DCIT, CENTRAL CIRCLE-20, NEW DELHI vs. LOTUS HERBALS P.LTD, DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment proceedings, the Assessing Officer has issues summons u/s 133(6) of the Act to various parties, out of which four parties namely (i) M/s Krishna Attire & Hospitality Services (Krishna Attire) Rs.7,46,697/- (ii) M/s Shan Creations - Rs.25,69,331/- (iii) M/s Brand Vision - Rs.8,00,000/- and (iv) Symmetrix Prints Pvt. Ltd. (‘Symmetrix Prints)- Rs.1

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment proceedings, the Assessing Officer has issues summons u/s 133(6) of the Act to various parties, out of which four parties namely (i) M/s Krishna Attire & Hospitality Services (Krishna Attire) Rs.7,46,697/- (ii) M/s Shan Creations - Rs.25,69,331/- (iii) M/s Brand Vision - Rs.8,00,000/- and (iv) Symmetrix Prints Pvt. Ltd. (‘Symmetrix Prints)- Rs.1

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment proceedings, the Assessing Officer has issues summons u/s 133(6) of the Act to various parties, out of which four parties namely (i) M/s Krishna Attire & Hospitality Services (Krishna Attire) Rs.7,46,697/- (ii) M/s Shan Creations - Rs.25,69,331/- (iii) M/s Brand Vision - Rs.8,00,000/- and (iv) Symmetrix Prints Pvt. Ltd. (‘Symmetrix Prints)- Rs.1

DCIT, CENTRAL CIRCLE-20, DELHI vs. LOTUS HERBALS PVT. LTD, DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment proceedings, the Assessing Officer has issues summons u/s 133(6) of the Act to various parties, out of which four parties namely (i) M/s Krishna Attire & Hospitality Services (Krishna Attire) Rs.7,46,697/- (ii) M/s Shan Creations - Rs.25,69,331/- (iii) M/s Brand Vision - Rs.8,00,000/- and (iv) Symmetrix Prints Pvt. Ltd. (‘Symmetrix Prints)- Rs.1

COSMIC INFORMATICS PVT. LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE - 2, NEW DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment proceedings, the Assessing Officer has issues summons u/s 133(6) of the Act to various parties, out of which four parties namely (i) M/s Krishna Attire & Hospitality Services (Krishna Attire) Rs.7,46,697/- (ii) M/s Shan Creations - Rs.25,69,331/- (iii) M/s Brand Vision - Rs.8,00,000/- and (iv) Symmetrix Prints Pvt. Ltd. (‘Symmetrix Prints)- Rs.1

COSMIC INFORMATICS PVT. LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE - 2, NEW DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment proceedings, the Assessing Officer has issues summons u/s 133(6) of the Act to various parties, out of which four parties namely (i) M/s Krishna Attire & Hospitality Services (Krishna Attire) Rs.7,46,697/- (ii) M/s Shan Creations - Rs.25,69,331/- (iii) M/s Brand Vision - Rs.8,00,000/- and (iv) Symmetrix Prints Pvt. Ltd. (‘Symmetrix Prints)- Rs.1

ARGOS HOLDINGS PTE. LTD.,SINGAPORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE INT TAX 1(1)(1), DELHI, DELHI

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

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

133(6) of the Income Tax Act, 1961, by SVHPL. Perusal of the bank statement of AHPL for the for the relevant F.Y. shows that throughout the year, the only transaction has been of a credit entry of 74,100,000 USD from Ephesus Pte Ltd and debit entry of same amount to SVHPL. This highlights the fact that AHPL

ARGOS HOLDINGS PTE. LTD.,SINGAPORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE INT TAX 1(1)(1), DELHI, DELHI

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

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

133(6) of the Income Tax Act, 1961, by SVHPL. Perusal of the bank statement of AHPL for the for the relevant F.Y. shows that throughout the year, the only transaction has been of a credit entry of 74,100,000 USD from Ephesus Pte Ltd and debit entry of same amount to SVHPL. This highlights the fact that AHPL

DCIT, CC-15, NEW DELHI vs. BDR BUILDERS & DEVELOPERS P. LTD., NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usasstt. Year: 2012-13 Dcit, Vs. Bdr Builders & Developers P. Ltd,B- Central Circle-15, 393, Zakir Nagar So, South East Delhi, New Delhi New Delhi-1100025 (Appellant) (Respondent) Pan No. Assessee By : Dr. Rakesh Gupta, Adv. Revenue By : Sh. Kanv Bali, Sr. Dr Date Of Hearing: 28.02.2023 Date Of Pronouncement: 16.03.2023

