CHIRAG KIRPAL,DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, GURGAON

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh & Shri Vimal Kumarchirag Kirpal, Vs. Acit, C/O. Anuj Bhatia, C-3, Bali International Taxation, Nagar, New Raja Garden, Gurgaon New Delhi (Appellant) (Respondent) Pan: Bwxpk8788D Assessee By : Shri. S. K. Gupta, Ca Revenue By: Shri M. S. Nethrapal, Cit Dr Date Of Hearing 17/09/2025 Date Of Pronouncement 30/09/2025

property for Rs. 65 lakhs during the year under consideration. Since the said transaction is more than the maximum amount not chargeable to tax and Assessee being a non-filer of income tax return, notice under section 148 of the Act stood issued to the Assessee on 29-03-2023 by ITO (International Tax), Gurgoan. In response to the said

BRAHAM SINGH,DELHI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT , DELHI

In the result, both the appeals are allowed for statistical purposes

Bench: Shri Pradip Kumar Kedia & Shri Vimal Kumarita No. 4757/Del/2024 Assessment Year: 2014-15 Ita No.4756/Del/2024 Assessment Year: 2016-17 Braham Singh, Vs Assessment Unit, House N0.57, Dhansa . Income Tax Department Raota, South West Delhi Delhi Pin: 1100 73 Delhi. Pan: Fhmps9910M (Appellant) (Respondent)

House N0.57, Dhansa . Income Tax Department Raota, South West Delhi Delhi PIN: 1100 73 Delhi. PAN: FHMPS9910M (Appellant) (Respondent) Assessee by: S/Shri I.P. Bansal & Vivek Bansal, Advs. Department by: Shri Amit Shukla, Sr. DR Date of Hearing: 08.05.2025 Date of Pronouncement: 08.05.2025 O R D E R PER VIMAL KUMAR, JUDICIAL MEMBER: The appeals filed by the Appellant/assessee are against

BRAHAM SINGH,DELHI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT, DELHI

In the result, both the appeals are allowed for statistical purposes

Bench: Shri Pradip Kumar Kedia & Shri Vimal Kumarita No. 4757/Del/2024 Assessment Year: 2014-15 Ita No.4756/Del/2024 Assessment Year: 2016-17 Braham Singh, Vs Assessment Unit, House N0.57, Dhansa . Income Tax Department Raota, South West Delhi Delhi Pin: 1100 73 Delhi. Pan: Fhmps9910M (Appellant) (Respondent)

House N0.57, Dhansa . Income Tax Department Raota, South West Delhi Delhi PIN: 1100 73 Delhi. PAN: FHMPS9910M (Appellant) (Respondent) Assessee by: S/Shri I.P. Bansal & Vivek Bansal, Advs. Department by: Shri Amit Shukla, Sr. DR Date of Hearing: 08.05.2025 Date of Pronouncement: 08.05.2025 O R D E R PER VIMAL KUMAR, JUDICIAL MEMBER: The appeals filed by the Appellant/assessee are against

MR. ABHISHEK DIXIT,GURUGRAM vs. DDIT/ADIT( IN TAX.), NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri Sudhir Pareek & Shri Brajesh Kumar Singh

house property. The assessee had claimed exempt income of Rs. 35,43,224/-. 3. At the outset, the Ld. AR submitted that the AO had reasons to believe that an income chargeable to tax amounting to Rs. 2,87,04,714/- had escaped assessment in the hands of the assessee for the year under consideration within the meaning of section

SUNITA BHARDWAJ,NEW DELHI vs. ITO WARD 61(1), NEW DELHI

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2012-13] Sunita Bhardwaj, Vs Acit, 1/2, Taj Apartments, Circle-63(1), R.K.Puram, Sector-12, Delhi Delhi-110022. Pan-Ahfpb1928E Appellant Respondent

house property income is bad in law and against the facts and circumstances of the case and the same is not sustainable on various legal and factual grounds. 7. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in charging interest

SUNITA BHARDWAJ,NEW DELHI vs. ITO WARD 61(1), NEW DELHI

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2012-13] Sunita Bhardwaj, Vs Acit, 1/2, Taj Apartments, Circle-63(1), R.K.Puram, Sector-12, Delhi Delhi-110022. Pan-Ahfpb1928E Appellant Respondent

house property income is bad in law and against the facts and circumstances of the case and the same is not sustainable on various legal and factual grounds. 7. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in charging interest

SUMAN KISHORE,NEW DELHI vs. ITO, NEW DELHI

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2012-13] Sunita Bhardwaj, Vs Acit, 1/2, Taj Apartments, Circle-63(1), R.K.Puram, Sector-12, Delhi Delhi-110022. Pan-Ahfpb1928E Appellant Respondent

house property income is bad in law and against the facts and circumstances of the case and the same is not sustainable on various legal and factual grounds. 7. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in charging interest

