M/S ACTIVE SECURITIES LIMITED,NEW DELHI vs. ITO, NEW DELHI

The appeals are allowed

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

12A, 12AA and 12B are intended merely to indicate the classes of income : the heads do not exhaustively delimit sources from which income arises." It was also held that: "even if an item of income is earned in the course of carrying on a business, it will not necessarily fall within the head "profits and gains of business" within

JAN ABHIVYAKTI SAMAJIK VIKAS SANSTHA,RAIPUR vs. PR.COMMISSIONER OF INCOME TAX (CENTRAL)-2 NEW DELHI, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Anubhav Sharma& Shri Amitabh Shukla[Assessment Year: 2024-25] Jan Abhivyankti Samajik Pr. Commissioner Of Income Tax, Vikas Sanstha, Lig-1361, (Central)-2, Room No.341, E-2, Sector-8, Housing Board Vs 2Nd Floor, Ara Centre, Colony, Saddu Mova, Raipur- Jhandewalan Extension, 492001 (C.G.) New Delhi-110055 Pan:Aabaj7197B Appellant Respondent Assessee By Dr. Rakesh Gupta, Adv. & Shri Deepesh Garg, Adv. Revenue By Shri Mukesh Kumar Jha, Cit(Dr) Date Of Hearing 18.12.2025 Date Of Pronouncement 21.01.2026

Housing Board Vs 2nd Floor, ARA Centre, Colony, Saddu Mova, Raipur- Jhandewalan Extension, 492001 (C.G.) New Delhi-110055 PAN:AABAJ7197B Appellant Respondent Assessee by Dr. Rakesh Gupta, Adv. and Shri Deepesh Garg, Adv. Revenue by Shri Mukesh Kumar Jha, CIT(DR) Date of Hearing 18.12.2025 Date of Pronouncement 21.01.2026 ORDER PER AMITABH SHUKLA, AM, The captioned appeal has been preferred

MODEL VILLAGE TRUST ,DELHI vs. SH. PRAKASH DUBEY CIT EXEMPTION, DELHI, DELHI

In the result, both the appeals of the assessee are allowed

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraआ.अ.सं/.I.T.A Nos. 3189 & 3190/Del/2024 िनधा"रणवष"/Assessment Year:- बनाम Model Village Trust, Sh. Prakash Dubey, E-89, 4Th Floor, Flat No.402, Vs. Cit Exemption, Abul Fazal Enclave, Part-1, New Delhi. New Delhi. Pan No.Aagtm6481K अपीलाथ" Appellant ""यथ"/Respondent

1 to 1351 submitted that all the necessary details were filed before the Ld. CIT(E) to prove the genuineness of the objects and activities of the assessee. Ld. Counsel submits that at the stage of granting registration one has to be seen whether the assessee trust was established for charitable purpose and secondly the activities of the trust

MODEL VILLAGE TRUST,DELHI vs. SH. PRAKASH DUBEY CIT EXEMPTION, DELHI , DELHI

In the result, both the appeals of the assessee are allowed

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraआ.अ.सं/.I.T.A Nos. 3189 & 3190/Del/2024 िनधा"रणवष"/Assessment Year:- बनाम Model Village Trust, Sh. Prakash Dubey, E-89, 4Th Floor, Flat No.402, Vs. Cit Exemption, Abul Fazal Enclave, Part-1, New Delhi. New Delhi. Pan No.Aagtm6481K अपीलाथ" Appellant ""यथ"/Respondent

1 to 1351 submitted that all the necessary details were filed before the Ld. CIT(E) to prove the genuineness of the objects and activities of the assessee. Ld. Counsel submits that at the stage of granting registration one has to be seen whether the assessee trust was established for charitable purpose and secondly the activities of the trust

Commissioner of Income Tax – I

house fabrication in addition to inspection at the vendors factory to whom the production or manufacture had been outsourced. Once the goods were received at the Noida unit, they were examined and assembled and tested. Rust protection was undertaken. Big assemblies were disassembled and repacked. Small assemblies were packed as such. Thereupon, the goods were exported from India and erected

APNA JAHAN CHARITABLE TRUST,DELHI vs. CIT EXEMPTION, DELHI

In the result, both the appeals of the assessee are allowed

Bench: Shri C. N. Prasad & Shri M. Balaganesh

House, F-14, Ward-1(1), Inner Middle Circle, Delhi Connaught Place, New Delhi (Appellant) (Respondent) PAN: AAITA4350P Assessee by : Shri Ahilesh Kumar, Adv Shri Vipin Garg, Adv Shri Rahul, Adv Revenue by: Shri Amit Jain, CIT DR Date of Hearing 24/09/2025 Date of pronouncement 15/12/2025 O R D E R PER M. BALAGANESH, A. M.: 1. The appeal

APNA JAHAN CHARITABLE TRUST,NEW DELHI vs. ITO, WARD- EXEMPTION 1(1), DELHI

In the result, both the appeals of the assessee are allowed

Bench: Shri C. N. Prasad & Shri M. Balaganesh

House, F-14, Ward-1(1), Inner Middle Circle, Delhi Connaught Place, New Delhi (Appellant) (Respondent) PAN: AAITA4350P Assessee by : Shri Ahilesh Kumar, Adv Shri Vipin Garg, Adv Shri Rahul, Adv Revenue by: Shri Amit Jain, CIT DR Date of Hearing 24/09/2025 Date of pronouncement 15/12/2025 O R D E R PER M. BALAGANESH, A. M.: 1. The appeal

