KAPLAN INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

The appeal of the assessee is partly allowed

Bench: Shri N.S. Saini & Shri Sudhanshu Srivastavaassessment Year: 2007-08 Kaplan India Pvt. Ltd., Vs Acit, Plot No. 15, Circle-5(1), Okhla Industrial Estate-Iii, New Delhi. New Delhi-110020 (Pan: Aaics9919F) (Appellant) (Respondent) Assessee : S/Shri Nageswar Rao, Sandeep S. Karhail, Adv. Shri Parth, Adv. Department By: Shri Sandeep Kumar Mishra, Sr Dr Date Of Hearing: 23.01.2019 Date Of Pronouncement: 26.03.2019

section 133(6) and disallowance of expenditure towards Group insurance of employees. The Ld. AR submitted that the Ld. CIT (A) upheld

INCOME TAX OFFICER WARD-1 HISAR, HISAR vs. AJAY KUMAR, HISAR

In the result, the appeal filed by the Revenue for AY 2022-23 is dismissed

Section 133(6) of the Income-tax Act, 1961. It is\nrespectfully submitted that such an inference is both legally\nunsustainable and factually flawed, for the following reasons:\ni. Non-response by Third Parties Cannot Lead to any Disallowance

INCOME TAX OFFICER, HISAR vs. AJAY KUMAR, HISAR

In the result, the appeal filed by the Revenue for AY 2022-23 is dismissed

Section 133(6) of the Income-tax Act, 1961. It is\nrespectfully submitted that such an inference is both legally\nunsustainable and factually flawed, for the following reasons:\ni.\nNon-response by Third Parties Cannot Lead to any Disallowance

ASSISTANT COMMISSIONER OF INCOME TAX, NEW DELHI vs. JAIPUR GOLDEN TRANSPORT CO PRIVATE LIMITED, NEW DELHI

In the result, appeal of the Revenue is partly allowed

Bench: Shri Anubhav Sharma& Shri Amitabh Shukla[Assessment Year:2012-13] Assistant Commissioner, Of Jaipur Golden Transport Co. Income Tax, Private Limited, Room No.316A, C.R. Vs 4741, Roshananra Road, Building, I.P Estate, Malkaganj, North Delhi, New New Delhi-110002 Delhi-110007 Pan Aaacj4124B Appellant Respondent Revenue By Shri Om Prakash, Sr. Dr Assessee By Shri Y.K. Mehan, Ca, Shri Dheeraj Kumar, Ca Date Of Hearing 11.12.2025 Date Of Pronouncement 19.12.2025

section 133(6) had not been complied with or details furnished were unsatisfactory and incomplete. Even in cases where replies were received, the Assessing Officer observed discrepancies which the assessee could not reconcile. The Assessing Officer concluded that there was scope for manipulation of expenses booked under this head and proceeded to disallow

ACIT, NEW DELHI vs. M/S. DEVINE INFRACON PVT. LTD., NEW DELHI

Bench: M Balaganesh, Accontant Member & Ms Madhumita Royassessment Year: 2010-11 The Assistant Vs. M/S Divine Infracon Commissioner Of Income Private Limited, Plot Tax, Central Circle-09, No. 4, Sector-13, Jhandewalan, New Delhi, Dwarka City Centre, Room No.357, Ara Centre, Dwarka, New Delhi- E-2, Jhandewalan 110075 Extension, New Delhi Pan :Aaccd4476A (Appellant) (Respondent) Assessee By Shri Salil Aggarwal, Sr, Advocate Department By Shri T James Singson, Cit, Dr

133(6) Shalimar Bagh, Delhi-110088 was directly PAN: AAACV4336K submitted with the learned officer by the lender and is part of the record.(page 225 to 226 of paper book) 5.6 It is thus, submitted that once the lenders have duly confirmed the factum of unsecured loan to the appellant company, addition under section

ACIT, MEERUT vs. M/S. PIONEER FABRICATORS PVT. LTD., MEERUT

In the result ground No. 6 of the appeal of the assessee is allowed

Bench: Shri I.C.Sudhir & Shri Prashant Maharishiacit, Vs. Pioneer Fabricators Pvt. Ltd, Circle-2, Meerut B-2, Saraswati Industrial Estate, Partapur, Meerut Pan:Aabcp3296R (Appellant) (Respondent) Pioneer Fabricators Pvt. Ltd, Acit, Vs. B-2, Saraswati Industrial Estate, Circle-2, Meerut Pioneer Partapur, Meerut Fabricators Pvt. Ltd, Pan:Aabcp3296R B-2, Saraswati Industrial Estate, Partapur, Meerut Pan:Aabcp3296R (Appellant) (Respondent)

section 133(6) of the income tax act to creditors. However, no confirmation could be received and therefore the Ld. assessing officer noted that sundry creditors of Rs. 64985536/- are not confirmed and therefore he made the addition to the total income of the assessee. iv. It was further noted by the assessee that assessee has made payment of interest

