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

OPAL BUILDWELL P.LTD,DELHI vs. ACIT, CENTRAL CIRCLE-2, NEW DELHI

In the result, appeal filed by the Revenue in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar Us

149 subject to provision to section 150(2) of the Act. Aggrieved by the said direction made by the ld CIT(A) for AY 2009-10 and 2010-11, the assessee has preferred appeals by challenging the direction issued by the ld CIT(A) issued u/s 150(1) of the Act in ITA No. 1557 and 1558/Del/2019 and 2829/Del/2019

OPAL BUILDWELL P.LTD,DELHI vs. ACIT, CENTRAL CIRCLE-2, NEW DELHI

In the result, appeal filed by the Revenue in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar Us

149 subject to provision to section 150(2) of the Act. Aggrieved by the said direction made by the ld CIT(A) for AY 2009-10 and 2010-11, the assessee has preferred appeals by challenging the direction issued by the ld CIT(A) issued u/s 150(1) of the Act in ITA No. 1557 and 1558/Del/2019 and 2829/Del/2019

ACIT, CENTRAL CIRCLE-2, NEW DELHI vs. OPAL BUILDWELL P.LTD, DELHI

In the result, appeal filed by the Revenue in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar Us

149 subject to provision to section 150(2) of the Act. Aggrieved by the said direction made by the ld CIT(A) for AY 2009-10 and 2010-11, the assessee has preferred appeals by challenging the direction issued by the ld CIT(A) issued u/s 150(1) of the Act in ITA No. 1557 and 1558/Del/2019 and 2829/Del/2019

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

In the result, the appeal of the Assessee is allowed

Delay condoned,\nHaving regard to the concession made by the petitioner\nDepartment in the case of Union of India v. Rajeev Bansal, Civil\nAppeal No. 8629 of 2024 on 03.10.2024 (2024 SCC ONLINE 754),\nthis Special Leave Petition would not survive for further\nconsideration.\nHence, the Special Leave Petition is dismissed.\nPending application (s), if any, shall stand disposed

SRD MANAGEMENT COMPANY,NEW DELHI vs. DCIT, CIRCLE-22(2), NEW DELHI

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Kul Bharat & Dr. B.R.R.Kumar[Assessment Year : 2012-13] Srd Management Company, Vs Dcit, 304, 3Rd Floor, 44 Deenar Circle-22(2), Bhawan, Nehru Place, New Delhi. New Delhi-110019. Pan-Aamcs3799K Appellant Respondent Appellant By Shri Bawa Kanwarjit Singh, Ca Respondent By Shri Om Parkash, Sr.Dr Date Of Hearing 01.08.2023 Date Of Pronouncement 07.08.2023

149) and MadhuDadha (Madras 317 ITR 458) it has been held that party has to show reason for delay on the last date of limitation period and thereafter for each day. Further, condonation of delay is not a matter of right. Court has to exercise the discretionary Jurisdiction. 6 Whether the inordinate delay was not due to negligence and inaction

ACIT, CIRCLE-26(2), NEW DELHI vs. VIKRAM ELECTRIC EQUIPMENT P.LTD, NEW DELHI

The appeal of the Revenue is dismissed as\ninfructuous

delayed, but the delay was condoned. The core issue revolves around the validity of the notice issued under Section 148 of the Income Tax Act for reassessment.", "held": "The Tribunal held that the notice under Section 148 of the Income Tax Act was not validly served on the assessee due to being sent to a wrong address and improper affixture

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

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

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

149 of the Act. since they are within the period\nof three years from the end of the relevant assessment year. Specified\nauthority under section 151 of the new law in this case shall be the\nauthority prescribed under clause (i) of that section.\n7.0 Cases where the Assessing Officer is required to provide the information\nand material relied upon

INTERNATIONAL COMMISSION ON IRRIGATION AND DRAINAGE EMPLOYEES PROVIDENT FUND (ICID PF TRUST),NEW DELHI vs. COMMISSIONER OF INCOME TAX (APPEALS), DELHI

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

Bench: Shri Anubhav Sharma & Shri Avdhesh Kumar Mishra

condonation of delay for filing revised ITRs with rider that the assessee’s refund claim cannot be entertained after 6 years. In such a situation where the Revenue is not considering overall facts of the case and decide the matter on merit, the only recourse available to the assessee is to file appeal before the Tribunal. 11. We further

INTERNATIONAL COMMISSION ON IRRIGATION AND DRAINAGE EMPLOYEES PROVIDENT FUND (ICID PF TRUST),NEW DELHI vs. COMMISSIONER OF INCOME TAX (APPEALS), DELHI

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

Bench: Shri Anubhav Sharma & Shri Avdhesh Kumar Mishra

condonation of delay for filing revised ITRs with rider that the assessee’s refund claim cannot be entertained after 6 years. In such a situation where the Revenue is not considering overall facts of the case and decide the matter on merit, the only recourse available to the assessee is to file appeal before the Tribunal. 11. We further

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-17, DELHI, DELHI vs. ASHWANI KUMAR GUPTA, LUCKNOW

In the result, both the Revenue appeals stand dismissed

Bench: Sh. M Balaganesh & Sh. Sudhir Kumar & Dcit, Central Circle-17, Vs. Ashwani Kumar Gupta, Delhi Gokhley Marg Room No. 244, Ara Lucknow Centre, Jhandewalan Uttar Pradesh-226001 Extension, New Delhi

condoned the delay in filing the appeal and admit the appeal for adjudication. 3. Briefly stated, facts are that in this case, the assessee filed his original return of income on 19.09.2012 declaring income of Rs. 93,64,400/-. A search and seizure operation u/s. 132 of the Income Tax Act, 1961 was carried out on 18.10.2019 in the case

