COMMISSIONER OF INCOME TAX (EXEMPTIONS) DELHI vs. SERVANTS OF PEOPLE SOCIETY

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MR. JUSTICE NAVIN CHAWLA

17. Proper officer can therefore reject the declared transactional value based on ―certain reasons‖ to doubt the truth or accuracy of the declared value in which event the proper officer is entitled to make assessment as per Rules 4 to 9 of the 2007 Rules. What is meant by the expression ―grounds for doubting the truth or accuracy

CIT vs. GS PHARMBUTOR PVT LTD

The appeal is allowed to the aforesaid extent

Bench: HON'BLE MR. JUSTICE BADAR DURREZ AHMED,HON'BLE MR. JUSTICE R.V.EASWAR

17. It was further contended on behalf of the appellant that the revocation of the passport of the appellant has seriously impacted the fundamental rights of the appellant under Article 19(1)(a) and 19(1)(g) of the Constitution inasmuch as the appellant has not been able to travel outside U.K to participate in conferences and discussions and express

PR. COMMISSIONER OF INCOME TAX (CENTRAL)-2 vs. VERSATILE POLYTECH PVT. LTD.

Appeals are dismissed as time barred

Bench: HON'BLE MR. JUSTICE RAJIV SHAKDHER,HON'BLE MR. JUSTICE GIRISH KATHPALIA

IV(1997) CLT 95 (SC). In the said decision, the Supreme Court has held that unless and until a reasonable or satisfactory explanation is given, the inordinate delay should not be condoned. In para 6 of the judgment, the Supreme Court has laid down in the following manner: “Law of Limitation may harshly affect a particular party Digitally Signed

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

BALVINDER SINGH,KARNAL, HARYANA vs. INCOME TAX OFFICER WARD-1, KARNAL, KARNAL ,HARYANA

In the result, appeal of the assessee is allowed

Bench: SHRI SATBEER SINGH GODARA (Judicial Member)

delay of 283 days in filing of instant appeal is hereby condoned in light of Collector, Land & Acquisition vs. Mst. Katiji & Others (1987) 167 ITR 471 (SC). 3. It emerges during the course of hearing that the sole substantive issue between the parties is that of correctness of the learned lower authorities action assessing the assessee’s interest component

DAULAT RAM,REWARI vs. ITO, REWARI (JAO), REWARI

In the result, appeal of the assessee is allowed

Bench: Shri Satbeer Singh Godaraassessment Year: 2017-18 Sh. Daulat Ram, Vs. Income Tax Officer, C/O- Anu Jain & Co., First Rewari (Jao) Floor, Near Palika Complex, Model Town, Rewari Pan: Avppr6711D (Appellant) (Respondent) Assessee By None Department By Sh. Monoj Kumar, Sr. Dr

Delay of 339 days in filing the asseessee’s instant appeal is condoned in larger interest of justice and in light of Collector, Land & Acquisition vs. Mst. Katiji & Others (1987) 167 ITR 471 (SC). 3. It emerges during the course of hearing that the sole substantive issue between the parties is that of correctness of the learned lower authorities action

