MOTHERSON SUMI SYSTEMS LIMITED,NEW DELHI vs. DCIT, NEW DELHI

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

Bench: Shri Shamim Yahya & Ms. Astha Chandraasstt. Year: 2010-11

reassessment year 1998-99, where it has declined the benefit to the assessee cannot be found fault with. But there is change in the law for the assessment year 2001-02. Section 10(B)(1) and (4) reads as under- "Section 108: Special provisions in respect off newly established hundred per cent export oriented undertakings (1) Subject to the provisions

RAJESH KUMAR,SONEPAT vs. ACIT, CENTRAL CIRCLE-2, GURGAON

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

Bench: Shri Kul Bharat & Shri Avdhesh Kumar Mishra[Assessment Year : 2018-19] Rajesh Kumar, Vs Acit, C/O-Shiva Constructions Co., Central Circle-2, Plot No.69, Sidharth Enclave, Gurgaon. Delhi Road Sonipat, Sonipat, Haryana-131001. Pan-Bkspk2518K Appellant Respondent [Assessment Year : 2018-19] Dcit, Vs Rajesh Kumar, Gurgaon. C/O-Shiva Constructions Co., Plot No.69, Sidharth Enclave, Delhi Road,Sonipat, Haryana-131001. Pan-Bkspk2518K Appellant Respondent Appellant By Shri Umesh Takkar, Ca & Shri Saurabh Nagpal, Ca Respondent By Shri P N Barnwal, Sr.Dr Date Of Hearing 03.07.2024 Date Of Pronouncement 07.08.2024 Order Per Kul Bharat, Jm : These Two Cross-Appeals Filed By The Assessee & The Revenue, Are Directed Against The Order Passed By Ld. Commissioner Of Income Tax(Appeals) [“Ld.Cit(A)”]-3, Gurgaon Dated 31.10.2022 For The Assessment Year 2018-19. Both Appeals Of The Assessee & The Revenue Are Heard Together & Are Being Disposed Off By Way Of Common Order For The Sake Of Brevity.

reassessment. We are of the view that if no assessment had been made, there was no occasion for the Assessing Officer to conclude that income had already escaped assessment. 12. This being the position, we are of the opinion that no substantial question of law that arises for our consideration and we do not find any error in the view

DCIT, GURUGRAM vs. RAJESH KUMAR, SONEPAT

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

Bench: Shri Kul Bharat & Shri Avdhesh Kumar Mishra[Assessment Year : 2018-19] Rajesh Kumar, Vs Acit, C/O-Shiva Constructions Co., Central Circle-2, Plot No.69, Sidharth Enclave, Gurgaon. Delhi Road Sonipat, Sonipat, Haryana-131001. Pan-Bkspk2518K Appellant Respondent [Assessment Year : 2018-19] Dcit, Vs Rajesh Kumar, Gurgaon. C/O-Shiva Constructions Co., Plot No.69, Sidharth Enclave, Delhi Road,Sonipat, Haryana-131001. Pan-Bkspk2518K Appellant Respondent Appellant By Shri Umesh Takkar, Ca & Shri Saurabh Nagpal, Ca Respondent By Shri P N Barnwal, Sr.Dr Date Of Hearing 03.07.2024 Date Of Pronouncement 07.08.2024 Order Per Kul Bharat, Jm : These Two Cross-Appeals Filed By The Assessee & The Revenue, Are Directed Against The Order Passed By Ld. Commissioner Of Income Tax(Appeals) [“Ld.Cit(A)”]-3, Gurgaon Dated 31.10.2022 For The Assessment Year 2018-19. Both Appeals Of The Assessee & The Revenue Are Heard Together & Are Being Disposed Off By Way Of Common Order For The Sake Of Brevity.

reassessment. We are of the view that if no assessment had been made, there was no occasion for the Assessing Officer to conclude that income had already escaped assessment. 12. This being the position, we are of the opinion that no substantial question of law that arises for our consideration and we do not find any error in the view

NKG INFRASTRUCTURE LIMITED,NEW DELHI vs. DCIT, CENTRAL CIRCLE-27, DELHI

In the result, the appeal filed by the assessee is partly allowed and the appeal filed by the Revenue is dismissed

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

reassessment or recomputation under section 147, the Assessing Officer shall serve on the assessee a notice requiring him to furnish within such period, as may be specified in the notice, a return of his income or the income of any other person in respect of which he is assessable under this Act during the previous year corresponding to the relevant

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-27, DELHI, DELHI vs. NKG INFRASTRUCTURE LIMITED, DELHI