ASHISH GUPTA,DELHI vs. ITO WARD-36(1), DELHI

In the result, all the five appeals of the assessee in ITA Nos

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

148A(d) on 27.07.2022 without giving sufficient time to the assessee for furnishing a reply, rendering the entire reassessment procedurally defective in a prejudiced and arbitrary conduct despite time sought by the assessee on 14.06.2022 and Ld. CIT(A) has erred in upholding the same. 6. That the Ld. AO has erred in initiating reassessment proceedings in a mechanical manner

ASHISH GUPTA,DELHI vs. ITO WARD-36(1), DELHI

In the result, all the five appeals of the assessee in ITA Nos

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

148A(d) on 27.07.2022 without giving sufficient time to the assessee for furnishing a reply, rendering the entire reassessment procedurally defective in a prejudiced and arbitrary conduct despite time sought by the assessee on 14.06.2022 and Ld. CIT(A) has erred in upholding the same. 6. That the Ld. AO has erred in initiating reassessment proceedings in a mechanical manner

ASHISH GUPTA,DELHI vs. ITO WARD-36(1), DELHI

In the result, all the five appeals of the assessee in ITA Nos

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

148A(d) on 27.07.2022 without giving sufficient time to the assessee for furnishing a reply, rendering the entire reassessment procedurally defective in a prejudiced and arbitrary conduct despite time sought by the assessee on 14.06.2022 and Ld. CIT(A) has erred in upholding the same. 6. That the Ld. AO has erred in initiating reassessment proceedings in a mechanical manner

ASHISH GUPTA,DELHI vs. ITO WARD-36(1), DELHI

In the result, all the five appeals of the assessee in ITA Nos

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

148A(d) on 27.07.2022 without giving sufficient time to the assessee for furnishing a reply, rendering the entire reassessment procedurally defective in a prejudiced and arbitrary conduct despite time sought by the assessee on 14.06.2022 and Ld. CIT(A) has erred in upholding the same. 6. That the Ld. AO has erred in initiating reassessment proceedings in a mechanical manner

ASHISH GUPTA,DELHI vs. ITO WARD-36(1), DELHI

In the result, all the five appeals of the assessee in ITA Nos

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

148A(d) on 27.07.2022 without giving sufficient time to the assessee for furnishing a reply, rendering the entire reassessment procedurally defective in a prejudiced and arbitrary conduct despite time sought by the assessee on 14.06.2022 and Ld. CIT(A) has erred in upholding the same. 6. That the Ld. AO has erred in initiating reassessment proceedings in a mechanical manner

BOOKING.COM B.V.,THE NETHERLANDS vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE 1(1)(2), INTERNATIONAL TAXATION, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri M Balaganesh & Shri Vimal Kumarbooking.Com B.V. Vs. Acit, Circle -1(1)(2) Oosterdokskade 163, International Taxation, 1011 Dl, Amsterdam, The Civic Centre, Minto Road, Netherlands, New Delhi – 110002 Haryana 122002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aagcb2395A Appellant .. Respondent

148A(b) of the Act fail to establish how the Appellant's income is taxable under the Act or the DTAA except saying that there are receipts from India and those have been subjected to withholding. 23. There is no linkage between the material on record and the formation of the belief that the income chargeable to tax has escaped

QUALCOMM INCORPORATED,SAN DIEGO, CALIFORNIA vs. DCIT CIRCLE 3(1)(1) INTERNATIONAL TAXATION, CIVIC CENTRE, NEW DELHI

In the result, all the captioned appeals of the assessee in ITA No

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

House Drive International Taxation San Diego, California, New Delhi The Skyview 10, 18’ F Survey No. 83, 1 Raidurg, Hyderabad, Telangana PAN: AAACQ 1484 H (Applicant) (Respondent) Assessee By : Shri Nishant Thakakr, Adv Ms. Jasmin Amalsadvala, Adv Shri Naveen K. Agarwal, CA Shri Zoheb Bhalwani, CA Department By : Shri Vijay B. Vasanta, CIT-DR Date of Hearing : 21.08.2024 Date

QUALCOMM INCORPORATED,SAN DIEGO, CALIFORNIA vs. DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE 3(1)(1) INTERNATIONAL TAXATION, NEW DELHI

In the result, all the captioned appeals of the assessee in ITA No

Bench: Shri Vikas Awasthy & Shri Naveen Chandra[A.Y 2017-18]

