INCOME TAX OFFICER, WARD-11(1), DELHI vs. HKT CORPORATION PVT LTD, DELHI

Appeal is dismissed

Bench: SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER\nAND\nSHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER\n\nITA No.1036/Del/2024\nAssessment Year: 2020-21\n\nIncome Tax Officer,\nWard-11(1),\nDelhi\nVs.\nM/s. HKT Corporation Pvt.\nLtd.,\n7, South Patel Nagar,\nNew Delhi\nPAN: AACCH0308M\n\n(Appellant)\n\n(Respondent)\n\nAssessee by\nSh. Tarandeep Singh, Adv.\n\nDepartment by\nSh. Rajesh Kumar Dhanesta, Sr. DR\n\nDate of hearing\n23.06.2025\n\nDate of pronouncement\n09.07.2025\n\nORDER\n\nPER SATBEER SINGH

section 143(3) of the\nIncome-tax Act, 1961 (hereinafter referred to as ‘the Act').\n\nHeard both the parties. Case file perused.\n\nITA No. 1036/Del/2024\n\n2. This Revenue's appeal raises the following substantive\ngrounds:\n\n“1.Whether on the facts and circumstance of the case, the L.d. CIT(A) has\nerred in treating the immovable property

DCIT, NEW DELHI vs. M/S. MARUTI SUZUKI INDIA LTD., NEW DELHI

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

gain of Rs.6,90,68,982/- as business income. 9.3 That the assessing officer erred on facts and in law in holding that investment in units of mutual funds and shares were made as a systematic business activity, without appreciating that such investments were made on capital account and not as “stock-in-trade”. 9.4 That the assessing officer erred

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

gain of Rs.6,90,68,982/- as business income. 9.3 That the assessing officer erred on facts and in law in holding that investment in units of mutual funds and shares were made as a systematic business activity, without appreciating that such investments were made on capital account and not as “stock-in-trade”. 9.4 That the assessing officer erred

RICHMOND EDUCATIONAL SOCIETY,NOIDA vs. DCIT/ACIT CENTRAL CIRCLE, GHAZIABAD, GHAZIABAD

In the result, the appeal of the Assessee is allowed

3) to the\nfifteenth proviso to clause (23C) of section 10 of the Act that where a reference,\nunder the first proviso to sub-section (3) of section 143, has been made on or before\nthe 31st March, 2022 by the Assessing Officer for the contravention of certain\nprovisions of clause (23C) of section 10 of the Act, such references

DCIT CENTRAL CIRCLE 05 , DELHI vs. DEEPAK KOTHARI , KANPUR

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

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)

capital gain earned in respect of transfer of land at Gujarat. The exemption was claimed in respect of a residential property acquired at Kanpur i.e the "new asset". That other than the "New Asset" the appellant was the legal owner of only one Residential Property at Sky lounge Pune. The L.D A.O however disallowed the exemption claimed by the appellant

DEEPAK KATHARI,KANPUR vs. ACIT, CC-5, NEW DELHI

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

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)

capital gain earned in respect of transfer of land at Gujarat. The exemption was claimed in respect of a residential property acquired at Kanpur i.e the "new asset". That other than the "New Asset" the appellant was the legal owner of only one Residential Property at Sky lounge Pune. The L.D A.O however disallowed the exemption claimed by the appellant

ACIT, NEW DELHI vs. M/S. KCT PAPERS LTD., NEW DELHI

In the result, grounds raised by the revenue are dismissed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharmaacit, Circle 5 (1) Vs. M/S. Kct Papers Limited, New Delhi. Thapar House, 124, Janpath, New Delhi – 110 001. (Pan : Aacck4937D) (Appellant) (Respondent) Assessee By : Shri Rohit Jain, Advocate Shri Deepesh Jain, Advocate Shri Tavish Verma, Advocate Revenue By : Shri Kailash Dan Ratnoo, Cit Dr Date Of Hearing : 10.09.2025 Date Of Order : 05.12.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)-Viii, New Delhi [Hereinafter Referred To As ‘Ld. Cit (A)] Dated 21.03.2014For Assessment Year 2008-09. 2. Brief Facts Of The Case Are, The Assessee Company Belongs To The Thapar Group Established By Late Lala Karam Chand Thapar. There Was A Family Settlement Between The Various Constituents Of The Karam Chand Thapar Family As A Result Of Which Revenue-Organization/Restructuring Of The Group Dated 27Th April, 2001. The Re April, 2001. The Re-Organization Of The Group Companies & Trusts Organization Of The Group Companies & Trusts Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala K.C. Thapar. The Family Tree Of Karam Chand T K.C. Thapar. The Family Tree Of Karam Chand Thapar Family Is Explained As Hapar Family Is Explained As Under In The Form Of A Diagrammatic Chart: Under In The Form Of A Diagrammatic Chart:

3,36,25,904 40. In this regard, it is respectfully submitted that aforesaid long-term capital gains were computed by the assessee by taking cost to MAL & KCTBL as its cost of acquisition as per section 49(1)(e) of the Act and including the period of holding of MAL & KCTBL in its period of holding while calculating

