THE HISAR LEADING BANK CO-OP NON-AGRI THRIFT & CREDIT SOCIETY,HISAR vs. INCOME-TAX OFFICER, WARD-1, HISAR, HISAR

In the result, Appeal of the Assessee is allowed

Section 149 as amended by Finance Act, 2021 as per Rajeev\nBansal's case could be till 17/06/2022. Since the notice u/s 148 of the Act\nhas been issued on 23/07/2022, the same is barred by limitation which\nrenders whole assessment proceedings as null and void. Thus, sought for\nallowing the Appeal.\n7. Per contra, the Ld. Departmental Representative submitted

MITTAL HOMES PVT LTD,DELHI vs. ITO WARD-17(1), DELHI

In the result, the appeal of the Assessee is allowed

Section 148 is undisputedly issued on 5th April\n2022, which is after 1st April 2021. Therefore, the said re-assessment\nproceedings ought to have been dropped in view of the concession made\nby the Ld. Additional Solicitor General of India before the Hon'ble\nSupreme Court as recorded in paragraph 190) of the decision rendered\nin Rajeev Bansal (supra). This

SHIVANI TAYAL,NEW DELHI vs. INCOME TAX OFFICER, WARD 49(1), NEW DELHI, DELHI

In the result, Appeal of the Assessee is allowed

Bench: Shri M. Balaganesh & Sh. Yogesh Kumar U.S.Shivani Tayal Vs. Income Tax Officer, C-27, Shop No.9-10, Ward 49(1), Mansarovar Garden, New New Delhi Delhi Pan: Andpt8647E Appellant Respondent Assessee By Advocate Ragini Handa Revenue By Sh. Sahil Kumar Bansal, Sr. Dr Date Of Hearing 06/05/2025 Date Of Pronouncement 13/06/2025 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of The Cit(A)/National Faceless Appeal Centre (‘Nfac’ For Short) Dated

148 of the Act was issued to the Assessee on 23/07/2022. 4. An assessment order came to be passed u/s 147 r.w. Section 144 r.w. Section 144B of the Act on 27/01/2023 against the Assessee by determining the income of the Assessee at Rs. 1,40,24,500/-. Aggrieved by the assessment order dated 27/01/2023, the Assessee preferred an Appeal

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, NOIDA, NOIDA vs. M/S RUDRA BULLDWELL HOMES PVT. LTD.,, DELHI

delay, we therefore condone the same\nand proceed to adjudicate this appeal.\n4.\nThe principal argument taken by the ld. Counsel for the assessee is that\nnotice under section 148

RAJBIR SINGH,GURGAON vs. ACIT, CENTRAL CIRCLE-19, NEW DELHI

In the result, Appeal of the Assessee is allowed

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Rajbir Singh Vs. Acit 1625A, The Magnolia, Dlf Central Circle-19, City, Phase-V, Gurgaon, Khandewalan, Haryana New Delhi Pan: Aaups2176H Appellant Respondent Assessee By Sh. Amarjeet Singh, Ca Revenue By Sh. Om Prakash, Sr. Dr Date Of Hearing 17/09/2025 Date Of Pronouncement 14/11/2025 Order

delay of 09 days in filing the present Appeal is hereby condoned. 3. The Ld. Counsel for the Assessee submitted that the approval under Section 151 of the Income Tax Act, 1961 ('Act' for short) has been obtained from Pr. Commissioner of Income Tax, Delhi-1, and should have 2 Rajbir Singh Vs. ACIT been obtained from PCIT

BASUDEO SONI,NEW DELHI vs. ITO WARD 35(1) , NEW DELHI

Appeal is allowed in above terms

Bench: Sh. Satbeer Singh Godaraita No. 4894/Del/2025 : Asstt. Year : 2016-17 Basudeo Soni, Vs Income Tax Officer, C/O B-50, Lgf, South Extension-Ii, Ward-35(1), New Delhi-110049 New Delhi (Appellant) (Respondent) Pan No. Agyps4983N Assessee By: Sh. Saantanu Jain, Adv. & Ms. Jahanvi Khanna, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 22.09.2025 Date Of Pronouncement: 22.09.2025

