016-17 and AY 2017-18. 5.1 That while denying the treaty benefits to the Appellant, the Ld. AO by following the directions of DRP, was not justified in holding as under :- (i) The scheme of arrangement employed

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 itself was invalid on various legal and factual grounds and thus proceeding initiated Page 2 of 14 ITA No. 3463/DEL/2024 [A.Y. 2015-16] Sanjay Singh Rana Vs. PCIT u/s 263 against the invalid reassessment order is clearly bad in law.” 3. Representatives of both the sides were heard at length. Case records carefully perused. Relevant documentary evidence

MAHASHIAN DI HATTI (P) LTD,NEW DELHI vs. PCIT-4, NEW DELHI

In the result, Appeal of the Assessee is allowed

Capital One Ltd vs DCIT 2025-TIOL-803-ITAT-MUM\n[Do 25/02/2025]\n(iii) PCIT vs Britannia Industries Ltd_2025-TIOL-1120-HC-KOL-IT\n09/07/2025.\n7.\nThe Ld. Counsel put forth one more argument that the\nassessment order was passed u/s 144B of the Act by National\nFaceless Appeal Centre, NFAC led by Principal Chief Commissioner of\nIncome

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

Capital Gain (“STCG”) from the penny stock companies. Thereafter, a search action was carried in the case of Alankit Group and its key promoters Shri Alok Agarwal and others on 18.10.2019. Based on the material found and seized during the course of search proceedings in Alankit group, proceedings in the case of the assessee were initiated u/s 153C