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, 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

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

M/S. SRI BALAJI FORGINGS (P) LTD.,NEW DELHI vs. PR. CIT- 8, NEW DELHI

In the result, appeal of Assessee is allowed

Bench: Shri Bhavnesh Saini, J.M. & Shri Prashant Maharishi, A.M.

133(6) of the I.T. Act to the Investors who have also replied directly to the A.O. Therefore, A.O. rightly accepted the credits as genuine. In view of the above finding, there is no need to give a finding in detail on merits. In view of the above, we allow the appeal of assessee. 7. In the result, ITA.No.2269/Del

ITO, NEW DELHI vs. M/S. ARIZONA VENUTRES PVT. LTD., NEW DELHI

In the result, both the appeals of the Revenue are dismissed

Bench: Shri Amit Shukla & Shri Prashant Maharishi

section 143(3) of the I.T. Act, 1961. Not only there is no penalty notice issued u/s 271(1)(b) in our case, there is no adverse comment against the assessee on the order sheet of the assessment proceedings with regard to any lapses. 2 Page 6 AO stated that The contention of the AO is wrong. In Para

CHARBUJA MARMO (INDIA) PVT. LTD.,DELHI vs. PR.CIT- 2 , NEW DELHI

In the result, appeal of Assessee allowed

Bench: Shri Bhavnesh Saini & Shri B.R.R. Kumar

133(6) of the I.T. Act to the Investors who have also replied directly to the A.O. Therefore, A.O. rightly accepted the credits as genuine. In view of the above finding, there is no need to give a finding in detail on merits. In view of the above, we allow the appeal of assessee. 7. In the result, ITA.No.2269/Del

SUPERIOR BUILDWELL PVT. LTD.,DELHI vs. PR. CIT- 8, NEW DELHI

In the result, appeal of the Assessee is allowed

Bench: Shri Bhavnesh Saini, J.M. & Shri Prashant Maharishi, A.M.

133(6) of the I.T. Act to the Investors who have also replied directly to the A.O. Therefore, A.O. rightly accepted the credits as genuine. In view of the above finding, there is no need to give a finding in detail on merits. In view of the above, we allow the appeal of assessee. 7. In the result, ITA.No.2269/Del

M/S. SHIV SAI INFRASTRUCTURE (P) LTD.,NEW DELHI vs. PR. CIT- 8, NEW DELHI

In the result, appeal of the Assessee is allowed

Bench: Shri Bhavnesh Saini, J.M. & Shri Prashant Maharishi, A.M.

133(6) of the I.T. Act to the Investors who have also replied directly to the A.O. Therefore, A.O. rightly accepted the credits as genuine. In view of the above finding, there is no need to give a finding in detail on merits. In view of the above, we allow the appeal of assessee. 7. In the result, ITA.No.2269/Del

M/S. SUPERSONIC TECHNOLOGIES PVT. LTD.,DELHI vs. PR. CIT- 8, NEW DELHI

In the result, appeal of the Assessee is allowed

Bench: Shri Bhavnesh Saini, J.M. & Shri Prashant Maharishi, A.M.

133(6) of the I.T. Act to the Investors who have also replied directly to the A.O. Therefore, A.O. rightly accepted the credits as genuine. In view of the above finding, there is no need to give a finding in detail on merits. In view of the above, we allow the appeal of assessee. 7. In the result, ITA.No.2269/Del

M/S. SPJ HOTELS PVT. LTD.,DELHI vs. PR. CIT- 8, NEW DELHI

In the result, appeal of the Assessee is allowed

Bench: Shri Bhavnesh Saini, J.M. & Shri Prashant Maharishi, A.M.

133(6) of the I.T. Act to the Investors who have also replied directly to the A.O. Therefore, A.O. rightly accepted the credits as genuine. In view of the above finding, there is no need to give a finding in detail on merits. In view of the above, we allow the appeal of assessee. 7. In the result, ITA.No.2269/Del

ITO, NEW DELHI vs. M/S. RANDEEP INVESTMENT PVT. LTD., NEW DELHI

In the result, the appeal of the assessee is allowed and that of the Revenue is dismissed

Bench: : Shri H.S. Sidhu & Shri L.P. Sahu

133(6), the above 4 share subscribers/Cos. confirmed their share subscriptions, copies of their replies are placed at pages pages 177-183, 296-302, 361-370 and 445-446 of paper book. This fact has also been admitted by the AO in his remand report, copy placed at pages 454-457 of the paper book. 3. Moreover, no documentary evidence

M/S. RANDEEP INVESTMENT PVT. LTD.,NEW DELHI vs. ITO, NEW DELHI

In the result, the appeal of the assessee is allowed and that of the Revenue is dismissed

Bench: : Shri H.S. Sidhu & Shri L.P. Sahu

133(6), the above 4 share subscribers/Cos. confirmed their share subscriptions, copies of their replies are placed at pages pages 177-183, 296-302, 361-370 and 445-446 of paper book. This fact has also been admitted by the AO in his remand report, copy placed at pages 454-457 of the paper book. 3. Moreover, no documentary evidence

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