In the result, the appeal filed by the assessee is partly allowed and the appeal filed by the Revenue is dismissed

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

reassessment or recomputation under section 147, the Assessing Officer shall serve on the assessee a notice requiring him to furnish within such period, as may be specified in the notice, a return of his income or the income of any other person in respect of which he is assessable under this Act during the previous year corresponding to the relevant

CIT vs. KEANE INDIA LTD

reassessment proceedings u/s 148 dated 25.3.2008.? . . . . . 3. The CIT (Appeals) further records that he had seen submissions dated 16.3.2006, 22.3.2006 and 23.3.2006 on the question of deduction under Section 10A

(Now known as Sony India Limited)

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154 for any assessment year the proceedings of which have been completed before the 1st day of October, 2009. (3) Where during the course of any proceeding for the assessment of income

ITO WARD - 23(3), NEW DELHI vs. SHREE BHAWANI POWER PROJECTS PVT LTD, NEW DELHI

In the result, both the appeals filed by the Revenue Department stands dismissed

Bench: Shri Anil Chaturvedi & Shri N.K. Choudhry

reassessment order which was passed on 07.12.2019, therefore, following the appellate order for A.Y. 2016-17, as referred above, the addition of Rs.1,85,97,591/- is hereby deleted and the Assessing Officer is directed to allow the claim of deduction u/s. 80IA of the Act to the appellant. 8.2 In order to adjudicate the issue under controversy properly

ITO WARD - 23(3), NEW DELHI vs. SHREE BHAWANI POWER PROJECTS PVT LTD, NEW DELHI

In the result, both the appeals filed by the Revenue Department stands dismissed

Bench: Shri Anil Chaturvedi & Shri N.K. Choudhry

reassessment order which was passed on 07.12.2019, therefore, following the appellate order for A.Y. 2016-17, as referred above, the addition of Rs.1,85,97,591/- is hereby deleted and the Assessing Officer is directed to allow the claim of deduction u/s. 80IA of the Act to the appellant. 8.2 In order to adjudicate the issue under controversy properly

SH. ATAR SINGH,FARIDABAD vs. ITO WARD-1(1), FARIDABAD

In the result, Appeal of the Assessee is partly allowed

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shuklai.T.A. No. 2732/Del/2025 (A.Y 2012-13) Sh. Atar Singh Vs Income Tax Officer House No. 5, Village, Gazipur, Ward 1(1) Gazipur Road, Faridabad, Faridabad, Haryana Haryana-121005 122001 Pan: Dmpps6598B Appellant Respondent Assessee By Sh. S.S. Nagar, Ca Revenue By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 29/10/2025 Date Of Pronouncement 19/12/2025 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals)/National Faceless Appeal

section 10A.” 19.1 The crux of the above judgments and the judgment of the Tribunal relied on the above had been that in case, incorrect, wrong and non-existing reasons are recorded by the AO for reopening of the assessment and that AO failed to verify the information received from Investigation Wing, the reopening of the assessment would be unjustified

SUMITRA DEVI,GURGAON vs. ITO,WARD 4(1),GURGAON, GURGAON

In the result, the appeal of the assessee is allowed in above terms

10A, NEAR G.D. GOENKA\nPUBLIC SCHOOL,\nGURGAON-122001\nHARYANA\n(PAN: AVPPD4710N)\n(Appellant)\nVS.\nITO, WARD 4(1),\nGURGAON\n(Respondent)\nASSESSEE BY : Sh. M.R. Sahu, CA\nRespondent by : Sh. Rajesh Kumar Dhanesta, Sr. DR.\nDate of Hearing\nDate of Pronouncement\n23.02.2026\n11.03.2026\nORDER\nPER SUDHIR KUMAR, JM:\nThis appeal by the Assessee against the order dated

ATAR SINGH,DELHI vs. ITO,WARD 70 (1)-DELHI, DELHI

In the result, the appeal of the assessee is allowed

10A,\nNear G. D. Goenka Public\nSchool, Gurgaon-122001,\nHaryana\nPAN:BDDPS5583H\nAssessee by : Mr. R. Sahu, CA\nRevenue by: Shri Manoj Kumar, Sr. DR\nDate of Hearing 12/08/2025\nDate of pronouncement 20/08/2025\n\nORDER\n\nVs. ITO,\nWard-70(1),\nDelhi\n\n1. The appeal in ITA No.186/Del/2025 for AY 2017-18 arises out of the order

DIT-I, INTERNATIONAL TAXATION vs. ALCATEL LUCENT USA, INC

The appeals are allowed

reassessments; but before the CIT (Appeals) it gave up the claim that it was not liable to tax in India and pressed its claim only to the extent of its liability to pay interest under Section 234B. It is submitted that this factual position is in complete contrast to the facts before this Court in Jacabs (supra) where the assessee

THE PR. COMMISSIONER OF INCOME TAX -4 vs. HEADSTRONG SERVICES INDIA PVT. LTD.