133(6), cannot form the valid basis for reaching to the "reasons to believe" for "escapement of income" in the hands of the appellant. It appears that these incomplete notices were issued without application of mind in a mechanical manner to just do formality of paper work to show that the AO had applied his mind independently. Such action

YOUNG INDIAN,NEW DELHI vs. ACIT(E), NEW DELHI

Bench: Shri Anil Chaturvedi & Shri Amit Shukla(Through Video Conference)

Section 133(6) of the Income Tax Act, has created a legal facade, to with-hold the information available with the assessee, It has not been explained by the A/R that when the information sought u/s 133(6) of the I.T. Act, is not available with the department, how come the inspection of the records of the department will facilitate

MAHAVIR TRANSMISSIN LTD ,NEW DELHI vs. DCIT, CENTRAL CIRCLE-25 , NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

reassessment framed under section 153A r.w.s 143(3) are in ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. violation of mandatory provisions of Section 153D of the Act and as such the same is bad in eyes of law. (ii) That the CIT(A) has erred in ignoring the contention of the assessee that the purported approval

DCIT, CENTRAL CIRCLE-25, NEW DELHI vs. MAHAVEER TRANSMISSION LTD, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

reassessment framed under section 153A r.w.s 143(3) are in ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. violation of mandatory provisions of Section 153D of the Act and as such the same is bad in eyes of law. (ii) That the CIT(A) has erred in ignoring the contention of the assessee that the purported approval

MAHAVIR TRANSMISSION LTD,NEW DELHI vs. DCIT, CENTRAL CIRCLE-25, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

reassessment framed under section 153A r.w.s 143(3) are in ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. violation of mandatory provisions of Section 153D of the Act and as such the same is bad in eyes of law. (ii) That the CIT(A) has erred in ignoring the contention of the assessee that the purported approval

MAHAVIR TRANSMISSION LTD,NEW DELHI vs. DCIT, CENTRAL CORCLE-25, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

reassessment framed under section 153A r.w.s 143(3) are in ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. violation of mandatory provisions of Section 153D of the Act and as such the same is bad in eyes of law. (ii) That the CIT(A) has erred in ignoring the contention of the assessee that the purported approval

DCIT, CENTRAL CIRCLE-25, NEW DELHI vs. MAHAVEER TRANSMISSION LTD., NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

reassessment framed under section 153A r.w.s 143(3) are in ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. violation of mandatory provisions of Section 153D of the Act and as such the same is bad in eyes of law. (ii) That the CIT(A) has erred in ignoring the contention of the assessee that the purported approval

DCIT, CENTRAL CIRCLE-25, NEW DELHI vs. MAHAVEER TRANSMISSION LTD, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

reassessment framed under section 153A r.w.s 143(3) are in ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. violation of mandatory provisions of Section 153D of the Act and as such the same is bad in eyes of law. (ii) That the CIT(A) has erred in ignoring the contention of the assessee that the purported approval

MAHAVIR TRANSMISSION LTD,NEW DELHI vs. DCIT, CENTRAL CIRCLE-25, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

reassessment framed under section 153A r.w.s 143(3) are in ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. violation of mandatory provisions of Section 153D of the Act and as such the same is bad in eyes of law. (ii) That the CIT(A) has erred in ignoring the contention of the assessee that the purported approval

ACIT CENTRAL CIRCLE, PANIPAT vs. KUNDAN RICE MILLS LTD., PANIPAT

In the result, assessee’s appeals are allowed, whereas,

Bench: Shri Saktijit Dey & Shri M. Balaganesh

133(6) as well as summons under section 131 of the Act, as, the concerned parties were never found. Thus, she submitted, the identity of the parties remained unverifiable. She submitted, since, the survey operation was carried out along with search operation, wherein genuineness of sales made to M/s. Dee Kay Trade Centre and M/s. J.S. Enterprises could

KUNDAN RICE MILLS LTD.,PANIPAT vs. ACIT CENTRAL CIRCLE, KARNAL

In the result, assessee’s appeals are allowed, whereas,

Bench: Shri Saktijit Dey & Shri M. Balaganesh

133(6) as well as summons under section 131 of the Act, as, the concerned parties were never found. Thus, she submitted, the identity of the parties remained unverifiable. She submitted, since, the survey operation was carried out along with search operation, wherein genuineness of sales made to M/s. Dee Kay Trade Centre and M/s. J.S. Enterprises could