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

2 years were deregistered from the ROC. b. Directors of those companies which had not filed annual returns were disqualified. ITA Nos.4115 & 4067/Del/2025 c. The struck-off companies were restricted from using their bank accounts. d. Genuine corporates were given benefit of condonation of delay scheme for filing the returns. In view of the above, it was felt necessary

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

2 years were deregistered from the ROC. b. Directors of those companies which had not filed annual returns were disqualified. ITA Nos.4115 & 4067/Del/2025 c. The struck-off companies were restricted from using their bank accounts. d. Genuine corporates were given benefit of condonation of delay scheme for filing the returns. In view of the above, it was felt necessary

ITO, NEW DELHI vs. M/S GRAVITY SYSTEMS PVT. LTD., DELHI

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

Bench: Shri. P. K. Bansal & Shri K.N. Charry Assessment Year:2004-05

2) after the issuance of notice under section 148 has ever been issued before the completion of assessment proceedings by the AO. 3. Without prejudice to the above the proceedings of 147 read with 148 are ab-initio-void, as no notice u/s 148 has ever been served on the assessee before the completion of assessment proceedings and the notice

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

2. That on the facts and circumstances of the case and in law, the notice issued under section 148 of the Act is time- barred, invalid and without jurisdiction as per the decision of the Hon'ble Supreme Court in the case of Union of India vs. Rajeev Bansal: (2024) 167 taxmann.com 70 (SC). 3. That on the facts

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

ACIT, NEW DELHI vs. M/S. DIMENSION PROMOTERS PVT. LTD., NEW DELHI

Bench: : Shri H.S. Sidhu. & Shri T.S. Kapoor

delay in issuing a notice under Section 143(2) of the Act would be fatal to the re-assessment proceedings. 15. For the aforementioned reasons, it is held that as far as the second ground is concerned, the Petitioner should succeed. In that view of the matter, the Court does not consider it necessary to examine the first ground

SHRI CHETAN SETH,NEW DELHI vs. ITO, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

condone the delay of 2947 days and admit this appeal for hearing. 3. Grounds of appeal raised by the assessee in ITA No.1808/Del/2023 for AY 2004-05 are as under:- “1.1. That the CIT (A) erred on facts and in law in not holding that the assessment order passed by the assessing officer under section 147/144 of the Income

SHRI CHETAN SETH,NEW DELHI vs. ITO, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

condone the delay of 2947 days and admit this appeal for hearing. 3. Grounds of appeal raised by the assessee in ITA No.1808/Del/2023 for AY 2004-05 are as under:- “1.1. That the CIT (A) erred on facts and in law in not holding that the assessment order passed by the assessing officer under section 147/144 of the Income

CHETAN SETH,NEW DELHI vs. ITO,WARD-15(3), DELHI

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

condone the delay of 2947 days and admit this appeal for hearing. 3. Grounds of appeal raised by the assessee in ITA No.1808/Del/2023 for AY 2004-05 are as under:- “1.1. That the CIT (A) erred on facts and in law in not holding that the assessment order passed by the assessing officer under section 147/144 of the Income

PUNIT KUMAR AGGARWAL,DELHI vs. ITO,WARD-36(2), DELHI

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

condone the delay of 2947 days and admit this appeal for hearing. 3. Grounds of appeal raised by the assessee in ITA No.1808/Del/2023 for AY 2004-05 are as under:- “1.1. That the CIT (A) erred on facts and in law in not holding that the assessment order passed by the assessing officer under section 147/144 of the Income

ISWAR CHAND DUBEY,DELHI vs. ITO,WARD-68 (1), DELHI

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

condone the delay of 2947 days and admit this appeal for hearing. 3. Grounds of appeal raised by the assessee in ITA No.1808/Del/2023 for AY 2004-05 are as under:- “1.1. That the CIT (A) erred on facts and in law in not holding that the assessment order passed by the assessing officer under section 147/144 of the Income

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

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shukla, Accountnat Member

delay, we therefore condone the same and proceed to adjudicate this appeal. 4. The principal argument taken by the ld. Counsel for the assessee is that notice under section 148 dated 18.07.2022 ought to have been issued by the Pr. Chief Commissioner of Income Tax as mandated under section 151 of the Act. The ld. Counsel drew our attention

ASSISTANT COMMISSIONER OF INCOME-TAX , DELHI vs. LOGIC CONTROL PVT. LTD., DELHI

In the result, appeal of Revenue in ITA No

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

delayed return in response to the same. The return was filed beyond the stipulated time and hence the issue/service of notice u/s 143(2) is not applicable in such a case. 6. Per contra, the ld. counsel for the assessee forcefully argued that the issue of notice u/s 143(2) of the Act is a must while framing order

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

UMAR DARAJ,MEERUT vs. ITO WARD-1(2)(4), MEERUT

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

Bench: Shri S.Rifaur Rahman & Shri Yogesh Kumar U.S.Umar Daraj, Vs. Ito, Ward 1(2)(4), 153/1, Hapur Road, Meerut. Umar Nagar, Meerut – 250 001 (Uttar Pradesh). (Pan : Ainpd8766H) (Appellant) (Respondent) Assessee By : Shri Sumit Lal Chandani, Advocate Revenue By : Shri Dayainder Singh Sidhu, Citdr Date Of Hearing : 17.09.2025 Date Of Order : 10.12.2025 O R D E R Per S. Rifaur Rahman:

2 not intentional and beyond the control of the assessee as well as the assessee could not get any benefit in delay filing the same. Accordingly, he prayed that the delay in filing the appeal be condoned. 3. We have heard both the counsels on the issue of condonation of delay. In our considered opinion, there was only 8 days

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

PR. COMMISSIONER OF INCOME TAX -7 vs. SUMITOMO CORPORATION INDIA (P) LTD.

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE RAVINDER DUDEJA

148 has been issued prior to the 1st day of June, 2016 and the assessment or reassessment has not been completed by such date due to exclusion of time referred to in Explanation 1, such assessment or reassessment shall be completed in accordance with the provisions of this section as it stood immediately before its substitution by the Finance

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MICROSOFT INDIA ( R & D) PVT. LTD.

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

148 has been issued prior to the 1st day of June, 2016 and the assessment or reassessment has not been completed by such date due to exclusion of time referred to in Explanation 1, such assessment or reassessment shall be completed in accordance with the provisions of this section as it stood immediately before its substitution by the Finance