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

disallowance on account of payment to suspicious parties, involving some common parties, was made by the AO in AY 2019-20, which was deleted by CITEA) on same reasoning; however, the Revenue has not filed appeal on that issue in that year. Re (ii): Notice(s) under section 133(6

DCIT, CENTRAL CIRCLE-20, DELHI vs. LOTUS HERBALS PVT. LTD, DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

disallowance on account of payment to suspicious parties, involving some common parties, was made by the AO in AY 2019-20, which was deleted by CITEA) on same reasoning; however, the Revenue has not filed appeal on that issue in that year. Re (ii): Notice(s) under section 133(6

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

disallowance on account of payment to suspicious parties, involving some common parties, was made by the AO in AY 2019-20, which was deleted by CITEA) on same reasoning; however, the Revenue has not filed appeal on that issue in that year. Re (ii): Notice(s) under section 133(6

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

disallowance on account of payment to suspicious parties, involving some common parties, was made by the AO in AY 2019-20, which was deleted by CITEA) on same reasoning; however, the Revenue has not filed appeal on that issue in that year. Re (ii): Notice(s) under section 133(6

DCIT, CENTRAL CIRCLE-20, NEW DELHI vs. LOTUS HERBALS P.LTD, DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

disallowance on account of payment to suspicious parties, involving some common parties, was made by the AO in AY 2019-20, which was deleted by CITEA) on same reasoning; however, the Revenue has not filed appeal on that issue in that year. Re (ii): Notice(s) under section 133(6

COSMIC INFORMATICS PVT. LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE - 2, NEW DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

disallowance on account of payment to suspicious parties, involving some common parties, was made by the AO in AY 2019-20, which was deleted by CITEA) on same reasoning; however, the Revenue has not filed appeal on that issue in that year. Re (ii): Notice(s) under section 133(6

COSMIC INFORMATICS PVT. LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE - 2, NEW DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

disallowance on account of payment to suspicious parties, involving some common parties, was made by the AO in AY 2019-20, which was deleted by CITEA) on same reasoning; however, the Revenue has not filed appeal on that issue in that year. Re (ii): Notice(s) under section 133(6

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

disallowance, Rs. 7,79,063/-, being proportionate time-cost of designated employees making investments. This amount, according to the appellant/assessee, was duly verified and certified by its auditors. As against this, the appellant/assessee had earned income by way of dividend which was 2021:DHC:1941-DB ITA 213-215/2020 Page 17 of 33 exempt from tax, via investments

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

disallowance, Rs. 7,79,063/-, being proportionate time-cost of designated employees making investments. This amount, according to the appellant/assessee, was duly verified and certified by its auditors. As against this, the appellant/assessee had earned income by way of dividend which was 2021:DHC:1941-DB ITA 213-215/2020 Page 17 of 33 exempt from tax, via investments

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

133] , noticing the settled rules of interpretation laid down following in para 11: (SCC pp. 914-15) “11. Now it is a well-settled rule of interpretation hallowed by time and sanctified by judicial decisions that, unless the terms of a statute expressly so provide or necessarily require it, retrospective operation should not be given to a statute

INCOME TAX OFFICER, DELHI vs. AKASH DEEP SETHI, DELHI

In the result, the appeal filed by the Revenue is dismissed and at the same time, the cross objections filed by the assessee are also dismissed

Bench: Shri Challa Nagendra Prasad & Shri S. Rifaur Rahmanincome Tax Officer, Vs. Akash Deep Sethi, Delhi. B-236, Derawal Nagar, Model Town, Delhi – 110 009. (Pan : Abyps8933P) Co No.26/Del/2025 (In Ita No.4973/Del/2024) (Assessment Year: 2021-22) Akash Deep Sethi, Vs. Income Tax Officer, B-236, Derawal Nagar, Delhi. Model Town, Delhi – 110 009. (Pan : Abyps8933P) (Appellant) (Respondent) Assessee By : Shri Ved Jain, Advocate Shri Aman Garg, Ca Ms. Kirti, Ca Revenue By : Shri Ajay Kumar Arora, Sr. Dr Date Of Hearing : 27.05.2025 Date Of Order : 16.07.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi

Section 133(6) of the Income-tax Act, 1961. It is respectfully submitted that such an inference is both legally unsustainable and factually flawed, for the following reasons: i. Non-response by Third Parties Cannot Lead to any Disallowance

CHARBUJA MARMO (INDIA) PVT. LTD.,DELHI vs. PR.CIT- 2 , NEW DELHI

In the result, appeal of Assessee allowed

Bench: Shri Bhavnesh Saini & Shri B.R.R. Kumar

Section 151 as a pre- condition for issuing notice u/s 147/148-Held, Section 151 stipulates that CIT (A), who was competent authority to authorize reassessment notice, had to apply his mind and form opinion- Mere appending of expression 'approved' says nothing-It was not as if CIT (A) had to record elaborate reasons for agreeing with noting put up-At same