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

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

In the result, appeal of the assessee is allowed

Bench: Sh. Satbeer Singh Godara

56(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

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

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

PR. COMMISSIONER OF INCOME TAX, CENTRAL-1, DELHI vs. SMT. SANGEETA SAWHNEY

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE TEJAS KARIA

VIII) Delay in the delivery of an arbitral award, by itself, is not sufficient to set aside that award. It is only when the effect of the undue delay in the delivery of an arbitral award is explicit and adversely reflects on the findings therein, such delay and, more so, if it remains unexplained, can be construed to result

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

viii) But for Section 13A of the Act, voluntary contributions would not be taxable income since it did not fall under any of the heads of the income under Section 14 of the Act. It would not come under the head ‘income from other sources’. The expenditure incurred by a political party on its political activities was allowable

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

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

viii) But for Section 13A of the Act, voluntary contributions would not be taxable income since it did not fall under any of the heads of the income under Section 14 of the Act. It would not come under the head ‘income from other sources’. The expenditure incurred by a political party on its political activities was allowable

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

viii) But for Section 13A of the Act, voluntary contributions would not be taxable income since it did not fall under any of the heads of the income under Section 14 of the Act. It would not come under the head ‘income from other sources’. The expenditure incurred by a political party on its political activities was allowable

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

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

viii) the period commencing from the date on which an application is made before the Authority for Advance Rulings [or before the Board for Advance Rulings] under sub-section (1) of section Digitally Signed By:KAMLESH KUMAR Signing Date:02.09.2024 17:04:21 Signature Not Verified ITA 52/2023 & other connected matters Page 41 of 74 245Q and ending with

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

viii) the period commencing from the date on which an application is made before the Authority for Advance Rulings [or before the Board for Advance Rulings] under sub-section (1) of section Digitally Signed By:KAMLESH KUMAR Signing Date:02.09.2024 17:04:21 Signature Not Verified ITA 52/2023 & other connected matters Page 41 of 74 245Q and ending with

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

viii) the period commencing from the date on which an application is made before the Authority for Advance Rulings [or before the Board for Advance Rulings] under sub-section (1) of section Digitally Signed By:KAMLESH KUMAR Signing Date:02.09.2024 17:04:21 Signature Not Verified ITA 52/2023 & other connected matters Page 41 of 74 245Q and ending with

DCIT, CIRCLE - 19(1), DELHI vs. PC JEWELLER LIMITED, DELHI

In the result appeals preferred by the revenue are dismissed and the\ncross objections preferred by the assessee are allowed\nOrder pronounced in open court on 06

viii) There is a distinction between inordinate delay and a\ndelay of short duration or fewdays, for to the former doctrine of\nprejudice is attracted whereas to the latter it may not be\nattracted. That apart, the first one warrants strict approach\nwhereas the second calls for a liberal delineation.\n(ix) The conduct, behavior and attitude of a party

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

In the result appeals preferred by the revenue are dismissed and the\ncross objections preferred by the assessee are allowed\nOrder pronounced in open court on 06

viii) There is a distinction between inordinate delay and a\ndelay of short duration or fewdays, for to the former doctrine of\nprejudice is attracted whereas to the latter it may not be\nattracted. That apart, the first one warrants strict approach\nwhereas the second calls for a liberal delineation.\n(ix) The conduct, behavior and attitude of a party

BROOM PUBLICATIONS PVT. LTD.,FARIDABAD vs. ITO WARD 1(2), FARIDABAD

In the result, the appeal of the assessee on this ground is allowed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Delay condoned. 3. The assessee has raised six grounds of appeal. The ld. AR has not pressed ground nos. 1, 4, 5 & 6. Balgopal Publication & Broom Publications Pvt. Ltd. 4. Ground No. 2 relates to addition of Rs.9,00,000/- u/s 68 of the Income Tax Act, 1961. 5. Ground No. 3 relates to enhancement of income by Rs.70

BALGOPAL COLD STORAGES PVT. LTD.,FARIDABAD vs. ITO WARD 1(2), FARIDABAD

In the result, the appeal of the assessee on this ground is allowed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Delay condoned. 3. The assessee has raised six grounds of appeal. The ld. AR has not pressed ground nos. 1, 4, 5 & 6. Balgopal Publication & Broom Publications Pvt. Ltd. 4. Ground No. 2 relates to addition of Rs.9,00,000/- u/s 68 of the Income Tax Act, 1961. 5. Ground No. 3 relates to enhancement of income by Rs.70

DCIT, NEW DELHI vs. SURYA BUILDWELL PVT. LTD., NEW DELHI

In the result cross objection filed by the assessee is allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi

condone the delay as sufficient cause is shown. 8. The Ld. authorized representative submitted that impugned assessment year involved in assessment year 2002-03 for which the return of income was filed by the assessee on 28/10/2002 and such return was processed and assessed under section 143(1) of the Income Tax Act. He further submitted that search took place

DCIT, NEW DELHI vs. SURYA BUILDWELL PVT. LTD., NEW DELHI

In the result cross objection filed by the assessee is allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi

condone the delay as sufficient cause is shown. 8. The Ld. authorized representative submitted that impugned assessment year involved in assessment year 2002-03 for which the return of income was filed by the assessee on 28/10/2002 and such return was processed and assessed under section 143(1) of the Income Tax Act. He further submitted that search took place