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

2) of the earlier\nIncome Tax Act, 1922 (11 of 1922). There is, however this difference\nbetween these two provisions that whereas Section 124 fixes jurisdiction,\nterritorial or otherwise, of the Income Tax Officers, Section 64 fixed the\nplace where an assessee was to be assessed. xxx xxxxxxxXX\n9. It is in the light of these considerations that we have

VISHAN GUNNA,HYDERABAD vs. ACIT CIRCLE INT. TAX 1(3)(1), NEW DELHI, INCOME TAX

In the result, appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2021-22] Vishan Gunna, Vs Acit, Plot No.550, House No.- Circle-Int.Tex 1(3)(1), 8-3-293/83/J-Iii, Road New Delhi. No.92, Jubilee Hills, Telangana-500033. Pan-Bmypg5434R Appellant Respondent Appellant By Shri R.Mohan Kumar, Adv. Respondent By Shri Abhishek Sharma, Cit Dr Date Of Hearing 07.05.2025 Date Of Pronouncement 25.07.2025

Reassessment order can be by a different officer)." 19. We would reiterate that sub-section (1) to Section 124 states that the Assessing Officer would have jurisdiction over the area in terms of any direction or order issued under sub- section (1) or sub-section (2) to Section 120 of the Act. Jurisdiction would depend upon the place where

SHRI CHETAN SETH,NEW DELHI vs. ITO, NEW DELHI

The appeals of the assessee are partly allowed

Bench: Shri Satbeer Singh Godara\Nand\Nshri Brajesh Kumar Singh\Nita Nos.1808/Del/2023 & 2983, 2984 & 2985/Del/2015\N[Assessment Years: 2004-05, 2005-06, 2006-07 & 2007-08]\Nshri Chetan Seth,\Nplot No.14, Lcs, Sector-B-1,\Nvasant Kunj,\Nnew Delhi-110070\Npan-Aolps2992A\Nappellant\Nincome Tax Officer,\Nward-15(3),\Nvs New Delhi\Nrespondent\Nappellant By\Nrespondent By\Nshri Arun Kishore, Ca &\Nshri Alok Suri, Ca\Nshri Rajesh Kumar Dhanesta, Sr.\N(Dr)\Ndate Of Hearing\Ndate Of Pronouncement\N28.03.2025\N25.06.2025\Norder\Nper Brajesh Kumar Singh, Am,\Nthese Four Appeals Filed By The Assessee Are Directed Against The\Norder Of Ld. Commissioner Of Income Tax (Appeals)-7, Delhi, Dated\N24.02.2015 For Ay 2004-05, 27.02.2015 For Ay 2005-06, 2006-07 And\N2007-08 Respectively Arising Out Of Assessment Orders Passed U/S 147/144\Nof The Income Tax Act, 1961 (Hereinafter Referred To ‘The Act') Dated\N31.10.2011 For All The Above Assessment Years, Respectively. Since, The\Nissues Are Common & Connected, Hence, These Appeals Were Heard\Ntogether & Are Disposed Of By This Common Order.\N2. First, We Shall Take Up The Ita No.1808/Del/2023 Pertaining To Ay\N2004-05.\N2.

127", "129", "234A", "234B", "234D", "244A", "143(1)", "143(3)", "153", "154", "155", "150(1)", "150(2)" ], "issues": "1. Condonation of delay in filing appeal due to alleged negligence of previous counsel. 2. Taxability of loan/advances as deemed dividend under Section 2(22)(e) in the hands of the shareholder. 3. Validity of reassessment

JSP PROJECTS (P) LTD,DELHI vs. DCIT CENTRAL CIRCLE - 13, DELHI

In the result appeal of the assessee in ITA number 3646/Del/2025 and

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

reassessment proceedings u/s 153C cannot per se be regarded as incriminating material available with the Assessing Officer; That the assessment order passed under section 153C of the Income Tax Act, 1961 is bad in law, void ab initio, and without jurisdiction, and therefore deserves to be quashed. Initiation of Proceedings barred by limitation - 'Cash Credit' is not asset 2. That

JSP PROJECTS (P) LTD,DELHI vs. DCIT CENTRAL CIRCLE -13, DELHI

In the result appeal of the assessee in ITA number 3646/Del/2025 and

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

reassessment proceedings u/s 153C cannot per se be regarded as incriminating material available with the Assessing Officer; That the assessment order passed under section 153C of the Income Tax Act, 1961 is bad in law, void ab initio, and without jurisdiction, and therefore deserves to be quashed. Initiation of Proceedings barred by limitation - 'Cash Credit' is not asset 2. That

JSP PROJECTS (P) LTD,DELHI vs. DCIT CENTRAL CIRCLE - 13, DELHI

In the result appeal of the assessee in ITA number 3646/Del/2025 and

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

reassessment proceedings u/s 153C cannot per se be regarded as incriminating material available with the Assessing Officer; That the assessment order passed under section 153C of the Income Tax Act, 1961 is bad in law, void ab initio, and without jurisdiction, and therefore deserves to be quashed. Initiation of Proceedings barred by limitation - 'Cash Credit' is not asset 2. That

JSP PROJECTS (P) LTD,DELHI vs. DCIT CENTRAL CIRCLE - 13, DELHI

In the result appeal of the assessee in ITA number 3646/Del/2025 and

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

reassessment proceedings u/s 153C cannot per se be regarded as incriminating material available with the Assessing Officer; That the assessment order passed under section 153C of the Income Tax Act, 1961 is bad in law, void ab initio, and without jurisdiction, and therefore deserves to be quashed. Initiation of Proceedings barred by limitation - 'Cash Credit' is not asset 2. That

