DIRECTOR OF INCOME TAX (EXEMPTION) vs. VISHWA JAGRITI MISSION

condoning the delay. 24. On the question of perversity of the decision of the Tribunal we may also refer to the judgment of the Supreme Court in Sree Meenakshi Mills Ltd. v. CIT, (1957) 31 ITR 28. In that judgment, it was noted that only a question of law can be referred for decision of the Court and the decision

DIRECTOR OF INCOME TAX (EXEMPTION) vs. VISHWA JAGRITI MISSION

condoning the delay. 24. On the question of perversity of the decision of the Tribunal we may also refer to the judgment of the Supreme Court in Sree Meenakshi Mills Ltd. v. CIT, (1957) 31 ITR 28. In that judgment, it was noted that only a question of law can be referred for decision of the Court and the decision

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.

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

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)

section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case files perused. 2. For the reasons stated in the assessee’s condonation averments, delay of 283 days in filing of instant appeal is hereby condoned in light of Collector, Land & Acquisition vs. Mst. Katiji & Others

ACIT, CC-14, DELHI vs. LAKSHYA CONSULTANTS PVT. LTD., NEW DELHI

In the result, the appeal of the Revenue in ITA No

Bench: Shri N.K. Billaiya & Shri Yogesh Kumar U.S

Section 5 Limitation Act have to receive liberal construction, but the court cannot ignore the fact that where an appeal gets barred by time, a definite right accrues to the opposite party and such right should not be taken away in a routine manner without disclosure of good and a sufficient cause for condonation of delay. 5.8 As regards

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

section 143(1) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Case called twice. None appears at the assessee’s behest. He is accordingly proceeded ex-parte. 2. 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

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

In the result, appeal of the assessee is allowed

Bench: Sh. Satbeer Singh Godara

section 28 of Land Acquisition Act, it can at best be said to be a debatable issue on which two views are possible and the Ld. AO accepts one of the views. In this view of the matter too, the Ld. PCIT cannot assume revisional jurisdiction as held by the Hon'ble Delhi High Court in CIT vs. Hindustan Coca

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

ACIT, NEW DELHI vs. M/S. CONTAINER CORPORATION OF INDIA LTD., NEW DELHI

In the result ITA No. 1364/Del/2012 for AY 2007-08 filed by the revenue is dismissed

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

condoning the delay of 585 and 502 days delay in both these appeals. ACIT, Vs. Container Cooperation of India Ltd ITA No. 1555/Del/2012, 1363/Del/2012, 3960/Del/2010 and 1364/Del/2012 Assessment Year: 2006-07 and 2007-08 9. Now coming on the merits of the case we first take up the appeal of the revenue in ITA NO. 1363/Del/2012 for Assessment Year

DEPUTY COMMISSIONER OF INCOME TAX, CR BUILDING vs. PC JEWELLER LIMITED, DELHI

Bench: Ms. Madhumita Roy & Shri Khettra Mohan Roy

Section 35D of the Act appeal was filed. 2.3 Consequently, the appellant appealed before Ld. CIT-(A) on 07- 11-2020 and hence, the delay of 4 years and 3 months (1537 days). The period of delay is tabulated as under:- Sl. No. Particulars Date Period of delay 1 Date of receipt of Intimation | 24-07-2016 issued

ACIT, NEW DELHI vs. SH. D.K. JAIN, NEW DELHI

In the result, appeal of the revenue is dismissed

Bench: Sh. Bhavnesh Saini & Sh. L. P. Sahuacit D. K. Jain Circle – 32(1) D-19, Nazamuddin East, New Delhi Vs. New Delhi

28 taxmann.com 210 held as under: “IT: Delay of 557 days in filing appeal by revenue taking ground of oversight and pressure of workload is found to be neither reasonable nor sufficient ground and, therefore, condonation of such delay is rightfully denied”. D) In the case of Hind Development Corpn. v. ITO [1979] 118 ITR 873, the Calcutta High Court

ADDL. CIT, SPECIAL RANGE- 6, NEW DELHI vs. NEC TECHNOLOGIES INDIA PVT. LTD., NEW DELHI

Bench: Shri Ramit Kochar & Shri Sudhir Pareek

section 253(3A) of the Act, the limitation for filing appeal before this Hon'ble Tribunal expire on 21.02.2015 and therefore, the present accompanying appeal is delayed by 1021 days. 4) The matter regarding filing of appeal in the impugned case for AY 2010-11 got missed due to the reason for this omission are as follows:-oversight which

ACIT, NEW DELHI vs. M/S ALANKAR SAPHIRE DEVELOPERS PVT. LTD.,, NEW DELHI

In the result, appeal of the Assessee allowed and appeal of the Department dismissed

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

delay of 20 days condoned by the Ld. CIT(A) in filing the appeal before him, violation of Rule 46A, allowing the grounds of appeal of assessee qua the jurisdiction to make the additions under section 153A in the absence of recovery of any incriminating material and additions deleted on merits. 49 ITA.No.2277/Del./2016 etc., batch M/s. Alankar Saphire

ACIT, NEW DELHI vs. M/S PEGASUS SOFTECH PVT. LTD.,, NEW DELHI

In the result, appeal of the Assessee allowed and appeal of the Department dismissed

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

delay of 20 days condoned by the Ld. CIT(A) in filing the appeal before him, violation of Rule 46A, allowing the grounds of appeal of assessee qua the jurisdiction to make the additions under section 153A in the absence of recovery of any incriminating material and additions deleted on merits. 49 ITA.No.2277/Del./2016 etc., batch M/s. Alankar Saphire

M/S. ALANKAR SAPHIRE DEVELOPERS,NEW DELHI vs. DCIT, NEW DELHI

In the result, appeal of the Assessee allowed and appeal of the Department dismissed

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

delay of 20 days condoned by the Ld. CIT(A) in filing the appeal before him, violation of Rule 46A, allowing the grounds of appeal of assessee qua the jurisdiction to make the additions under section 153A in the absence of recovery of any incriminating material and additions deleted on merits. 49 ITA.No.2277/Del./2016 etc., batch M/s. Alankar Saphire

ACIT, NEW DELHI vs. M/S WITNESS CONSTRUCTIONS PVT. LTD.,, NEW DELHI

In the result, appeal of the Assessee allowed and appeal of the Department dismissed

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

delay of 20 days condoned by the Ld. CIT(A) in filing the appeal before him, violation of Rule 46A, allowing the grounds of appeal of assessee qua the jurisdiction to make the additions under section 153A in the absence of recovery of any incriminating material and additions deleted on merits. 49 ITA.No.2277/Del./2016 etc., batch M/s. Alankar Saphire

M/S. ALANKAR SAPHIRE DEVELOPERS,NEW DELHI vs. DCIT, NEW DELHI

In the result, appeal of the Assessee allowed and appeal of the Department dismissed

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

delay of 20 days condoned by the Ld. CIT(A) in filing the appeal before him, violation of Rule 46A, allowing the grounds of appeal of assessee qua the jurisdiction to make the additions under section 153A in the absence of recovery of any incriminating material and additions deleted on merits. 49 ITA.No.2277/Del./2016 etc., batch M/s. Alankar Saphire