EBRO INDIA PVT.LTD. ,DELHI vs. ACIT CIRCLE-7(1), DELHI

In the result, the ground no 4 raised by the assessee is allowed

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

section 1448 of IT Act, the case was duly transferred to the jurisdiction AO, who has no previous idea about the assessment proceedings in the case. However it is pointed out, that, even during the DRP stage and even after providing opportunity by AO, the assessee could not submit any evidence with respect to bank statement of assessee and also

MAHARASHTRA FEEDS P. LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE, FARIDABAD

In the result, the appeals of the assessee are allowed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

reassessment, tax shall be calculated on the aggregate of the total income as assessed in the earlier proceeding for assessment under section 143 or section 144 or section 147 and the income disclosed in the application as if such aggregate were the total income. FORM NO. 34B [See rules 44C and 44CA] Form of application for settlement of case under

MAHARASHTRA FEEDS P. LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE, FARIDABAD

In the result, the appeals of the assessee are allowed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

reassessment, tax shall be calculated on the aggregate of the total income as assessed in the earlier proceeding for assessment under section 143 or section 144 or section 147 and the income disclosed in the application as if such aggregate were the total income. FORM NO. 34B [See rules 44C and 44CA] Form of application for settlement of case under

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

13. While it is true that Section 153C and the procedure prescribed therein had ceased to be applicable post 31 March 2021, the First Proviso to Section 149(1) does not appear to suggest that the First Proviso to Section 153C(1) would either become inapplicable or be liable to be ignored. Undisputedly, the First Proviso to Section 153C(1

COMMISSIONER OF WEALTH TAX vs. S.S. AHLUWALIA

13) The provisions indicate that Sections 120, 124 and 127 of the Act recognizes flexibility and choice, both with the assessee and the authorities i.e. the Assessing Office before whom return of income could be filed and assessment could be made. The Assessing Officer within whose area an assessee was carrying on business, resided or otherwise income had accrued

RAKESH KUMAR GUPTA,DELHI vs. LD. ITO, WARD 35(1), DELHI, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2021-22] Rakesh Kumar Gupta, Income Tax Officer, Ward-35(1), B-2/38, Ground Floor, E-2, Civic Centre, Delhi-110002 Ashok Vihar, Phase-Ii, Vs Delhi-110052 Pan-Aafhr8657H Appellant Respondent

reassessment, referred to in clause (a) of subsection (1), in a case where an order under sub- section (4) has been made accepting the application." 22. As is evident from a reading of Section 270A(1), a person would be liable to be considered to have under reported its income if the contingencies spoken of in clauses

DHARAMVIR KHOSLA ,. vs. DCIT CC-5, NEW DELHI , .

The appeals are allowed for statistical purposes and ld

13\nITA Nos. 3976 & 3977/Del/2025\nDharamvirKhosla (AY: 2019-20 & 2020-21)\n10. The reliance on the decision of the Apex Court in Sun Engineering\nWorks (P.) Ltd. (supra) by the Revenue is misplaced. The above case dealt\nwith re-opening of an assessment under Section 147 of the Act. It was in\nthat context that the Apex Court observed that

DCIT CENTRAL CIRCLE-14, NEW DELHI vs. SH. VIJAY KUMAR SONI, NEW DELHI

The appeal of the Revenue is dismissed as infructuous

Bench: Dr. B. R. R. Kumarsh. Sudhir Kumarita No. 1883/Del/2023 : Asstt. Year : 2017-18 Bijay Kumar Soni, Vs Dcit, C/O Anil Jain Dd & Co., Central Circle-14, 611, Surya Kiran Building, 19, New Delhi-110055 K. G. Marg, New Delhi-110001 (Appellant) (Respondent) Pan No. Aolps5917H Ita No. 2144/Del/2023 : Asstt. Year : 2017-18 Dcit, Vs Bijay Kumar Soni, Central Circle-14, 61/14, Block No. 61, Ram Jas, New Delhi-110055 Karol Bagh, New Delhi-110005 (Appellant) (Respondent) Pan No. Aolps5917H Assessee By : Sh. Anil Jain, Ca Revenue By : Ms. Monika Dhami, Cit-Dr Date Of Hearing: 01.08.2023 Date Of Pronouncement: 06.09.2023 Order Per Dr. B. R. R. Kumar:

13 Vijay Kumar Soni ”153A. (1) Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st

BIJAY KUMAR SONI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-14, NEW DELHI

The appeal of the Revenue is dismissed as infructuous

Bench: Dr. B. R. R. Kumarsh. Sudhir Kumarita No. 1883/Del/2023 : Asstt. Year : 2017-18 Bijay Kumar Soni, Vs Dcit, C/O Anil Jain Dd & Co., Central Circle-14, 611, Surya Kiran Building, 19, New Delhi-110055 K. G. Marg, New Delhi-110001 (Appellant) (Respondent) Pan No. Aolps5917H Ita No. 2144/Del/2023 : Asstt. Year : 2017-18 Dcit, Vs Bijay Kumar Soni, Central Circle-14, 61/14, Block No. 61, Ram Jas, New Delhi-110055 Karol Bagh, New Delhi-110005 (Appellant) (Respondent) Pan No. Aolps5917H Assessee By : Sh. Anil Jain, Ca Revenue By : Ms. Monika Dhami, Cit-Dr Date Of Hearing: 01.08.2023 Date Of Pronouncement: 06.09.2023 Order Per Dr. B. R. R. Kumar:

13 Vijay Kumar Soni ”153A. (1) Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st

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

Section 164.'. Thus, as held in CIT v. Anjum\nM.H.Ghaswala 119 Taxman 352/252 ITR 1 (SC), by the Constitutional Bench that\n'it is a normal rule of construction that when a statue vests certain powers in a\nauthority to be exercised in a particular manner then the said authority has to\nexercise it only in the manner provided

A2Z MAINTENANCE & ENGINEERING SERVICES LTD.,GURGAON vs. DCIT, CENTRAL CIRCLE-II, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

DCIT-CENTRAL CIRCLE-2, FARIDABAD vs. A2Z INFRA ENGINEERS LTD., GURGAON

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT CC-2 , FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. CCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

INFRA ENGINEERS LTD.,GURGAON vs. DCIT, CC-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

DCIT CC-2 , FARIDABAD vs. A2Z MAINTENANCE AND ENGINEERING SERVICES LTD., GURGAON

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made