DCIT, CENTRAL CIRCLE-17, DELHI vs. ASHWANI KUMAR GUPTA, LUCKNOW

In the result, both the Revenue appeals stand dismissed

Bench: Sh. M Balaganesh & Sh. Sudhir Kumar & Dcit, Central Circle-17, Vs. Ashwani Kumar Gupta, Delhi Gokhley Marg Room No. 244, Ara Lucknow Centre, Jhandewalan Uttar Pradesh-226001 Extension, New Delhi

condoned the delay in filing the appeal and admit the appeal for adjudication. 3. Briefly stated, facts are that in this case, the assessee filed his original return of income on 19.09.2012 declaring income of Rs. 93,64,400/-. A search and seizure operation u/s. 132 of the Income Tax Act, 1961 was carried out on 18.10.2019 in the case

DHARAMVIR KHOSLA ,. vs. DCIT CC-5, NEW DELHI , .

The appeals are allowed for statistical purposes and ld

condonation of delay since assessee's application for rectification of the\nintimation under section 143(1) of the Act has been filed within time and same is\npending disposal. With the above said observation, the grounds of the assessee are\nrejected.\nPage | 11\nITA Nos. 3976 & 3977/Del/2025\nDharamvirKhosla (AY: 2019-20 & 2020-21)\n9.\nHowever, what is material is that

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

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

MOHD. ALAM QUERSHI,MORADABAD vs. ITO WARD-1(1), MORADABAD

In the result, the appeal of the assesse is allowed

Bench: Shri Mahavir Singh & Shri Manish Agarwalmohd. Alam Quershi, Income Tax Officer, 0, Gol Kothi, Depduty Ganj, Ward-1(1), Moradabad-244001, Vs. Moradabad. Uttar Pradesh. Pan-Aadpq4002B (Appellant) (Respondent) Assessee By Shri Neeraj Jain, Ca & Shri P.K. Mishra, Ca Department By Shri Manish Gupta, Sr. Dr 19.11.2025 Date Of Hearing Date Of Pronouncement 19.11.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A) In Short], Dated 17.02.2025 In Appeal No. Nfac/2014-15/10282979 Arising Out Of The Assessment Order Passed U/S 147 R.W.S. 144 Dated 19.05.2023 For Assessment Year 2015-16. 2. Brief Facts Of The Case Are That Case Of The Assessee Was Reopened On The Basis Of Information Received That There Were Larger Credits In The Bank Account Of The Assessee & There Is Mismatch In The Income Declared By The Assessee & Credits In The Bank Account & Accordingly, Notice U/S 148 Was Issued On 06.04.2021. Mohd. Alam Qureshi Vs. Ito Thereafter, In Terms Of The Order Of Hon’Ble Supreme Court In The Case Of Union Of India Vs. Ashish Agarwal & Ors. In Civil Appeal No. 3005/2002, The Said Notice Was Treated As Notice U/S 148A(2) Of The Act. After Passing The Order U/S 148A(D) Of The Act, A Fresh Notice U/S 148 Was Issued On 29.07.2022. In Response, The Assessee Filed The Return On 28.08.2022 Declaring Total Income Of Rs. 3,90,230/-. The Assessment Was Completed U/S 147 R.W.S. 144B At An Income Of Rs. 58,64,382/- By Making Addition Of Rs. 54,74,132/-.

condoned the delay in the instant appeal and admit the same for adjudication. 6. Before us, ld. AR for the assessee submits that first notice for reopening u/s 148 of the Act was issued on 06.04.2021 and thereafter in terms of the procedure laid down by the Hon’ble Supreme Court in the case of Union of India vs. Ashish

PUSHPANJALI CONSTRUCTIONS PRIVATE LIMITED,PUSHPANJALI PALACE,DEHLI GATE,AGRA vs. DCIT, CEN CIR GHAZIABAD

In the result appeal filed by the assessee is partly allowed

condone the delay in filing the appeal\nbefore the Tribunal.\n4.\nGround Nos.1, 9 and 11 are general in nature, hence not adjudicated. At\nthe time of hearing, ld. AR of the assessee has not pressed Ground Nos.2,\n3, 7 & 8, relating to initiation of proceedings u/s 153C and DIN issues\nhence the same are dismissed as not pressed

INCOME TAX OFFICER, WARD-14(3), NEW DELHI vs. KOLAHAI INFOTECH PRIVATE LIMITED , NEW DELHI

In the result the appeal of the Revenue is dismissed

Bench: Shri Sudhir Kumar & Shri Manish Agarwalassessment Year: 2015-16 Income Tax Officer, Vs. Kolahai, Infotech Private Limited Ward-14(3) , Room 129, First Floor Transport Centre No.305 Cr Building I.P. Punjabi Bagh New Delhi, Delhi- Estate New Delhi -110002 110034

section 149(1)(b) of the Act, and time limit is 31-03-2026 as per the new regime. 5. Ld. AR of the assessee submitted that the impugned proceedings is barred by limitation in view of the judgment dated 03-10-2024 rendered by Hon’ble Supreme Court in the case of union Of India and others vs. Rajeev