Delay of 103 days in filing of the instant appeal is condoned in the larger interest of justice in light of Collector Land Acquisition vs. Mst. Katiji & Ors (1987) 167 ITR 471 (SC). 2 Basudeo Soni 4. It emerges at the outset that there arises the first and foremost issue of validity of section 148

SH. RAJ KUMAR CHAUDHARY,DELHI vs. ITO WARD-34(5), DELHI

In the result, both the appeals of the assessee are allowed for statistical purposes only

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh[Assessment Year: 2018-19] Shri Raj Kumar Chaudhary, Income Tax Officer, C-243, Sector-3, Dsidc Ward-34(5), Indl. Area Bawana, Vs Delhi. New Delhi-11003. Pan- Aewpk1980K Assessee Revenue [Assessment Year: 2018-19] Shri Raj Kumar Chaudhary, Income Tax Officer, C-243, Sector-3, Dsidc Ward-34(5), Indl. Area Bawana, Vs Delhi. New Delhi-11003. Pan- Aewpk1980K Assessee Revenue

148 of the Act issued without validly complying section 151 of the Act were also without jurisdiction. 3.7That the learned Commissioner of Income Tax (Appeals) has failed to appreciate that notice u/s 148A(b) of the Act and order u/s 148A(d) of the Act are contrary to section 151A of the Act; and therefore the assumption of jurisdiction

SH. RAJ KUMAR CHAUDHARY,DELHI vs. ITO WARD-34(5), DELHI

In the result, both the appeals of the assessee are allowed for statistical purposes only

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh[Assessment Year: 2018-19] Shri Raj Kumar Chaudhary, Income Tax Officer, C-243, Sector-3, Dsidc Ward-34(5), Indl. Area Bawana, Vs Delhi. New Delhi-11003. Pan- Aewpk1980K Assessee Revenue [Assessment Year: 2018-19] Shri Raj Kumar Chaudhary, Income Tax Officer, C-243, Sector-3, Dsidc Ward-34(5), Indl. Area Bawana, Vs Delhi. New Delhi-11003. Pan- Aewpk1980K Assessee Revenue

148 of the Act issued without validly complying section 151 of the Act were also without jurisdiction. 3.7That the learned Commissioner of Income Tax (Appeals) has failed to appreciate that notice u/s 148A(b) of the Act and order u/s 148A(d) of the Act are contrary to section 151A of the Act; and therefore the assumption of jurisdiction

BRIJESH CHARITABLE TRUST,PANIPAT vs. ACIT, CIRCLE PANIPAT, PANIPAT

Appeals are dismissed

Bench: Shri Saktijit Deyassessment Year: 1993-94 With Assessment Year: 1994-95 With Assessment Year: 1993-94 With Assessment Year: 1994-95

condone delay, I dismiss the appeals without admitting them. 11. In the result, the appeals are dismissed. ITA No.2783/Del/2012 for AY: 1993-94 ITA No. 2784/Del/2012 for AY:1994-95 12. These two appeals arise out of proceedings under section 154 of the Act. 13. Briefly the facts are, for the assessment year under dispute, the assessee did not file

BRIJESH CHARITABLE TRUST,PANIPAT vs. ACIT, PANIPAT

Appeals are dismissed

Bench: Shri Saktijit Deyassessment Year: 1993-94 With Assessment Year: 1994-95 With Assessment Year: 1993-94 With Assessment Year: 1994-95

condone delay, I dismiss the appeals without admitting them. 11. In the result, the appeals are dismissed. ITA No.2783/Del/2012 for AY: 1993-94 ITA No. 2784/Del/2012 for AY:1994-95 12. These two appeals arise out of proceedings under section 154 of the Act. 13. Briefly the facts are, for the assessment year under dispute, the assessee did not file

