TAYAL SONS PRIVATE LIMITED,HISAR vs. DCIT, HISAR

The Appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalita No. 3323/Del/2025 (A.Y. 2019-20) Tayal Sons Private Vs Dcit Limited Income Tax Office, Sesctor14, 653A, Kath Mandi Road, Hisar, Hisar, Haryana Pan: Aabct6693E Appellant Respondent Ita No. 3467/Del/2025 (A.Y. 2019-20) Dcit Vs Tayal Sons Private Limited Income Tax Office, 653A, Kath Mandi Road, Hisar, Sesctor14, Hisar, Haryana. Pan: Aabct6693E Appellant Respondent Assessee By Sh. Sh. Salil Kapoor, Adv, Ms. Ananya Kapoor, Adv, Ms. Ishitafarsiya, Adv, Ms. Soumya Singh, Adv& Ms. Sakshirustagi. Revenue By Ms. Amisha S. Gupt, Cit (Dr) Date Of Hearing 27/11/2025 Date Of Pronouncement 28/11/2025 Order Per Yogesh Kumar, U.S. Jm: The Captioned Two Appeals Are Filed By The Assessee & Two

reassessment. The phrase "to the extent provided in Section 144B of the Act" would mean that the restriction provided in Section 144B of the Act, such as keeping the International Tax Jurisdiction or Central Circle Jurisdiction Tayal sons Pvt. Ltd. Vs. DCIT out of the ambit of Section 144B of the Act would also apply under the Scheme. Further

DCIT, HISAR vs. TAYAL SONS PVT. LTD., HISAR

The Appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalita No. 3323/Del/2025 (A.Y. 2019-20) Tayal Sons Private Vs Dcit Limited Income Tax Office, Sesctor14, 653A, Kath Mandi Road, Hisar, Hisar, Haryana Pan: Aabct6693E Appellant Respondent Ita No. 3467/Del/2025 (A.Y. 2019-20) Dcit Vs Tayal Sons Private Limited Income Tax Office, 653A, Kath Mandi Road, Hisar, Sesctor14, Hisar, Haryana. Pan: Aabct6693E Appellant Respondent Assessee By Sh. Sh. Salil Kapoor, Adv, Ms. Ananya Kapoor, Adv, Ms. Ishitafarsiya, Adv, Ms. Soumya Singh, Adv& Ms. Sakshirustagi. Revenue By Ms. Amisha S. Gupt, Cit (Dr) Date Of Hearing 27/11/2025 Date Of Pronouncement 28/11/2025 Order Per Yogesh Kumar, U.S. Jm: The Captioned Two Appeals Are Filed By The Assessee & Two

reassessment. The phrase "to the extent provided in Section 144B of the Act" would mean that the restriction provided in Section 144B of the Act, such as keeping the International Tax Jurisdiction or Central Circle Jurisdiction Tayal sons Pvt. Ltd. Vs. DCIT out of the ambit of Section 144B of the Act would also apply under the Scheme. Further

TAYAL SONS PRIVATE LIMITED,HISAR vs. DCIT, HISAR

The Appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalita No. 3323/Del/2025 (A.Y. 2019-20) Tayal Sons Private Vs Dcit Limited Income Tax Office, Sesctor14, 653A, Kath Mandi Road, Hisar, Hisar, Haryana Pan: Aabct6693E Appellant Respondent Ita No. 3467/Del/2025 (A.Y. 2019-20) Dcit Vs Tayal Sons Private Limited Income Tax Office, 653A, Kath Mandi Road, Hisar, Sesctor14, Hisar, Haryana. Pan: Aabct6693E Appellant Respondent Assessee By Sh. Sh. Salil Kapoor, Adv, Ms. Ananya Kapoor, Adv, Ms. Ishitafarsiya, Adv, Ms. Soumya Singh, Adv& Ms. Sakshirustagi. Revenue By Ms. Amisha S. Gupt, Cit (Dr) Date Of Hearing 27/11/2025 Date Of Pronouncement 28/11/2025 Order Per Yogesh Kumar, U.S. Jm: The Captioned Two Appeals Are Filed By The Assessee & Two

reassessment. The phrase "to the extent provided in Section 144B of the Act" would mean that the restriction provided in Section 144B of the Act, such as keeping the International Tax Jurisdiction or Central Circle Jurisdiction Tayal sons Pvt. Ltd. Vs. DCIT out of the ambit of Section 144B of the Act would also apply under the Scheme. Further