MAHENDER MALIK,HISAR vs. ITO,WARD -(1), HISAR

In the result, appeal of the assessee is allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2018-19 Sh. Mahender Malik, Vs. Income Tax Officer, 388, Satroad Khurad, Near Ward-1, Adarsh High School, Hisar Hisar Pan: Bitpm5341N (Appellant) (Respondent) Assessee By Ms. Karishma Rathore, Adv. Sh. Mayank Patawari, Adv. Department By Sh. Yogeshwar Sharma, Sr. Dr Date Of Hearing 29.01.2026 Date Of Pronouncement 29.01.2026 Order Per Satbeer Singh Godara, Jm This Assessee’S Appeal For Assessment Year 2018-19, Arises Against The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre [In Short, The “Cit(A)/Nfac”], Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1069269047(1), Dated 30.09.2024 Involving Proceedings Under Section 154 Of The Income- Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). Heard Both The Parties. Case File Perused. 2. For The Reasons Stated In The Assessee’S Condonation Averments, Delay Of 3 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 Emerges During The Course Of Hearing That The Sole Substantive Issue Between The Parties Is That Of Correctness Of The Learned Lower Authorities’ Action Assessing The Assessee’S Interest Component Of Land Acquisition Compensation U/S 28 Of The Land Acquisition Act, 1894, While Invoking Section 57(Iv) R.W.S. 56(1)(A) R.W.S. 145A(B) Of The Act. 4. Learned Sr. Dr Representing The Department Vehemently Argued That The Instant Issue Is No More Res Integra In Light Of Mahender Pal Narang Vs. Cbdt (2020) 423 Itr 13 (P&H) As Well As Pcit Vs. Inderjit Singh Sodhi Huf (2024) 161 Taxmann.Com 301 (Del.) Wherein The Department Has Succeeded Before Their Lordships That The Impugned Interest Component Ought To Be Assessed As Income From “Other” Sources Only.

delay of 3 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 emerges during the course of hearing that the sole substantive issue between the parties is that of correctness of the learned lower authorities’ action assessing the assessee’s interest component

SHASTRI LAL,GURGAON vs. ITO WARD -4(1), GURGAON, GURGAON

In the result, appeal of the assessee is allowed

Bench: Sh. Satbeer Singh Godara

2)(viii) and 57(iv), the nature of interest under section 28 of the 1894 Act will remain that of compensation and decisions of the Hon'ble Supreme Court in the case of Ghanshyam (HUF) and the decision of Hon'ble Gujrat High Court in Movaliya Bhikhubhai Balabhai vs. ITO TDS (2016) 388 ITR 343 were relied upon

COMMISSIONER OF INCOME TAX DELHI-XI vs. INDIAN NATIONAL CONGRESS/ALL INDIA CONGRESS COMMITTEE

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE VIBHU BAKHRU

iv) The Assessee did not fulfil the conditions (a), (b) and (c) under the proviso to Section 13A of the Act and, therefore, the AO was justified in not allowing exemption therein. (v) The reasons given by the AO for making an estimate of receipts from state and other units at Rs. 15 crores was not convincing or satisfactory

INDIAN NATIONAL CONG. (I) AICC vs. C.I.T.- XI

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE VIBHU BAKHRU

iv) The Assessee did not fulfil the conditions (a), (b) and (c) under the proviso to Section 13A of the Act and, therefore, the AO was justified in not allowing exemption therein. (v) The reasons given by the AO for making an estimate of receipts from state and other units at Rs. 15 crores was not convincing or satisfactory

MAWASI,HARYANA vs. COMMISSIONER OF INCOME TAX (APPEALS), DELHI

In the result, appeal of the assessee is allowed

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

Delay of 111 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 ITA No. 5020/Del./2025 Mawasi 4. It emerges during the course of hearing that the sole substantive issue between the parties is that of correctness

GANGA BISHAN,GURGAON vs. ITO WARD 1(3), GURGAON

In the result, appeal of the assessee is allowed

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

Delay of 1 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 ITA No. 2179/Del./2025 Ganga Bishan 4. It emerges during the course of hearing that the sole substantive issue between the parties is that of correctness

INDIAN NATIONAL CONG. (I) AICC vs. C.I.T.- XI

iv) The Assessee did not fulfil the conditions (a), (b) and (c) under the proviso to Section 13A of the Act and, therefore, the AO was justified in not allowing exemption therein. (v) The reasons given by the AO for making an estimate of receipts from state and other units at Rs. 15 crores was not convincing or satisfactory

ACIT, CIRCLE-24(1), NEW DELHI vs. SPRING INFRADEV LTD., NEW DELHI

Bench: Shri Yogesh Kumar Us & Shri Brajesh Kumar Singh[Assessment Year:2016-17]

delay of 1726 days in filing the cross objection is condoned. CO No.118/Del/2024 6. During the hearing before us, the assessee reiterated the above fact of inadvertently offering the above capital gains and submitted that the AO is obligated to assess the correct income relying upon Board Circular No.14 XL-35, dated 11.04.1955. It was further submitted that tax collection