House Drive International Taxation San Diego, California, New Delhi The Skyview 10, 18’ F Survey No. 83, 1 Raidurg, Hyderabad, Telangana PAN: AAACQ 1484 H (Applicant) (Respondent) Assessee By : Shri Nishant Thakakr, Adv Ms. Jasmin Amalsadvala, Adv Shri Naveen K. Agarwal, CA Shri Zoheb Bhalwani, CA Department By : Shri Vijay B. Vasanta, CIT-DR Date of Hearing : 20.08.2024 Date

QUALCOMM INCORPORATED,SAN DIEGO, CALIFORNIA vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1), CIVIC CENTRE, NEW DELHI

In the result, all the captioned appeals of the assessee in ITA No

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

House Drive International Taxation San Diego, California, New Delhi The Skyview 10, 18’ F Survey No. 83, 1 Raidurg, Hyderabad, Telangana PAN: AAACQ 1484 H (Applicant) (Respondent) Assessee By : Shri Nishant Thakakr, Adv Ms. Jasmin Amalsadvala, Adv Shri Naveen K. Agarwal, CA Shri Zoheb Bhalwani, CA Department By : Shri Vijay B. Vasanta, CIT-DR Date of Hearing : 21.08.2024 Date

DHARAMBIR,DELHI vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI, DELHI

In the result, the appeal of the assessee is allowed for statistical purpose

Bench: Shri C.N. Prasad & Shri M. Balaganeshassessment Year 2014-15 Dharambir Vs. National Faceless Assessment H. No.227, Pandwala, Centre, Delhi Kalan, Najafgarh, New Delhi Pan No.Agypy8801D Appellant Respondent Appellant Sh. Manpreet Singh Kapoor, Ca Sh. Rajendra Singh Rathoe, Advocate Respondent Sh. Om Prakash, Sr. Dr

148A and 149 of the Income Tax Act, 1961. 5. That the impugned notice u/s 148 of the Income Tax Act issued by the Ld.AO and confirmed by CIT (A) is in contravention to the provisions of Section 149(1). (b) of the Act and the first proviso thereto. 6. That the CIT (A) has erred in law in upholding

URMILA DEVI,GHAZIABAD vs. INCOME TAX OFFICER WARD-2(2) (1) GZB., GHAZIABAD

In the result, the Assessee’s appeal is dismissed

Bench: Shri Mahavir Singh, Hon’Bleasstt. Year : 2015-16 Urmila Devi, Vs. Ito, Ward 2(2)(1), R-2/44, Raj Nagar, Ghaziabad Ghaziabad (Pan: Agcpd5389H) (Appellant) (Respondent) Appellant By : Shri Saif Ali, Adv. (Through Vc) & Shri Pranav Menon, Adv. Respondent By : Shri Manoj Kumar, Sr. Dr. Date Of Hearing 03.09.2025 Date Of Pronouncement 12.09.2025 Order This Appeal By The Assessee Is Emanating From The Order Of The Nfac, Delhi Order Dated 12.03.2025 Relating To Assessment Year 2015-16 On The Following Grounds:- 1. That The Order U/S. 250 Passed By The Cit(A) Is Bad In Law. 2. That The Cit(A) Has Grossly Erred In Passing Order U/S. 250 With Pre- Conceived Motion & Without Appreciating Material On Records. 3. That The Cit(A) Has Erred In Confirming The Disallowance Of Exemption Amounting To Rs. 2442775/- Claimed U/S. 54 Of The Act In Respect Of Ltcg For Investment On The Construction Of The House. 4. That The Ld. Cit(A) Has Erred In Rejecting The Report Of The Valuer In Support Of The Construction Of The House For Claim Of Exemption U/S. 54 Of The Act.

148A(1)(d) of the Act was passed on 31.3.2022 being fit case for issue of notice u/s. 148 of the Act to the assessee on 31.03.2022, after obtaining necessary approval from the PCCIT, UP West & Uttarakhand issued notice u/s 148 of the Act to the assessee. Thereafter, necessary statutory notices were also issued to the assessee and in response

KAMLA YADAV,SHAKURPUR,DWELHI vs. ACIT-ASSESSMENT UNIT, NFAC

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Raj Kumar Chauhan & Shri Amitabh Shukla

House No. 340 Assessment Unit Village Shakurpur, Vs. New Delhi Delhi-110034 PAN: AAAPY6730B (Respondent) (Appellant) Appellant by Sh. V.K.Tulsiyan, CA Respondent by Ms. Suman Malik, CIT-DR Date of Hearing 04/02/2026 Date of Pronouncement 10/04/2026 O R D E R PER RAJ KUMAR CHAUHAN (J.M.): 1. This appeal is filed by the assessee /appellant against the order of Learned