DY. COMMISSIONER OF INCOME TAX, HISAR vs. M/S. TAYAL SONS PVT. LTD., HISAR

The Appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalita No. 3323/Del/2025 (A.Y. 2019-20) Tayal Sons Private Vs Dcit Limited Income Tax Office, Sesctor14, 653A, Kath Mandi Road, Hisar, Hisar, Haryana Pan: Aabct6693E Appellant Respondent Ita No. 3467/Del/2025 (A.Y. 2019-20) Dcit Vs Tayal Sons Private Limited Income Tax Office, 653A, Kath Mandi Road, Hisar, Sesctor14, Hisar, Haryana. Pan: Aabct6693E Appellant Respondent Assessee By Sh. Sh. Salil Kapoor, Adv, Ms. Ananya Kapoor, Adv, Ms. Ishitafarsiya, Adv, Ms. Soumya Singh, Adv& Ms. Sakshirustagi. Revenue By Ms. Amisha S. Gupt, Cit (Dr) Date Of Hearing 27/11/2025 Date Of Pronouncement 28/11/2025 Order Per Yogesh Kumar, U.S. Jm: The Captioned Two Appeals Are Filed By The Assessee & Two

reassessment. The phrase "to the extent provided in Section 144B of the Act" would mean that the restriction provided in Section 144B of the Act, such as keeping the International Tax Jurisdiction or Central Circle Jurisdiction Tayal sons Pvt. Ltd. Vs. DCIT out of the ambit of Section 144B of the Act would also apply under the Scheme. Further

TABLEAU INTERNATION UNLIMITED COPMANY THE OVAL SHELBOURNE ROAD OVEL BALLSBRIDGE DUBLIN,IRELAND D04E7K5,IRELAND vs. DCIT,CIRCLE3(1)(1) INTERNATIOANAL TAXATION , DELHI

Appeal stands allowed in terms as indicated above

Bench: Shri Kul Bharat & Dr. B.R.R. Kumarassessment Year: 2019-20

section 119. The power is given for the purpose of just, proper and efficient management of the work of assessment and in public interest. It is a beneficial power given to the Board for proper administration of fiscal law so that undue hardship may not be caused to the assessee and the fiscal laws may be correctly applied. Hard cases

PRAKASH INDUSTRIES LTD.,NEW DELHI vs. ACIT, CC- 30,, NEW DELHI

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

reassessed consequently. In other words, after the search, the assessment for the 6 preceding assessment years under section 153A has necessarily to take place and there is no scope for any abatement. This is what comes out from the bare reading of the provisions of section 153A of the act. This is also been held by the Hon'ble Delhi

ACIT, CENTRAL CIRCLE- 30, NEW DELHI vs. PRAKASH INDUSTRIES LTD., HISAR

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

reassessed consequently. In other words, after the search, the assessment for the 6 preceding assessment years under section 153A has necessarily to take place and there is no scope for any abatement. This is what comes out from the bare reading of the provisions of section 153A of the act. This is also been held by the Hon'ble Delhi

ACIT, CENTRAL CIRCLE- 30, NEW DELHI vs. PARKASH INDUSTRIES LTD, HISAR

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

reassessed consequently. In other words, after the search, the assessment for the 6 preceding assessment years under section 153A has necessarily to take place and there is no scope for any abatement. This is what comes out from the bare reading of the provisions of section 153A of the act. This is also been held by the Hon'ble Delhi

PRAKASH INDUSTRIES LTD.,NEW DELHI vs. ACIT, CC- 30,, NEW DELHI

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

reassessed consequently. In other words, after the search, the assessment for the 6 preceding assessment years under section 153A has necessarily to take place and there is no scope for any abatement. This is what comes out from the bare reading of the provisions of section 153A of the act. This is also been held by the Hon'ble Delhi

PRAKASH INDUSTRIES LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 30, NEW DELHI

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

reassessed consequently. In other words, after the search, the assessment for the 6 preceding assessment years under section 153A has necessarily to take place and there is no scope for any abatement. This is what comes out from the bare reading of the provisions of section 153A of the act. This is also been held by the Hon'ble Delhi

ACIT, CENTRAL CIRCLE- 30, NEW DELHI vs. PARKASH INDUSTRIES LTD, HISAR

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

reassessed consequently. In other words, after the search, the assessment for the 6 preceding assessment years under section 153A has necessarily to take place and there is no scope for any abatement. This is what comes out from the bare reading of the provisions of section 153A of the act. This is also been held by the Hon'ble Delhi