MAHASHIAN DI HATTI (P) LTD,NEW DELHI vs. PCIT-4, NEW DELHI

In the result, Appeal of the Assessee is allowed

section 114 of\nEvidence Act raises presumption that official acts have been\nregularly done. There are no reasons to presume that the\nFAU has not followed the said SOP.\n1.1 As per the SOP, the initial notice_u/s_142(1) was\nrequired to be issued considering 360% information/portal\netc. where all the information including history and other\nnature of business

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 3, NEW DELHI, DELHI vs. BHUSHAN DUA, DELHI

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

1) (b) Pioneer Channel Factory Pvt Ltd for a deal value of Rs 3,87,20,000/- vide agreement dated 28.04.2014 (copy enclosed at Page 508 to 515 P/B Vol.1) 134. In this regard, it has been explained that commission 5% on the deal of Rs. 7,00,00,000/- (between SCIPL and Disney Broadcasting (India) Ltd & commission

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3, NEW DELHI, DELHI vs. BHUSHAN DUA, DELHI

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

1) (b) Pioneer Channel Factory Pvt Ltd for a deal value of Rs 3,87,20,000/- vide agreement dated 28.04.2014 (copy enclosed at Page 508 to 515 P/B Vol.1) 134. In this regard, it has been explained that commission 5% on the deal of Rs. 7,00,00,000/- (between SCIPL and Disney Broadcasting (India) Ltd & commission

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3, NEW DELHI, DELHI vs. SUPER CASSETTES INDUSTRIES PVT. LTD., DELHI

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

1) (b) Pioneer Channel Factory Pvt Ltd for a deal value of Rs 3,87,20,000/- vide agreement dated 28.04.2014 (copy enclosed at Page 508 to 515 P/B Vol.1) 134. In this regard, it has been explained that commission 5% on the deal of Rs. 7,00,00,000/- (between SCIPL and Disney Broadcasting (India) Ltd & commission

SUPER CASSETTES INDUSTRIES PVT LTD,DELHI vs. DCIT CENTRAL CIRCLE-3, DELHI

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

1) (b) Pioneer Channel Factory Pvt Ltd for a deal value of Rs 3,87,20,000/- vide agreement dated 28.04.2014 (copy enclosed at Page 508 to 515 P/B Vol.1) 134. In this regard, it has been explained that commission 5% on the deal of Rs. 7,00,00,000/- (between SCIPL and Disney Broadcasting (India) Ltd & commission

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3, DELHI vs. SUPER CASSETTES INDUSTRIES PRIVATE LIMITED, DELHI

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

1) (b) Pioneer Channel Factory Pvt Ltd for a deal value of Rs 3,87,20,000/- vide agreement dated 28.04.2014 (copy enclosed at Page 508 to 515 P/B Vol.1) 134. In this regard, it has been explained that commission 5% on the deal of Rs. 7,00,00,000/- (between SCIPL and Disney Broadcasting (India) Ltd & commission

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, DELHI vs. BHUSHAN DUA, NEW DELHI

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

1) (b) Pioneer Channel Factory Pvt Ltd for a deal value of Rs 3,87,20,000/- vide agreement dated 28.04.2014 (copy enclosed at Page 508 to 515 P/B Vol.1) 134. In this regard, it has been explained that commission 5% on the deal of Rs. 7,00,00,000/- (between SCIPL and Disney Broadcasting (India) Ltd & commission

SUPER CASSETTES INDUSTRIES PRIVATE LIMITED,DELHI vs. DCIT CENTRAL CIRCLE-3, DELHI

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

1) (b) Pioneer Channel Factory Pvt Ltd for a deal value of Rs 3,87,20,000/- vide agreement dated 28.04.2014 (copy enclosed at Page 508 to 515 P/B Vol.1) 134. In this regard, it has been explained that commission 5% on the deal of Rs. 7,00,00,000/- (between SCIPL and Disney Broadcasting (India) Ltd & commission

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3, NEW DELHI, DELHI vs. BHUSHAN DUA, DELHI

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

1) (b) Pioneer Channel Factory Pvt Ltd for a deal value of Rs 3,87,20,000/- vide agreement dated 28.04.2014 (copy enclosed at Page 508 to 515 P/B Vol.1) 134. In this regard, it has been explained that commission 5% on the deal of Rs. 7,00,00,000/- (between SCIPL and Disney Broadcasting (India) Ltd & commission

SUPER CASSETTES INDUSTRIES PVT LTD,NEW DELHI vs. DCIT CENTRAL CIRCLE-3, DELHI

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

1) (b) Pioneer Channel Factory Pvt Ltd for a deal value of Rs 3,87,20,000/- vide agreement dated 28.04.2014 (copy enclosed at Page 508 to 515 P/B Vol.1) 134. In this regard, it has been explained that commission 5% on the deal of Rs. 7,00,00,000/- (between SCIPL and Disney Broadcasting (India) Ltd & commission

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 3, DELHI, DELHI vs. SUPER CASSETTES INDUSTRIES PVT. LTD., DELHI

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

1) (b) Pioneer Channel Factory Pvt Ltd for a deal value of Rs 3,87,20,000/- vide agreement dated 28.04.2014 (copy enclosed at Page 508 to 515 P/B Vol.1) 134. In this regard, it has been explained that commission 5% on the deal of Rs. 7,00,00,000/- (between SCIPL and Disney Broadcasting (India) Ltd & commission