INCOME TAX OFFICER, ROHTAK vs. PANKAJ JAIN, ROHTAK

In the result, the appeal filed by the Revenue is dismissed

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmaincome Tax Officer, Vs. Pankaj Jain, Rohtak. 123/34, Vishwakarma Kathmandi, Rohtak – 124 001 (Haryana). (Pan : Azupj6345A) (Appellant) (Respondent) Assessee By : Shri Shri Naveen Gupta, Advocate Shri Nakul Gupta, Advocate Revenue By : Shri Ajay Kumar Arora,Sr. Dr Date Of Hearing : 06.11.2025 Date Of Order : 30.12.2025 Order Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Cit(A)”, For Short] Dated 04.02.2025 For The Assessment Year 2018-19 Raising Following Grounds Of Appeal :- “1. The Learned Cit(A) Has Erred In Law & On Facts In Not Upholding The Validity Of The Notice Issued Under Section 148 Of The Income Tax Act, 1961 (The Act) Without The Proper & Mandatory Compliance With The Provisions Of Section 148A(B). 2. The Learned Cit(A) Has Further Erred In Law & On Facts By Failing To Consider That The Then Ao Has Given Notice U/S 148A(B) To Assessee On 31.03.2022

reassessment proceedings, the AO proceeded to disallow purchase of Rs.5,42,96,886/- as bogus purchase. However, the assessment was not reopened

KULDIP KUMAR GOEL,DELHI vs. ACIT(1)(1), DELHI

In the result, the appeal of the assessee is partly allowed in above\nterms for statistical purposes

reassessment stage, the appellant had not\nprovided vouchers, bills, or third-party confirmations to show that these\nimprovement outlays were incurred wholly and exclusively to enhance\nthe property's value, thereby justifying deduction from sale amount. Due\nto non-compliance and the absence of credible supporting evidence, the\nLd.JAO invoked best judgment (u/s 144), disallowing

CIT vs. FOOD CORPORATION OF INDIA

The appeal of the Revenue is allowed to this extent

disallowed.? . . . . . In the reassessment, all the aforesaid three items were disallowed by the Assessing Officer. The assessee filed an appeal

DEPUTY COMMISSIONER OF INCOME TAX, GHAZIABAD vs. SALUJA OVERSEAS PVT. LTD., GHAZIABAD

In the result, the Revenue’s appeal stands dismissed

Bench: Shri Mahavir Singh & Shri Krinwant Sahaydcit, Ghaziabad, Vs. Saluja Overseas Pvt. Ltd., Room No. 201, First Floor, A-1, Plot No. 1, Delhi Meerut Road, Cgo Complex, Hapur Chungi, New Arya Nagar, Ghaziabad Ghaziabad, Up-201002 Up-201001 (Pan: Aaucs6233L) (Appellant) (Respondent)

disallowed in reassessment proceedings. Hence, addition made by Assessing Officer in reassessment proceedings is not sustainable in law. Hence, we are not inclined

ANAVYA INVESTMENTS PVT. LTD.,NEW DELHI vs. ITO WARD-2(4), NEW DELHI

In the result, appeal of the assessee is allowed

Bench: Shri C. N. Prasad & Shri M. Balaganeshm/S. Anavya Investments Pvt. Ltd, Vs. Ito, C/O. Sanjay & Sanjay, A-1-A, 14B, Ward-2(4), Janakpuri, New Delhi New Delhi (Appellant) (Respondent) Pan:Aahc4820A Assessee By : Shri Sanjay Garg, Ca Shri Akarsh Garg, Adv Revenue By: Shri Kanv Bali, Sr. Dr Date Of Hearing 11/01/2024 Date Of Pronouncement 08/04/2024

reassessment proceedings, the ld AO made disallowance of Rs. 46,07,275/- representing losses claimed by the assessee due to client

SUKSHAM FINLEASE & INVESTMENT P.LTD,NEW DELHI vs. ITO, WARD-24(3), NEW DELHI

In the result, appeal of the assessee is allowed

reassessment\nproceedings, the ld AO made disallowance of Rs. 46,07,275/- representing losses\nclaimed by the assessee due to client

GLOBUS POWER GENERATION LTD (FORMELY KNOWN AS CUMULATIVE INVESTMENTS & TRADING CO. PVT LTD),NEW DELHI vs. ACIT CIRCLE-6(2), NEW DELHI

In the result, appeal of the assessee is allowed

Bench: Shri C.M. Garg & Shri M. Balaganeshglobus Power Generation Ltd Vs. Acit, (Formerly Known As Cumulative Circle-6(2), Investments & Trading Co. Pvt. Ltd, New Delhi A-60, Naraina Industrial Area, Phase-1, New Delhi-110028 (Appellant) (Respondent) Pan: Aaacg6734E

reassessment proceedings, the ld AO made disallowance of Rs. 46,07,275/- representing losses claimed by the assessee due to client

