NKG INFRASTRUCTURE LTD.,NEW DELHI vs. PR.CIT, C- 3 , NEW DELHI

In the result all the three appeals of the assessee are allowed

Bench: Shri G.D. Agrawal, Hon’Ble & Shri K.Narasimha Chary

153-B of the Act. 15. Basing on this, the Ld. AR submits that the assessment order in this case is barred by limitation and is non-est in the eye of law. Taking forward this argument and placing reliance on the decision of the Hon’ble Apex Court 9 reported in Kiran Singh & Ors. V. Chaman Paswan

NKG INFRASTRUCTURE LTD.,NEW DELHI vs. PR.CIT, C- 3 , NEW DELHI

In the result all the three appeals of the assessee are allowed

Bench: Shri G.D. Agrawal, Hon’Ble & Shri K.Narasimha Chary

153-B of the Act. 15. Basing on this, the Ld. AR submits that the assessment order in this case is barred by limitation and is non-est in the eye of law. Taking forward this argument and placing reliance on the decision of the Hon’ble Apex Court 9 reported in Kiran Singh & Ors. V. Chaman Paswan

HITACHI ASTEMO HARYANA PRIVATE LIMITED,FARIDABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, DELHI

In the result, the Appeal of the Assessee is allowed

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.Hitachi Astemo Haryana Private Vs Assistant Commissioner Limited Of Income Tax, Circle Plot No. 23-32, Sector-58, 10(1), C. R. Building, Behind Jcb India Ltd, Ito, Ip Estate, Faridabad, Haryana, India New Delhi Pan: Aabce5725G Appellant Respondent Assessee By Ms. Ananya Kapoor, Adv Revenue By Sh. S. K. Jadhav, Cit- Dr Date Of Hearing 06/08/2025 Date Of Pronouncement 03 /09/2025 Order Per Yogesh Kumar, U.S. Jm: This Appeal Is Filed By The Assessee Pertaining To Assessment

3) r.w. Section 254 of the Income Tax Act, 1961 ('Act' for short). 2. The grounds of Appeal are as under:- “GENERAL GROUNDS 1. On the facts and circumstances of the case and in law, the assessment order giving effect to Hon'ble ITAT's direction has been issued beyond the statutory timeline prescribed under Section 153

DCIT, NEW DELHI vs. M/S. NATIONAL BUILDING CONSTRUCTION CORPORATION LTD.,, NEW DELHI

In the result, all the appeals filed by the Revenue are dismissed and the

Bench: Shri Inturi Rama Rao & Shri Sudhanshu Srivastava

depreciation of Rs.12,74,14,023/- subject to verification of the figures as shown by the appellant company in the chart with the departmental records. As a result, the appeal filed by the assesse is partly allowed in the aforesaid manner.” Being aggrieved by the above order, the Revenue is before us with the present appeals. 3. The grievance

DCIT, NEW DELHI vs. M/S. NATIONAL BUILDING CONSTRUCTION CORPORATION LTD.,, NEW DELHI

In the result, all the appeals filed by the Revenue are dismissed and the

Bench: Shri Inturi Rama Rao & Shri Sudhanshu Srivastava

depreciation of Rs.12,74,14,023/- subject to verification of the figures as shown by the appellant company in the chart with the departmental records. As a result, the appeal filed by the assesse is partly allowed in the aforesaid manner.” Being aggrieved by the above order, the Revenue is before us with the present appeals. 3. The grievance

DCIT, NEW DELHI vs. M/S. NATIONAL BUILDING CONSTRUCTION CORPORATION LTD.,, NEW DELHI

In the result, all the appeals filed by the Revenue are dismissed and the

Bench: Shri Inturi Rama Rao & Shri Sudhanshu Srivastava

depreciation of Rs.12,74,14,023/- subject to verification of the figures as shown by the appellant company in the chart with the departmental records. As a result, the appeal filed by the assesse is partly allowed in the aforesaid manner.” Being aggrieved by the above order, the Revenue is before us with the present appeals. 3. The grievance

DCIT, NEW DELHI vs. M/S. NATIONAL BUILDING CONSTRUCTION CORPORATION LTD.,, NEW DELHI

In the result, all the appeals filed by the Revenue are dismissed and the

Bench: Shri Inturi Rama Rao & Shri Sudhanshu Srivastava

depreciation of Rs.12,74,14,023/- subject to verification of the figures as shown by the appellant company in the chart with the departmental records. As a result, the appeal filed by the assesse is partly allowed in the aforesaid manner.” Being aggrieved by the above order, the Revenue is before us with the present appeals. 3. The grievance

DCIT, NEW DELHI vs. M/S. NEW DELHI TELEVISION LTD., NEW DELHI

Bench: Shri H. S. Sidhu & Shri Prashant Maharishinew Delhi Television Ltd, Vs. Acit, 207, Okhla Industrial Estate, Phase- Circle-13(1), Iii, New Delhi New Delhi Pan: Aaacn0865D (Appellant) (Respondent) Acit, Vs. New Delhi Television Ltd, Circle-13(1), 207, Okhla Industrial Estate, New Delhi Phase-Iii, New Delhi Pan: Aaacn0865D (Appellant) (Respondent)

