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

condoned the delay of 10 days and\nshould have decided the appeal on its merit. In so far as, merit is\nconcerned. It is the case of the Assessee that the issueinvolved in the appeal\nis squarely covered in the ratio laid down by the Hon'ble Supreme Court in\nthe case of union of India Vs. Rajiv Bansal (supra

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

condonation of delay in filing of these two appeals" is not based on correct appreciation of facts on record and therefore unsustainable. 2.2That conclusion of the learned Commissioner of Income Tax (Appeals) National Faceless Appeal Centre (NFAC), New Delhi that "accordingly, appellant's all grounds of appeal are dismissed as not maintainable and thereby appellant two appeals

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

condonation of delay in filing of these two appeals" is not based on correct appreciation of facts on record and therefore unsustainable. 2.2That conclusion of the learned Commissioner of Income Tax (Appeals) National Faceless Appeal Centre (NFAC), New Delhi that "accordingly, appellant's all grounds of appeal are dismissed as not maintainable and thereby appellant two appeals

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 dated 18.07.2022 ought to have been issued by the Pr.\nChief Commissioner of Income Tax as mandated under section 151 of the Act.\nThe ld. Counsel drew our attention

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

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. SUNCITY INFRASTRUCTURES PRIVATE LIMITED, DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Anubhav Sharma & Shri Manish Agarwaldy. Cit, Suncity Infrastructures Pvt. Ltd., Delhi. Lgf-10, Vasant Square Mall, Vs. Vasant Kunj, New Delhi-110070. Pan-Aaics7928N (Appellant) (Respondent) Assessee By Shri Ved Jain, Advocate & Shri Pawan Garg, Ca Department By Shri Mahesh Kumar, Cit-Dr Date Of Hearing 01/07/2025 Date Of Pronouncement 26/09/2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Revenue Against The Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Dated 20.08.2024 In Appeal No. Nfac/2014-15/10115325 Arising Out Of The Order Passed U/S 147 R.W.S.144B Dated 29.03.2021 For Assessment Year 2015-16. 2. Brief Facts Of The Case Are That The Assessee Is A Company Engaged In The Business Of Real State. The Return Of Income Of The Year Under Appeal Was Filed On 30.09.2015 Declaring Total Income Of Rs.2,93,54,930/- & The Same Was Assessee U/S 143(3) Of The Act Vide Order Dated 24.11.2017 Wherein The Income Declared Was Accepted By The Ao. Thereafter, Based On The Information That The Assessee Has Dcit Vs. Suncity Infrastructures Pvt. Ltd. Allotted Preference Shares To One Shri Tarun Agarwal, At 16546/- Per Which Were Not Commensurate With The Financials Of The Company & After Obtaining The Approval Form The Competent Authority Notice Was Issued U/S 148 Dated 31.03.2021 Which Was Served Upon The Assessee On 01.04.2021. Thereafter, Reassessment Order Was Passed U/S 147 R.W.S. 144B Of The Act Wherein Addition Of Rs.11,00,00,000/- Was Made On Account Of Share Premium Treated As Unexplained U/S 68 Of The Act R.W.S 115Bbe Of The Act.

Delay condoned. Having regard to the concession made by the petitioner-Department in the case of Union of India vs. Rajeev Bansal, Civil Appeal no.8629 of 2024 on 03.10.2024 (2024 SCC ONLINE 754), this Special Leave Petition would not survive for further consideration Hence, the Special Leave Petition is dismissed. Pending application(s), if any, shall stand disposed

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 proceedings herein between the parties

KANHA SOFTECH PRIVATE LIMITED,UTTAR PRADESH vs. ACIT, CENTRAL-CIRCLE-I, NOIDA

In the result, the appeal of the Revenue is dismissed

delay of 252 days in filing of the instant appeal is condoned in light of Collector, Land & Acquisition vs. Mst. Katiji & Others (1987) 167 ITR 471 (SC). 3. It transpires during the course of hearing that there arises the first and foremost issue of validity of the impugned reopening itself which the learned assessing authority set into motion against

EAST END APARTMENTS CGHS LTD,DELHI vs. ITO, WARD 60(1), DELHI

In the result, the appeal of the assessee is accordingly allowed as above terms for statistical purposes

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

delay in filing of appeal before CIT (Appeals)/National Faceless Appeal Centre (NFAC) may kindly be condoned and the appeal be directed to be decided on merits or alternatively should be restored back to the Assessing officer (A0) as the assessment order has been passed under section 144 of the Act. 3. The CIT (Appeals)/National Faceless Appeal Centre (NFAC

ASSISTANT COMMISSIONER OF INCOME TAX, DELHI vs. PREM CHAND PRAVESH KUMAR, DELHI

In the result, the Cross Objection of the assessee is allowed and appeal of the revenue is dismissed