LINKEDIN TECHNOLOGY INFORMATION PRIVATE LIMITED,DELHI vs. PRINCIPAL COMMISSIONER OF INCOME-TAX, DELHI -4 , DELHI

In the result, the appeal of the assessee is partly allowed

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

reassessment order is in line with accepted legal position and reflects one of the possible views. 2.4. On the facts and in the circumstances of the case and in law, the Ld. Pr. CIT's direction to disallow

ITO (INTERNATIONAL TAXATION) GURGAON, UDYOG VIHAR, GURGAON vs. BAIN AND COMPANY INDIA PRIVATE LTD., GURGAON

In the result, appeals of the Revenue are dismissed

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

disallowance was made in the reassessment orders (refer para 9 of the reassessment orders for both years). 24. In view

ITO (INTERNATIONAL TAXATION) GURGAON, UDYOG VIHAR,GURGAON vs. BAIN AND COMPANY INDIA PRIVATE LTD., DLF CYBER CITY PHASE-II

In the result, appeals of the Revenue are dismissed

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

disallowance was made in the reassessment orders (refer para 9 of the reassessment orders for both years). 24. In view

CIT vs. PNB FINANCE & INDUSTRIES LTD

disallowed 2010:DHC:5530-DB under Section 14A of the Act. In the reassessment proceedings, the AO, thus, disallowed the expenses

GOEL PAWAN KUMAR & FAMILY (HUF) ,SONIPAT vs. INCOME TAX OFFICER, NEW DELHI

In the result, the appeal of the assessee is partly allowed as indicated above

reassessment proceedings and disallowed purchases of Rs.24,20,165/- treating them as bogus.", "held": "The Tribunal held that while purchases

OMEGA FINHOLD PVT. LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 14, NEW DELHI

In the result, the appeal filed by the assessee is allowed

disallowed in the reassessment proceedings completed on 31/03/2016 both under the normal provisions of the Act as well as in the computation

NOIDA SPECIAL ECONOMIC ZONE AUTHORITY,NOIDA vs. DCIT, CIRCLE-2, NOIDA

In the result, the assessing officer is directed to allow both the disallowances

Bench: Shripawan Singhand Shribrajesh Kumar Singhआ.अ.सं/.I.T.A No.6540/Del/2018 िनधा"रणवष"/Assessment Year:2010-11 (Physical Hearing) Noida Special Economic Zone Authority, बनाम Dcit, Phase-Ii, Dadri Road, Noida, Circle-2, Vs. Uttar Pradesh. Aayakar Bhawan, 2D, A-Block, Sector-24, Pan No.Aaaln0639A Noida, Uttar Pradesh. अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.6541/Del/2018 िनधा"रणवष"/Assessment Year:2012-13 Noida Special Economic Zone Authority, बनाम Dcit,Circle-2, Phase-Ii, Dadri Road, Noida, Aayakar Bhawan, 2D, Vs. Uttar Pradesh. A-Block, Sector-24, Noida, Uttar Pradesh. Pan No.Aaaln0639A अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.6732/Del/2018 िनधा"रणवष"/Assessment Year:2012-13 Acit, बनाम Noida Special Economic Zone Authority, Circle-2, Phase-Ii, Dadri Road, Noida, Vs. Aayakar Bhawan, 2D, Uttar Pradesh. A-Block, Sector-24, Noida, Uttar Pradesh. Pan No.Aaaln0639A अपीलाथ" Appellant ""यथ"/Respondent Assessee By Shri Ram Avtar Sharma, Ca & Shri Bhupesh Agarwal, Ca Revenue By Ms. Monika Singh, Cit-Dr सुनवाईक"तारीख/ Date Of Hearing: 26.11.2025 उ"ोषणाक"तारीख/Pronouncement On 12.12.2025 आदेश /O R D E R Per Pawan Singh:

disallowed deduction under section 80IB of Rs.13.96 Crores. On appeal before CIT(A), the action of the Assessing Officer was upheld vide order dated 09.01.2018. Resultantly, the assessee has approached this Tribunal. 3. The ld. AR of the assessee submits that reassessment