153 (4) (vii) read with the first proviso. Information was sought with respect to the corporate guarantee fee, if any paid by NDTV Network Plc to the appellant with respect to the raising of hundred millions of advance during the year in question by the NDTV Network plc in United Kingdom. A separate reference on sale of shares

M/S. NEW DELHI TELEVISION LTD.,NEW DELHI vs. ACIT, NEW DELHI

Bench: Shri H. S. Sidhu & Shri Prashant Maharishinew Delhi Television Ltd, Vs. Acit, 207, Okhla Industrial Estate, Phase- Circle-13(1), Iii, New Delhi New Delhi Pan: Aaacn0865D (Appellant) (Respondent) Acit, Vs. New Delhi Television Ltd, Circle-13(1), 207, Okhla Industrial Estate, New Delhi Phase-Iii, New Delhi Pan: Aaacn0865D (Appellant) (Respondent)

153 (4) (vii) read with the first proviso. Information was sought with respect to the corporate guarantee fee, if any paid by NDTV Network Plc to the appellant with respect to the raising of hundred millions of advance during the year in question by the NDTV Network plc in United Kingdom. A separate reference on sale of shares

ANAND KUMAR JAIN,NEW DELHI vs. DCIT, CENTRAL CIRCLE- 25, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

3. At the time of hearing, Ld. Counsel for the assessee has only argued on legal issue relating to validity of assessment framed by the Assessing Officer u/s. 153A of the I.T. Act, 1961 which is in contravention of the provisions of section 153C of the I.T. Act where no incriminating material was found from the search operation conducted

ANAND KUMAR JAIN,FARIDABAD vs. DCIT, CENTRAL CIRCLE-25, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

3. At the time of hearing, Ld. Counsel for the assessee has only argued on legal issue relating to validity of assessment framed by the Assessing Officer u/s. 153A of the I.T. Act, 1961 which is in contravention of the provisions of section 153C of the I.T. Act where no incriminating material was found from the search operation conducted

ANAND JAIN HUF,NEW DELHI vs. DCIT, CENTRAL CIRCLE- 25, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

3. At the time of hearing, Ld. Counsel for the assessee has only argued on legal issue relating to validity of assessment framed by the Assessing Officer u/s. 153A of the I.T. Act, 1961 which is in contravention of the provisions of section 153C of the I.T. Act where no incriminating material was found from the search operation conducted

ANAND KUMAR JAIN,NEW DELHI vs. DCIT, CENTRAL CIRCLE- 25, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

3. At the time of hearing, Ld. Counsel for the assessee has only argued on legal issue relating to validity of assessment framed by the Assessing Officer u/s. 153A of the I.T. Act, 1961 which is in contravention of the provisions of section 153C of the I.T. Act where no incriminating material was found from the search operation conducted

SAJAN KUMAR JAIN,DELHI vs. DCIT,CENTRAL CIRCLE-25, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

3. At the time of hearing, Ld. Counsel for the assessee has only argued on legal issue relating to validity of assessment framed by the Assessing Officer u/s. 153A of the I.T. Act, 1961 which is in contravention of the provisions of section 153C of the I.T. Act where no incriminating material was found from the search operation conducted

ANAND JAIN HUF,NEW DELHI vs. DCIT, CENTRAL CIRCLE- 25, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

3. At the time of hearing, Ld. Counsel for the assessee has only argued on legal issue relating to validity of assessment framed by the Assessing Officer u/s. 153A of the I.T. Act, 1961 which is in contravention of the provisions of section 153C of the I.T. Act where no incriminating material was found from the search operation conducted

SATISH DEV JAIN,DELHI vs. DCIT, CENTRAL CIRCLE-25, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

3. At the time of hearing, Ld. Counsel for the assessee has only argued on legal issue relating to validity of assessment framed by the Assessing Officer u/s. 153A of the I.T. Act, 1961 which is in contravention of the provisions of section 153C of the I.T. Act where no incriminating material was found from the search operation conducted

KUNSHAN Q TECH MICROELECTRONICS (INDIA) PVT. LTD.,UTTAR PRADESH vs. DCIT, CENTRAL CIRCLE-30, DELHI

153 r.w.s. 144C of the Act and hence, void-ab-initio, therefore, needs to be quashed/ annulled.\n4. That on the facts, law and in the circumstances of the case, the Ld. AO, Ld. TPO as well as the Ld. DRP have erred in law in framing a high-pitched assessment u/s 143(3) r.w.s. 144C

ADDL. CIT, NEW DELHI vs. M/S. IRCON INTERNATIONAL LTD., NEW DELHI

In the result, the appeal of the Revenue is accordingly dismissed

Bench: Shri Amit Shukla & Shri O.P. Kant[Through Video Conferencing]

3) of the Act, has been reopened within four years from the end of the relevant assessment year. Therefore, issue in dispute before us is that in what circumstances assessment can be reopened within the period of four years from the end of the relevant assessment year. This issue has been discussed and adjudicated by Hon’ble High Court