THE COMMISSIONER OF INCOME TAX -INTERNATIONAL TAXATION-1 vs. REEMA CHAWLA

Appeals are dismissed

Section 54F is a beneficial provision and is applicable to an assessee when the old capital asset is replaced by a new capital asset in the form of a residential house. Once an assessee falls within the ambit of a beneficial provision, then the said provision should be liberally interpreted. The Supreme Court in CCE v. Favourite Industries

JCIT(OSD), JHANDEWALAN vs. NARENDRA AGGARWAL, FARIDABAD

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

Bench: Shri Sudhir Kumar & Shri Manish Agarwaljcit (Osd), Jhandewalan, Vs. Narendra Aggarwal, Delhi H.No. 467, Sector-21-A, Fardidabad, Haryana (Pan: Aagpa1441D) (Appellant) (Respondent) Assessee By : Dr.Rakesh Gupta, Adv., Sh. Somil Agarwal, Adv., Saksham Agarwal, Ca & Deepesh Garg, Adv. Revenue By : Ms. Amisha S. Gupt, Cit Dr Date Of Hearing : 04.11.2025 Date Of Order : 19.12.2025 O R D E R Per Sudhir Kumar, Jm :

3) of the Acton 27.12 2022. Legal framework for initiation of proceeding under section 153C 6.5 Section 153C of the Act provides as under: (1) Notwithstanding anything contained in section 139, section 147, section 148. section 149, section 151 and section 153. where the Assessing Officer is satisfied that.— (a) any money, bullion, jewellery or other valuable article or thing

NINA KSHETRY,NOIDA vs. ACIT, CIRCLE INT.TAX. 2(1)(2), NEW DELHI

In the result, the appeal of the assesses in ITA 1876/Del/2023, ITA

Bench: Sh. C.N. Prasad & Sh. Naveen Chandraassessment Year: 2016-17

3. CIT v. Usha International [2012] 348 ITR 485 (Del) [FB] 4. Asian Paints Ltd. v. DCIT, [2009] 308 ITR 195 (Borm.) 12. The ld. AR further argued that the Approval under Section 151 is based on borrowed satisfaction, without independent application of mind and is mechanical in law and relied on the judgement of CIT vs. SPL'S Siddhartha

SANGITA KSHETRY,NOIDA vs. ACIT,CIRCLE INT.TAX. 2(1)(2), NEW DELHI

In the result, the appeal of the assesses in ITA 1876/Del/2023, ITA

Bench: Sh. C.N. Prasad & Sh. Naveen Chandraassessment Year: 2016-17

3. CIT v. Usha International [2012] 348 ITR 485 (Del) [FB] 4. Asian Paints Ltd. v. DCIT, [2009] 308 ITR 195 (Borm.) 12. The ld. AR further argued that the Approval under Section 151 is based on borrowed satisfaction, without independent application of mind and is mechanical in law and relied on the judgement of CIT vs. SPL'S Siddhartha

HERSH VARDHAN KSHETRY,NOIDA vs. ACIT, CIRCLE INT. TAX. 2(1)(2), NEW DELHI

In the result, the appeal of the assesses in ITA 1876/Del/2023, ITA

Bench: Sh. C.N. Prasad & Sh. Naveen Chandraassessment Year: 2016-17

3. CIT v. Usha International [2012] 348 ITR 485 (Del) [FB] 4. Asian Paints Ltd. v. DCIT, [2009] 308 ITR 195 (Borm.) 12. The ld. AR further argued that the Approval under Section 151 is based on borrowed satisfaction, without independent application of mind and is mechanical in law and relied on the judgement of CIT vs. SPL'S Siddhartha

CIT vs. USHA INTERNATIONAL LTD

153 referred to as the relevant assessment year): Provided that where an assessment under sub-section (3) of section 143 or this section has been made for the relevant assessment year, no action shall be taken under this section after the expiry of four years from the end of the relevant assessment year, unless any income chargeable

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents or assets seized or requisitioned shall be handed over

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents or assets seized or requisitioned shall be handed over

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents or assets seized or requisitioned shall be handed over

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents or assets seized or requisitioned shall be handed over

SUNIL KAPOOR,NEW DELHI vs. ACIT CIRCLE INTL. TAXATION 2(1)(2), NEW DELHI

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

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2021-22 Shri Sunil Kapoor, Vs. Acit K-77, Lajpat Nagar-Ii, Circle Intt. New Delhi-110 024 Taxation 2(1)(2) Pan Aoips5698J New Delhi. (Appellant) (Respondent)

153 of I.T.A., 1963 and thus could not be called upon to verify the 10 year old transaction through Appellant to the extent of beyond reasonable doubt. Even under Section 149(1) (b) of Income Tax Act, 1961, the assessee cannot be called upon to furnish the particulars income beyond a period of 10 years.” 3. In brief, the facts