ACIT, CIRCLE-2, NOIDA vs. NOIDA SPECIAL ECONOMIC ZONE AUTHORITY, NOIDA

In the result, the assessing officer is directed to allow both the disallowances

Bench: Shripawan Singhand Shribrajesh Kumar Singhआ.अ.सं/.I.T.A No.6540/Del/2018 िनधा"रणवष"/Assessment Year:2010-11 (Physical Hearing) Noida Special Economic Zone Authority, बनाम Dcit, Phase-Ii, Dadri Road, Noida, Circle-2, Vs. Uttar Pradesh. Aayakar Bhawan, 2D, A-Block, Sector-24, Pan No.Aaaln0639A Noida, Uttar Pradesh. अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.6541/Del/2018 िनधा"रणवष"/Assessment Year:2012-13 Noida Special Economic Zone Authority, बनाम Dcit,Circle-2, Phase-Ii, Dadri Road, Noida, Aayakar Bhawan, 2D, Vs. Uttar Pradesh. A-Block, Sector-24, Noida, Uttar Pradesh. Pan No.Aaaln0639A अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.6732/Del/2018 िनधा"रणवष"/Assessment Year:2012-13 Acit, बनाम Noida Special Economic Zone Authority, Circle-2, Phase-Ii, Dadri Road, Noida, Vs. Aayakar Bhawan, 2D, Uttar Pradesh. A-Block, Sector-24, Noida, Uttar Pradesh. Pan No.Aaaln0639A अपीलाथ" Appellant ""यथ"/Respondent Assessee By Shri Ram Avtar Sharma, Ca & Shri Bhupesh Agarwal, Ca Revenue By Ms. Monika Singh, Cit-Dr सुनवाईक"तारीख/ Date Of Hearing: 26.11.2025 उ"ोषणाक"तारीख/Pronouncement On 12.12.2025 आदेश /O R D E R Per Pawan Singh:

disallowed deduction under section 80IB of Rs.13.96 Crores. On appeal before CIT(A), the action of the Assessing Officer was upheld vide order dated 09.01.2018. Resultantly, the assessee has approached this Tribunal. 3. The ld. AR of the assessee submits that reassessment

NOIDA SPECIAL ECONOMIC ZONE AUTHORITY,NOIDA vs. DCIT, CIRCLE-2, NOIDA

In the result, the assessing officer is directed to allow both the disallowances

Bench: Shripawan Singhand Shribrajesh Kumar Singhआ.अ.सं/.I.T.A No.6540/Del/2018 िनधा"रणवष"/Assessment Year:2010-11 (Physical Hearing) Noida Special Economic Zone Authority, बनाम Dcit, Phase-Ii, Dadri Road, Noida, Circle-2, Vs. Uttar Pradesh. Aayakar Bhawan, 2D, A-Block, Sector-24, Pan No.Aaaln0639A Noida, Uttar Pradesh. अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.6541/Del/2018 िनधा"रणवष"/Assessment Year:2012-13 Noida Special Economic Zone Authority, बनाम Dcit,Circle-2, Phase-Ii, Dadri Road, Noida, Aayakar Bhawan, 2D, Vs. Uttar Pradesh. A-Block, Sector-24, Noida, Uttar Pradesh. Pan No.Aaaln0639A अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.6732/Del/2018 िनधा"रणवष"/Assessment Year:2012-13 Acit, बनाम Noida Special Economic Zone Authority, Circle-2, Phase-Ii, Dadri Road, Noida, Vs. Aayakar Bhawan, 2D, Uttar Pradesh. A-Block, Sector-24, Noida, Uttar Pradesh. Pan No.Aaaln0639A अपीलाथ" Appellant ""यथ"/Respondent Assessee By Shri Ram Avtar Sharma, Ca & Shri Bhupesh Agarwal, Ca Revenue By Ms. Monika Singh, Cit-Dr सुनवाईक"तारीख/ Date Of Hearing: 26.11.2025 उ"ोषणाक"तारीख/Pronouncement On 12.12.2025 आदेश /O R D E R Per Pawan Singh:

disallowed deduction under section 80IB of Rs.13.96 Crores. On appeal before CIT(A), the action of the Assessing Officer was upheld vide order dated 09.01.2018. Resultantly, the assessee has approached this Tribunal. 3. The ld. AR of the assessee submits that reassessment

VERTEX BUILDWELL PRIVATE LIMITED,DELHI vs. INCOME TAX OFFICER, WARD - 26(2), C R BUILDING, NEW DELHI

In the result, appeal of assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

reassess and disallow the expenditure incurred on DAP and production and translation expenses only demonstrate a change of opinion on the part

NISHA GOEL,DELHI vs. INCOME TAX OFFICER, WARD 52(3), WARD

In the result, appeal of the assessee is partly allowed as

Bench: Shri Shamim Yahya & Shri Challa Nagendra Prasadिनधा"रणवष"/Assessment Year: 2012-13

reassessment order on the legal issue, we are not inclined to go into the merits of the addition of disallowance

UMAR DARAJ,MEERUT vs. ITO WARD-1(2)(4), MEERUT

In the result, the appeal filed by the assessee is partly allowed

Bench: Shri S.Rifaur Rahman & Shri Yogesh Kumar U.S.Umar Daraj, Vs. Ito, Ward 1(2)(4), 153/1, Hapur Road, Meerut. Umar Nagar, Meerut – 250 001 (Uttar Pradesh). (Pan : Ainpd8766H) (Appellant) (Respondent) Assessee By : Shri Sumit Lal Chandani, Advocate Revenue By : Shri Dayainder Singh Sidhu, Citdr Date Of Hearing : 17.09.2025 Date Of Order : 10.12.2025 O R D E R Per S. Rifaur Rahman:

disallowance. 10. That the reassessment proceedings have been carried out in violation of the principles of natural justice, as the Assessing