10A of the Act and transfer pricing adjustment made by the TPO. 5. Being aggrieved, the respondent-assessee filed an appeal before the ITAT, where the additions on account transfer pricing and deduction under Section l0A of the Act were set aside and the Assessing Officer was directed to frame the assessment afresh. The matter was restored to the Assessing

VATIKA SEVEN ELEMENTS P.LTD,NEW DELHI vs. ACIT, CIRCLE-26(2), NEW DELHI

In the result, all ITA Nos

Bench: Shrivikas Awasthy & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.5422/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22 बनाम Express Freight Consortium, Assessment Unit,Income Tax C-4, District Centre, Saket, New Vs. Dept,Civic Centre,Pratyakshar Delhi. Bhawan, Pan No.Aaaae8440R Shayama Prasad Mukherjee Marg, New Delhi. अपीलाथ" Appellant ""यथ"/Respondent

10A-16, Ground Floor, Narain Manzil, Circle 19(1), Range-44, 23, Barakhamba Road, New Delhi. C.R. Building, Delhi. PAN No.AABCO8528P अपीलाथ" Appellant ""यथ"/Respondent Assessee by Shri Kashish Gupta, AR, Ms. Taranjeet Kaur, AR & Shri Anil Kumar, Advocate आ.अ.सं/.I.T.A No.5342/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22 बनाम T.EN GLOBAL BUSINESS SERVICES PRIVATE LIMITED, The Deputy Commissioner

MODI ENTERTAINMENT LTD vs. DCIT CIRCLE 5 (1),

In the result, the appeal of the assessee on this ground is dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

reassessment being based merely on change of opinion, was bad in law and void ab- initio. 2. That the CIT(A) erred on facts and in law in confirming the action of the assessing officer in making an addition of Rs.19,40,928/ while computing 'book profit under section 115JB of the Income Tax Act, 1961('the Act'), on account

RAMPGREEN SOLUTIONS PVT LTD vs. COMMISSIONER OF INCOME TAX

The appeal is allowed

Bench: The Tribunal, Impugning The Assessment Order Passed By The Assessing Officer (Hereafter ‘Ao’) Making The Transfer Pricing Adjustments (Hereafter ‘Tp Adjustments’) In Respect Of The Assessment Year (Hereafter ‘Ay’) 2008-09 As Finalised By The Transfer Pricing Officer 2015:Dhc:6421-Db

10A of the Act and disallowance under Section 14A of the Act. 8. The Assessee appealed against the final assessment order dated 9th October, 2012, inter alia, on the ground that eClerx and Vishal could not be considered as comparable entities for the purpose of calculating the benchmark operating profit margin. The Assessee claimed that the said companies were engaged

SURESH CHAND,GURGAON vs. ITO,WARD 4(1),GURGAON, GURGAON

Appeal is allowed

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahmanita No. 4110/Del/2024 : Asstt. Year : 2013-14 Suresh Chand, Vs Income Tax Officer, C/O Ca M R Sahu, House No. 651, Ward-4(1), 1St Floor, Sector-10A, Near G. D. Gurgaon, Goenka Public School, Gurgaon, Haryana-122016 Haryana-122001 (Appellant) (Respondent) Pan No. Aoopk7257H Assessee By : Sh. M. R. Sahu, Ca Revenue By : Sh. Mahesh Kumar Cit-Dr Date Of Hearing: 07.07.2025 Date Of Pronouncement: 30.07.2025 Order Per Satbeer Singh Godara: This Revenue’S Appeal For Assessment Year 2013-14, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1066753639(1) Dated 16.07.2024, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

10A, Near G. D. Gurgaon, Goenka Public School, Gurgaon, Haryana-122016 Haryana-122001 (APPELLANT) (RESPONDENT) PAN No. AOOPK7257H Assessee by : Sh. M. R. Sahu, CA Revenue by : Sh. Mahesh Kumar CIT-DR Date of Hearing: 07.07.2025 Date of Pronouncement: 30.07.2025 ORDER Per Satbeer Singh Godara, Judicial Member: This Revenue’s appeal for Assessment Year 2013-14, arises against