PR. COMMISSIONER OF INCOME TAX CENTRAL 2 NEW DELHI vs. MEETA GUTGUTIA PROP M/S FERNS N PETALS

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE CHANDER SHEKHAR

5,09,343 was held to be justified and correct. It was duly accounted for under „liabilities‟ and transferred to income in a phased manner. This was not done by manipulating the account books of the Assessee as alleged by the Revenue. This would have been evident had the return been picked up for scrutiny under Section

PR COMMISSIONER OF INCOME TAX CENTRAL -2 vs. MEETA GUTGUTIA PROP M/S FERNS N PETALS

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE CHANDER SHEKHAR

5,09,343 was held to be justified and correct. It was duly accounted for under „liabilities‟ and transferred to income in a phased manner. This was not done by manipulating the account books of the Assessee as alleged by the Revenue. This would have been evident had the return been picked up for scrutiny under Section

PR. COMMISSIONER OF INCOME TAX CENTRAL 2 NEW DELHI vs. MEETA GUTGUTIA PROP M/S FERSN N PETALS

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE CHANDER SHEKHAR

5,09,343 was held to be justified and correct. It was duly accounted for under „liabilities‟ and transferred to income in a phased manner. This was not done by manipulating the account books of the Assessee as alleged by the Revenue. This would have been evident had the return been picked up for scrutiny under Section

CAIRN UK HOLDING LTD.,AHMEDABAD vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

In the result ground No. 5 of the appeal of the assessee is allowed

Bench: Shri H. S. Sidhu & Shri Prashant Maharishi

133A of the Act by the Department on 15 January 2014. The AO failed to appreciate that all relevant facts were available with the Department several years prior to the above referenced survey. 5. Incorrect levy of interest under Section 234A and 234B of the Act 5.1. The AO has erred in and the DRP has further erred in confirming

BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE-18, DELHI

In the result, the appeals of the revenue in ITA No

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

5. Heard rival submissions, perused the orders of the authorities below. The issue as to whether the Ld. CIT(A) is empowered to give directions to the AO to initiate reassessment proceedings u/s.148 of the Act, came up for consideration before the coordinate Bench of ITAT Jaipur in the case of DCIT Vs. Sh. Vaibhav Banka Aakarshan reported

BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-18, NEW DELHI

In the result, the appeals of the revenue in ITA No

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

5. Heard rival submissions, perused the orders of the authorities below. The issue as to whether the Ld. CIT(A) is empowered to give directions to the AO to initiate reassessment proceedings u/s.148 of the Act, came up for consideration before the coordinate Bench of ITAT Jaipur in the case of DCIT Vs. Sh. Vaibhav Banka Aakarshan reported

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

5. Mr. Sandeep Goyal, Advocate for the petitioner(s) submits that notice dated 28.03.2024 issued under Section 148 is in contravention of notification dated 29.03.2022 as well as Section 151A of 1961 Act whereby concept of Faceless Assessment has been introduced. A Division Bench of Telangana High Court in 'KankanalaRavindra Reddy v. Income-Tax Officer [2023] 156 taxmann.com 178/295 Taxman

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

5. Mr. Sandeep Goyal, Advocate for the petitioner(s) submits that notice dated 28.03.2024 issued under Section 148 is in contravention of notification dated 29.03.2022 as well as Section 151A of 1961 Act whereby concept of Faceless Assessment has been introduced. A Division Bench of Telangana High Court in 'KankanalaRavindra Reddy v. Income-Tax Officer [2023] 156 taxmann.com 178/295 Taxman

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

5. Mr. Sandeep Goyal, Advocate for the petitioner(s) submits that notice dated 28.03.2024 issued under Section 148 is in contravention of notification dated 29.03.2022 as well as Section 151A of 1961 Act whereby concept of Faceless Assessment has been introduced. A Division Bench of Telangana High Court in 'KankanalaRavindra Reddy v. Income-Tax Officer [2023] 156 taxmann.com 178/295 Taxman

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

5. Mr. Sandeep Goyal, Advocate for the petitioner(s) submits that notice dated 28.03.2024 issued under Section 148 is in contravention of notification dated 29.03.2022 as well as Section 151A of 1961 Act whereby concept of Faceless Assessment has been introduced. A Division Bench of Telangana High Court in 'KankanalaRavindra Reddy v. Income-Tax Officer [2023] 156 taxmann.com 178/295 Taxman

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

5. It is respectfully submitted that Section 148B and Section 153D of the Act are pari materia, both embodying a statutory safeguard requiring prior approval by a higher authority before framing assessment orders. While Section 153D uses the expression "each assessment year" and Section 148B employs the phrase "an assessment year", the legislative intent in both provisions is identical-namely

DY. COMMISSIONER OF INCOME TAX, NOIDA vs. M/S ACE MEGA STRUCTURE PRIVATE LIMITED, NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

133A, other than under sub- section (2A) or sub-section (5) of that section, on or after the 1st day of April, 2021, in the case of the assessee; or (iii) the Assessing Officer is satisfied, with the prior approval of the Principal Commissioner or Commissioner, that any money, bullion, jewellery or other valuable article or thing, seized or requisitioned

ACE MEGA STRUCTURES PRIVATE LIMITED,UTTAR PRADESH vs. DCIT/ACIT CEN CIR, NOIDA, NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

133A, other than under sub- section (2A) or sub-section (5) of that section, on or after the 1st day of April, 2021, in the case of the assessee; or (iii) the Assessing Officer is satisfied, with the prior approval of the Principal Commissioner or Commissioner, that any money, bullion, jewellery or other valuable article or thing, seized or requisitioned

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

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

reassessment under section 147 shall abate.Assessments under section 153A i.e, “Assessment in case of search or requisition” shall not abate by operation of section 153A itself. In the year of search, no notice has to be issued under section 153A consequent to a search. However in the 6 preceding years, notice under 153A has to be mandatorily issued

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

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

reassessment under section 147 shall abate.Assessments under section 153A i.e, “Assessment in case of search or requisition” shall not abate by operation of section 153A itself. In the year of search, no notice has to be issued under section 153A consequent to a search. However in the 6 preceding years, notice under 153A has to be mandatorily issued

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

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

reassessment under section 147 shall abate.Assessments under section 153A i.e, “Assessment in case of search or requisition” shall not abate by operation of section 153A itself. In the year of search, no notice has to be issued under section 153A consequent to a search. However in the 6 preceding years, notice under 153A has to be mandatorily issued

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

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

reassessment under section 147 shall abate.Assessments under section 153A i.e, “Assessment in case of search or requisition” shall not abate by operation of section 153A itself. In the year of search, no notice has to be issued under section 153A consequent to a search. However in the 6 preceding years, notice under 153A has to be mandatorily issued

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

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

reassessment under section 147 shall abate.Assessments under section 153A i.e, “Assessment in case of search or requisition” shall not abate by operation of section 153A itself. In the year of search, no notice has to be issued under section 153A consequent to a search. However in the 6 preceding years, notice under 153A has to be mandatorily issued

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

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

reassessment under section 147 shall abate.Assessments under section 153A i.e, “Assessment in case of search or requisition” shall not abate by operation of section 153A itself. In the year of search, no notice has to be issued under section 153A consequent to a search. However in the 6 preceding years, notice under 153A has to be mandatorily issued