ACIT, CENTRAL CIRCLE- 30, NEW DELHI vs. PARKASH INDUSTRIES LTD, HISAR

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

reassessed consequently. In other words, after the search, the assessment for the 6 preceding assessment years under section 153A has necessarily to take place and there is no scope for any abatement. This is what comes out from the bare reading of the provisions of section 153A of the act. This is also been held by the Hon'ble Delhi

PRAKASH INDUSTRIES LTD.,NEW DELHI vs. ACIT, CC- 30,, NEW DELHI

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

reassessed consequently. In other words, after the search, the assessment for the 6 preceding assessment years under section 153A has necessarily to take place and there is no scope for any abatement. This is what comes out from the bare reading of the provisions of section 153A of the act. This is also been held by the Hon'ble Delhi

PRAKASH INDUSTRIES LTD.,NEW DELHI vs. ACIT, CC- 30,, NEW DELHI

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

reassessed consequently. In other words, after the search, the assessment for the 6 preceding assessment years under section 153A has necessarily to take place and there is no scope for any abatement. This is what comes out from the bare reading of the provisions of section 153A of the act. This is also been held by the Hon'ble Delhi

ACIT, CENTRAL CIRCLE- 30, NEW DELHI vs. PRAKASH INDUSTRIES LTD., HISAR

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

reassessed consequently. In other words, after the search, the assessment for the 6 preceding assessment years under section 153A has necessarily to take place and there is no scope for any abatement. This is what comes out from the bare reading of the provisions of section 153A of the act. This is also been held by the Hon'ble Delhi

PRAKASH INDUSTRIES LTD.,NEW DELHI vs. ACIT, CC- 30,, NEW DELHI

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

reassessed consequently. In other words, after the search, the assessment for the 6 preceding assessment years under section 153A has necessarily to take place and there is no scope for any abatement. This is what comes out from the bare reading of the provisions of section 153A of the act. This is also been held by the Hon'ble Delhi

PRAKASH INDUSTRIES LTD.,NEW DELHI vs. ACIT, CC- 30,, NEW DELHI

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

reassessed consequently. In other words, after the search, the assessment for the 6 preceding assessment years under section 153A has necessarily to take place and there is no scope for any abatement. This is what comes out from the bare reading of the provisions of section 153A of the act. This is also been held by the Hon'ble Delhi

BSES YAMUNA POWER LTD.,NEW DELHI vs. DCIT, CIRCLE- 5(1), NEW DELHI

The appeal of the assessee is allowed on legal issues

Bench: Shri Anubhav Sharma & Shri Manish Agarwalbses Rajdhani Power Ltd., Dy. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd., Asst. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Yamuna Power Dy. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd. & Ors Vs. Acit Bses Yamuna Power Asst. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv., Sh. Deepesh Jain, Adv. & Sh. Shivam Gupta, Ca Department By Mr. Javed Akhtar, Cit-Dr Date Of Hearing 20/02/2025 Date Of Pronouncement 16/04/2025 O R D E R

119 of PB). BSES Rajdhani Power Ltd. & Ors vs. ACIT 38. In the order dated 15.10.2014, the assessing officer failed to specifically dispose off, much less reject, the aforesaid legal objection [Refer pages 155-161 of PB), except cryptically repeating the language of proviso to section 147 @pg 160 (refer second last para) observing as under: The notice under section

BSES YAMUNA POWER LTD,DELHI vs. ACIT, CIRCLE-5(1), NEW DEL;HI

The appeal of the assessee is allowed on legal issues

Bench: Shri Anubhav Sharma & Shri Manish Agarwalbses Rajdhani Power Ltd., Dy. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd., Asst. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Yamuna Power Dy. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd. & Ors Vs. Acit Bses Yamuna Power Asst. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv., Sh. Deepesh Jain, Adv. & Sh. Shivam Gupta, Ca Department By Mr. Javed Akhtar, Cit-Dr Date Of Hearing 20/02/2025 Date Of Pronouncement 16/04/2025 O R D E R

119 of PB). BSES Rajdhani Power Ltd. & Ors vs. ACIT 38. In the order dated 15.10.2014, the assessing officer failed to specifically dispose off, much less reject, the aforesaid legal objection [Refer pages 155-161 of PB), except cryptically repeating the language of proviso to section 147 @pg 160 (refer second last para) observing as under: The notice under section