BRIJESH CHARITABLE TRUST,PANIPAT vs. ACIT, PANIPAT

Appeals are dismissed

Bench: Shri Saktijit Deyassessment Year: 1993-94 With Assessment Year: 1994-95 With Assessment Year: 1993-94 With Assessment Year: 1994-95

condone delay, I dismiss the appeals without admitting them. 11. In the result, the appeals are dismissed. ITA No.2783/Del/2012 for AY: 1993-94 ITA No. 2784/Del/2012 for AY:1994-95 12. These two appeals arise out of proceedings under section 154 of the Act. 13. Briefly the facts are, for the assessment year under dispute, the assessee did not file

BRIJESH CHARITABLE TRUST,PANIPAT vs. ACIT, CIRCLE PANIPAT, PANIPAT

Appeals are dismissed

Bench: Shri Saktijit Deyassessment Year: 1993-94 With Assessment Year: 1994-95 With Assessment Year: 1993-94 With Assessment Year: 1994-95

condone delay, I dismiss the appeals without admitting them. 11. In the result, the appeals are dismissed. ITA No.2783/Del/2012 for AY: 1993-94 ITA No. 2784/Del/2012 for AY:1994-95 12. These two appeals arise out of proceedings under section 154 of the Act. 13. Briefly the facts are, for the assessment year under dispute, the assessee did not file

NAGPAL ,UTTAR PRADESH vs. ITO WARD -2 (5) , CHANDAUSI

Appeal is allowed in above terms

delay of 617 days in filing the appeal, which was condoned. The primary issue was the validity of the Section 148

KRISHAN KUMAR MAKRANIA PRO. M/S. MAKRANIA OIL MILL,,BHIWANI vs. DCIT CENTRAL CIRCLE-I, GURGAON

In the result, assessee’s appeal in ITA No

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singhassessment Year: 2011-12)

delay in filing the appeal before the Tribunal deserve to be condoned. We hold and direct accordingly. 3 Krishna Kumar Makrania 4. The assessee before us, mainly challenged the assessment proceedings on this particular count that notice u/s. 143(2) of the Act have not been issued and served upon the assessee and the reassessment proceedings finalized u/s. 148

MONICA GOLD PIPES PRIVATE LIMITED,KHASRA NO. vs. INCOME TAX OFFICER, WARD 16(2), C R BUILDING

In the result, appeals of the assessee are allowed

Bench: Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A Nos.3791 & 3792/Del/2023 िनधा"रणवष"/Assessment Years: 2013-14 & 2014-15

Section 253 of the Income-tax Act, 1961- Appellate Tribunal - Appeals to(Condonation of delay) - Assessment years 1994-95 and 1996-97- Whether where assessee filed appeal before Tribunal with a delay of 2984 days by taking a plea that he was wrongly advised by his Chartered Accountant earlier not to file appeal, in view of fact that assessee produced

MONICA GOLD PIPES PRIVATE LIMITED,KHASRA NO. vs. INCOME TAX OFFICER, WARD 16(2), C R BUILDING

In the result, appeals of the assessee are allowed

Bench: Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A Nos.3791 & 3792/Del/2023 िनधा"रणवष"/Assessment Years: 2013-14 & 2014-15

Section 253 of the Income-tax Act, 1961- Appellate Tribunal - Appeals to(Condonation of delay) - Assessment years 1994-95 and 1996-97- Whether where assessee filed appeal before Tribunal with a delay of 2984 days by taking a plea that he was wrongly advised by his Chartered Accountant earlier not to file appeal, in view of fact that assessee produced

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

148 taxmann. com 313 (Calcutta) has held as under: Where Assessing Officer solely based on statement of assessee's director recorded during search operation treated share application money received by assessee-company as undisclosed income and made additions under section 68, since said statement was retracted during search operation and there was no cash trail or any other corroborative evidence

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

148 taxmann. com 313 (Calcutta) has held as under: Where Assessing Officer solely based on statement of assessee's director recorded during search operation treated share application money received by assessee-company as undisclosed income and made additions under section 68, since said statement was retracted during search operation and there was no cash trail or any other corroborative evidence