Bench: Shri M. Balaganesh & Shri Sudhir Kumaracit, Vs. Prem Chand Pravesh New Delhi Kumar, (Through Erstwhile Partner Sanchit Garg), 292, Katra Peran, Tilak Bazar, Delhi- 110006 (Appellant) (Respondent) Pan: Aajfp9925A Co No. 120/Del/2025 (In Ita No. 736/Del/2025) (Assessment Year: 2014-15) Prem Chand Pravesh Vs. Acit, Kumar, (Through New Delhi Erstwhile Partner Sanchit Garg), 292, Katra Peran, Tilak Bazar, Delhi- 110006 (Appellant) (Respondent) Pan: Aajfp9925A Assessee By : Shri Ved Jain, Adv Shri Pawan Garg, Ca Ms. Ishika Dua, Ca Revenue By: Shri Om Prakash, Sr. Dr Date Of Hearing 08/09/2025 Date Of Pronouncement 10/09/2025

condone the delay and admit the Cross Objection of the assessee for adjudication. 3. The Ground No. 2 raised by the assessee is challenging the validity of assumption of jurisdiction u/s 147 of the Act, wherein, it has been pleaded that the notice u/s 148 of the Act is barred by limitation. This goes to root the matter and hence

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

Appeal is allowed in above terms

148A(d) of the Act is not sustainable.\nConsequently, the subsequent proceedings, including the\nassessment order dated 23.05.2023, cannot be sustained.\nAccordingly, the impugned order passed under Section\n148A(d) of the Act, the notice issued under Section 148 of\nthe Act as well as the assessment order dated 23.05.2023\nand the demand raised pursuant thereto, are hereby set\naside

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

In the result, the appeal of the Assessee is allowed

148A(d)\nissued the notice under section 148 dated 29.07.2022. The\ncontention of the assessee is that the said notice is barred by\nlimitation as per the first proviso to the un-amended provisions of\nsection 149(1) as has been confirmed by the decision of the\nHon'ble Supreme Court in the case of Rajeev Bansal (Supra). The\nrelevant

KIRAN,DELHI vs. ITO WARD-43(1), DELHI, DELHI

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

condoned the delay in filing the appeal, finding reasonable cause. The Tribunal found that the notice under Section 148 was not issued with the proper approval from the Principal Chief Commissioner as required by the amended Section 151(ii) of the Act. Relying on Supreme Court and High Court decisions, the Tribunal held the reassessment action unsustainable.", "result": "Allowed", "sections

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)

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 of the Act, is therefore, held to be invalid. 5. The brief

AJIT BATRA,DELHI vs. ITO, CIVIC CENTER

In the result, the appeal of the revenue is dismissed

Bench: Shri C.N. Prasad & Shri M. Balaganesh[Assessment Year: 2017-18] Ajit Batra, Vs. Ito Shop No.9 Bhagwan Nagar, Civic Center New Delhi South Delhi- 110014 Pan No.Ahlpb5923H Appellant Respondent Assessee By Sh. Naman Gupta, Ca Revenue By Sh. Ajay Kumar Arora, Sr. Dr Date Of Hearing 25.09.2025 Date Of Pronouncement 12.12.2025

148A. Due to this ensuing cascading effect, the filing of appeal was delayed by 38 days and therefore it was prayed that the delay may be condoned. 4. We have heard the rival submissions on the condonation of delay in fling the appeal. Following the Supreme Court decision of Collector, Land Acquisition Vs. MST. Katiji and Others

BRAHAM SINGH,DELHI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT , DELHI

In the result, both the appeals are allowed for statistical purposes

Bench: Shri Pradip Kumar Kedia & Shri Vimal Kumarita No. 4757/Del/2024 Assessment Year: 2014-15 Ita No.4756/Del/2024 Assessment Year: 2016-17 Braham Singh, Vs Assessment Unit, House N0.57, Dhansa . Income Tax Department Raota, South West Delhi Delhi Pin: 1100 73 Delhi. Pan: Fhmps9910M (Appellant) (Respondent)

148A of the Act dated 22.07.2022. Notice under Section 148 was served upon the assessee on 22.7.2022 was issued. Notices under Section 142(1) dated 28.01.2023 and 16.03.2023 were issued but assessee did not respond. Show-cause-notice under Section 144 of the Act dated 26.04.2023 and 09.05.2023 were issued but there was no response by the assessee. On completion

BRAHAM SINGH,DELHI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT, DELHI

In the result, both the appeals are allowed for statistical purposes

Bench: Shri Pradip Kumar Kedia & Shri Vimal Kumarita No. 4757/Del/2024 Assessment Year: 2014-15 Ita No.4756/Del/2024 Assessment Year: 2016-17 Braham Singh, Vs Assessment Unit, House N0.57, Dhansa . Income Tax Department Raota, South West Delhi Delhi Pin: 1100 73 Delhi. Pan: Fhmps9910M (Appellant) (Respondent)

148A of the Act dated 22.07.2022. Notice under Section 148 was served upon the assessee on 22.7.2022 was issued. Notices under Section 142(1) dated 28.01.2023 and 16.03.2023 were issued but assessee did not respond. Show-cause-notice under Section 144 of the Act dated 26.04.2023 and 09.05.2023 were issued but there was no response by the assessee. On completion

AVA RESOURCES PRIVATE LIMITED,NEW DELHI vs. DCIT CENTRAL 1(1), NEW DELHI

In the result, the Appeal of the Assessee is partly allowed for

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ita No. 3401/Del/2024, (A.Y.2019-20)

condoning the delay in filing the Appeal of 35 days despite the Assessee submitting in response to deficiency letter issued by the NFAC that delay in filing of appeal was on account of initial advice of a senior counsel to file a writ before the Hon'ble Delhi High Court which writ was withdrawn on the advice of the High