JSP PROJECTS (P) LTD,DELHI vs. DCIT CENTRAL CIRCLE - 13, DELHI

In the result appeal of the assessee in ITA number 3646/Del/2025 and

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

reassessment proceedings u/s 153C cannot per se be regarded as incriminating material available with the Assessing Officer; That the assessment order passed under section 153C of the Income Tax Act, 1961 is bad in law, void ab initio, and without jurisdiction, and therefore deserves to be quashed. Initiation of Proceedings barred by limitation - 'Cash Credit' is not asset 2. That

CHETAN SETH,NEW DELHI vs. ITO,WARD-15(3), DELHI

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

127 of the Act for transfer of jurisdiction from Ward - 15(1) to Ward - 15(3). ii) That the assessment so made and all consequent orders be annulled. 6. Current account wrongly classified as loan or advance: That the Ld. CIT(A) and Ld. AO have erred in law and on facts by upholding and making addition u/s 2

SHRI CHETAN SETH,NEW DELHI vs. ITO, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

127 of the Act for transfer of jurisdiction from Ward - 15(1) to Ward - 15(3). ii) That the assessment so made and all consequent orders be annulled. 6. Current account wrongly classified as loan or advance: That the Ld. CIT(A) and Ld. AO have erred in law and on facts by upholding and making addition u/s 2

SHRI CHETAN SETH,NEW DELHI vs. ITO, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

127 of the Act for transfer of jurisdiction from Ward - 15(1) to Ward - 15(3). ii) That the assessment so made and all consequent orders be annulled. 6. Current account wrongly classified as loan or advance: That the Ld. CIT(A) and Ld. AO have erred in law and on facts by upholding and making addition u/s 2

ISWAR CHAND DUBEY,DELHI vs. ITO,WARD-68 (1), DELHI

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

127 of the Act for transfer of jurisdiction from Ward - 15(1) to Ward - 15(3). ii) That the assessment so made and all consequent orders be annulled. 6. Current account wrongly classified as loan or advance: That the Ld. CIT(A) and Ld. AO have erred in law and on facts by upholding and making addition u/s 2

PUNIT KUMAR AGGARWAL,DELHI vs. ITO,WARD-36(2), DELHI

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

127 of the Act for transfer of jurisdiction from Ward - 15(1) to Ward - 15(3). ii) That the assessment so made and all consequent orders be annulled. 6. Current account wrongly classified as loan or advance: That the Ld. CIT(A) and Ld. AO have erred in law and on facts by upholding and making addition u/s 2

MICROSOFT CORPORATION (INDIA) PRIVATE LIMITED,NEW DELHI vs. DCIT, CIRCLE-16(1), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Usmicrosoft Corporation (India) Vs. Dcit, Pvt. Ltd, Circle-16(1), 807, New Delhi House, New Delhi Barakhamba Road, New Delhi (Appellant) (Respondent) Pan: Aaacm5586C Assessee By : Shri Nageswar Rao & Parth, Adv Revenue By: Shri Rajesh Kumar, Cit(Dr) Date Of Hearing 22/02/2024 Date Of Pronouncement 28/02/2024

127; or (d) exercise of jurisdiction in case of change of incumbency as referred to in section 129, so as to impart greater efficiency, transparency and accountability by— (i) eliminating the interface between the income-tax authority and the assessee or any other person, to the extent technologically feasible; (ii) optimising utilisation of the resources through economies of scale

MEENA SWARUP,NEW DELHI vs. DCIT CIRCLE-3(1)(2), NEW DELHI

In the result, appeal of the assessee is allowed

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2014-15] Mrs. Meena Swarup, Vs Dcit, 397, Mandakini Enclave, Circle-3(1)(2), New Delhi-110019. Intl. Tax., Pan-Amrps5792E New Delhi. Appellant Respondent Appellant By Shri R.S.Ahuja, Ca & Shri P.S.Sodhi, Adv. Respondent By Shri Dheeraj Kumar Jain, Sr.Dr Date Of Hearing 01.07.2025 Date Of Pronouncement 19.09.2025 Order Per Manish Agarwal, Am :

reassessment, it shall be deemed that any notice under any of the provision of the Act, which is required to be served upon him, has been duly served upon him in time in accordance with the provisions of the Act and such assessee shall be precluded from taking any objection in any proceeding or inquiry under the Act that

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

In the result, all the appeals for Assessment Years 2013-14 to 2022-23 in ITA

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 4153 & 4008/Del/2025 (Assessment Year: 2012-13 & 2018-19) Dcit, Proform Interiors Pvt. Ltd., Central Circle-20, Ground Floor, Jmd Regent Room No. 269A, 2Nd Floor, Vs. Plaza, Mg Road, Gurgaon, Ara Centre, Jhandewalan Haryana-122001. Extn., Delhi-110055. Pan-Aahcs5999J

reassessment u/s 147 r.w.s. 148 which is special mechanism for bringing to tax the income discovered in consequence of a search. Although Sec.148 (inserted w.e.f. 01.04.2021) does not begin with a non- obstante clause similar to the erstwhile section 153A, its context and Explanation- 2 makes it clear that where a search is initiated, the jurisdiction thereafter must flow through

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

VENETIAN LDF PROJECTS LLP,GURGAON vs. ACIT CIRCLE-4(1), GURGAON

In the result, grounds raised by the assessee are dismissed

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

127 It is submitted that during the relevant assessment year, the appellant recorded purchase of traded goods amounting to INR14,626.25 crores in its statement of profit and loss, which was duly disclosed in “Note 18 to the Audited Financial Statements – Purchase of traded goods” (filed before AO vide reply dated 12.07.2022 @ page 487 of the paperbook