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

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

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

Appeal is allowed in above terms

2. In each of these cases, the challenges to a notice\nissued by the Income- tax Department (hereinafter\n“Department”) under section 148 of the Income-tax Act,\n1961, (IT Act) as it stood prior to the amendment by the\nFinance Act of 2021 with effect from April 1, 2021. In\nother words, in each of these cases, the notice

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

The appeals of the assessee are partly allowed

Bench: Shri Satbeer Singh Godara\Nand\Nshri Brajesh Kumar Singh\Nita Nos.1808/Del/2023 & 2983, 2984 & 2985/Del/2015\N[Assessment Years: 2004-05, 2005-06, 2006-07 & 2007-08]\Nshri Chetan Seth,\Nplot No.14, Lcs, Sector-B-1,\Nvasant Kunj,\Nnew Delhi-110070\Npan-Aolps2992A\Nappellant\Nincome Tax Officer,\Nward-15(3),\Nvs New Delhi\Nrespondent\Nappellant By\Nrespondent By\Nshri Arun Kishore, Ca &\Nshri Alok Suri, Ca\Nshri Rajesh Kumar Dhanesta, Sr.\N(Dr)\Ndate Of Hearing\Ndate Of Pronouncement\N28.03.2025\N25.06.2025\Norder\Nper Brajesh Kumar Singh, Am,\Nthese Four Appeals Filed By The Assessee Are Directed Against The\Norder Of Ld. Commissioner Of Income Tax (Appeals)-7, Delhi, Dated\N24.02.2015 For Ay 2004-05, 27.02.2015 For Ay 2005-06, 2006-07 And\N2007-08 Respectively Arising Out Of Assessment Orders Passed U/S 147/144\Nof The Income Tax Act, 1961 (Hereinafter Referred To ‘The Act') Dated\N31.10.2011 For All The Above Assessment Years, Respectively. Since, The\Nissues Are Common & Connected, Hence, These Appeals Were Heard\Ntogether & Are Disposed Of By This Common Order.\N2. First, We Shall Take Up The Ita No.1808/Del/2023 Pertaining To Ay\N2004-05.\N2.

sections": [ "147", "144", "2(22)(e)", "148", "151", "127", "129", "234A", "234B", "234D", "244A", "143(1)", "143(3)", "153", "154", "155", "150(1)", "150(2)" ], "issues": "1. Condonation of delay

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

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

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, GHAZIABAD vs. RITU CANSAL, GHAZIABAD

delay in filing the cross-objection was condoned.", "result": "Partly Allowed", "sections": [ "147", "148", "148A", "151", "151(i)", "151(ii)", "151(1)", "151(2

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

CIT vs. CREATIVE TRAVEL PVT LTD

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE R.V.EASWAR

2 of 8 Section 151 CPC for condonation of delay of 66 days in re-filing the petition. The only

MR. NIKHIL SAWHNEY,NEW DELHI vs. ACIT, NOIDA

In the result, appeal of the assessee is dismissed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishimr. Nikhil Sawhney Acit, 17 – Sunder Nagar, Central Circle, Vs. New Delhi – 110 003. Noida. Pan: Aaups0222Q (Appellant) (Respondent)

condone the delay admitting the appeal of the assessee and proceed to decide the issue on merits. 08. Facts of case in a narrow compass shows that assessee filed his return of income on 31 August 2012 declaring total income of Rs. 167,09,146 which was subsequently revised on 25th of March 2014 declaring same

CIT vs. MOUNTAIN TOUCH BUILDERS P. LTD

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE R.V.EASWAR

Section 151 CPC for condonation of delay of 66 days in re-filing the petition. The only ground for such delay stated in the application is that the petition was returned under defect on 11.01.2012 and was refilled on 10.02.2012 as on the petition some documents were to be re-typed which OMP No.388/2012 Page 2

DY. COMMISSIONER OF INCOME TAX, NOIDA vs. M/S RUDRA BUILDWELL HOMES PVT. LTD, DELHI

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2016-17 Vs. M/S. Rudra Buildwell Homes Dcit, Central Circle-I, Noida Pvt. Ltd., 53, Okhla Phase, Delhi Pan: Aafcr6959P (Appellant) (Respondent) With C.O. No.106/Del/2025 [Arising Out Of Ita No.602/Del/2025] Assessment Year: 2016-17 M/S. Rudra Buildwell Vs. Dcit, Central Circle-I, Homes Pvt. Ltd., Noida A-66, Sector-63, Noida Pan: Aafcr6959P (Appellant) (Respondent) Assessee By Sh. Rohit Kapoor, Adv. Sh. Veersen Agarwal, Itp Department By Sh. Rajesh Chandra, Cit(Dr) Date Of Hearing 12.08.2025 Date Of Pronouncement 29.08.2025 Order Per Satbeer Singh Godara, Jm This Revenue’S Appeal Ita No.602/Del/2025 & Assessee’S Cross Objection C.O. No. 106/Del/2025 For Assessment Year 2016-

delay of 10 days in filing of instant cross objection is hereby 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/reassessment itself as the learned lower authorities have set into motion

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

151 of WP 17.06.2019 Annexure P- 10 on pg. 329 of WP 17.06.2019 Annexure P-10 on pg. 233 of WP 17.06.2019 Annexure P-12 on pg. 299 of WP 11 Response to sec 274 notice dated 17.06.2019 filed by the Petitioner before AO 27.06.2019 Annexure P-13 on pg. 206 of WP 28.06.2019 Annexure

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

151 of WP 17.06.2019 Annexure P- 10 on pg. 329 of WP 17.06.2019 Annexure P-10 on pg. 233 of WP 17.06.2019 Annexure P-12 on pg. 299 of WP 11 Response to sec 274 notice dated 17.06.2019 filed by the Petitioner before AO 27.06.2019 Annexure P-13 on pg. 206 of WP 28.06.2019 Annexure

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MARUTI SUZUKI INDIA LTD.

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

151 of WP 17.06.2019 Annexure P- 10 on pg. 329 of WP 17.06.2019 Annexure P-10 on pg. 233 of WP 17.06.2019 Annexure P-12 on pg. 299 of WP 11 Response to sec 274 notice dated 17.06.2019 filed by the Petitioner before AO 27.06.2019 Annexure P-13 on pg. 206 of WP 28.06.2019 Annexure

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