ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents

JCIT(OSD), JHANDEWALAN vs. NARENDRA AGGARWAL, FARIDABAD

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Sudhir Kumar & Shri Manish Agarwaljcit (Osd), Jhandewalan, Vs. Narendra Aggarwal, Delhi H.No. 467, Sector-21-A, Fardidabad, Haryana (Pan: Aagpa1441D) (Appellant) (Respondent) Assessee By : Dr.Rakesh Gupta, Adv., Sh. Somil Agarwal, Adv., Saksham Agarwal, Ca & Deepesh Garg, Adv. Revenue By : Ms. Amisha S. Gupt, Cit Dr Date Of Hearing : 04.11.2025 Date Of Order : 19.12.2025 O R D E R Per Sudhir Kumar, Jm :

5 incriminating documents of cash transactions relate to AY 2016-17 and therefore, no proceeding under section 153C of the Act could be initiated as the said material does not have a bearing in determining the total income of the assessment year 2015-16. Fourth, as in this case a consolidated satisfaction note had been recorded for all the assessment

JINDAL PHOTO LTD.,NEW DELHI vs. ACIT, CC- 30, NEW DELHI

reassessment made in pursuance to section 153A of\nthe Act, is not a denovo assessment and, therefore, it was not open to the\nassessee to claim and be allowed such deduction or allowance of\nexpenditure which it had not claimed in the original assessment\nproceedings which in the case of assessee stood completed vide order dated\n15.01.2009 passed under section

M/S. JINDAL PHOTO LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, all the appeals of the assessee in ITA No

reassessment made in pursuance to section 153A of\nthe Act, is not a denovo assessment and, therefore, it was not open to the\nassessee to claim and be allowed such deduction or allowance of\nexpenditure which it had not claimed in the original assessment\nproceedings which in the case of assessee stood completed vide order dated\n15.01.2009 passed under section

M/S. JINDAL PHOTO LTD.,NEW DELHI vs. ACIT, NEW DELHI

reassessment made in pursuance to section 153A of\nthe Act, is not a denovo assessment and, therefore, it was not open to the\nassessee to claim and be allowed such deduction or allowance of\nexpenditure which it had not claimed in the original assessment\nproceedings which in the case of assessee stood completed vide order dated\n15.01.2009 passed under section

CHANDRA VIDYA INVESTMENT & FINANCE PVT. LTD.,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -28, DELHI, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal, Accountnat Member

139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents

CHANDRA VIDYA INVESTMENT & FINANCE PVT. LTD.,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -28, DELHI, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal, Accountnat Member

139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents

CHANDRA VIDYA INVESTMENT & FINANCE PVT. LTD.,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -28, DELHI, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal, Accountnat Member

139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents

DEPUTY COMMISSIONER, DELHI vs. RAVINDRA SINGH, GREATER NOIDA

In the result, the Appeals of the Revenue in I

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 2456/Del/2023 (A.Y 2011-12) I.T.A. No. 2457/Del/2023 (A.Y 2012-13) I.T.A. No. 2458/Del/2023 (A.Y 2013-14) I.T.A. No. 2459/Del/2023 (A.Y 2014-15)

139; (b) Assess or reassess the total income of six assessment years immediately preceding the assessment year relevant to the previous year in which such search is conducted or requisition is made; Provided that the Assessing Officer shall assess or reassess the total income in respect of each assessment year falling within such six assessment years; Provided further that assessment

DEPUTY COMMISSIONER , DELHI vs. RAVINDRA SINGH, GREATER NOIDA

In the result, the Appeals of the Revenue in I

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 2456/Del/2023 (A.Y 2011-12) I.T.A. No. 2457/Del/2023 (A.Y 2012-13) I.T.A. No. 2458/Del/2023 (A.Y 2013-14) I.T.A. No. 2459/Del/2023 (A.Y 2014-15)

139; (b) Assess or reassess the total income of six assessment years immediately preceding the assessment year relevant to the previous year in which such search is conducted or requisition is made; Provided that the Assessing Officer shall assess or reassess the total income in respect of each assessment year falling within such six assessment years; Provided further that assessment

DEPUTY COMMISSIONER, DELHI vs. RAVINDRA SINGH, GREATER NOIDA

In the result, the Appeals of the Revenue in I

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 2456/Del/2023 (A.Y 2011-12) I.T.A. No. 2457/Del/2023 (A.Y 2012-13) I.T.A. No. 2458/Del/2023 (A.Y 2013-14) I.T.A. No. 2459/Del/2023 (A.Y 2014-15)

139; (b) Assess or reassess the total income of six assessment years immediately preceding the assessment year relevant to the previous year in which such search is conducted or requisition is made; Provided that the Assessing Officer shall assess or reassess the total income in respect of each assessment year falling within such six assessment years; Provided further that assessment

DCIT, CC-14, NEW DELHI vs. A.P. SECURITAS PVT. LTD, DELHI

In the result, application for condonation of delay of 52 days in filing of appeal is allowed and appeal filed by the Department of Revenue is dismissed

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumardcit, Vs. A. P. Securitas Pvt. Ltd, Central Circle-14, 10-Dda, Commercial Complex, New Delhi New Delhi (Appellant) (Respondent) Pan: Aaaca1315R

5. Legislative Intent Behind Finance Act, 2018 Amendment  Prior to Finance Act, 2018, Section 80AC applied only to a limited set of deductions. By expanding its scope to cover all deductions under Part C of Chapter VIA, the Legislature intended to strictly enforce timely compliance.  The Memorandum explaining the provisions of Finance Bill, 2018 emphasized rationalization and uniformity, ensuring that

M/S JINDAL PHOTO LTD.,,NEW DELHI vs. ACIT, NEW DELHI

In the result, all the appeals of the assessee in ITA No

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

139(5) as held by the Hon'ble Apex Court in the Wipro Ltd. (supra) judgment already discussed above. 47. With regard to the merits of the claim of sales tax subsidy being a capital receipts for the AYs 2012-13 to 2014-15, the ld DR stated that the sales tax incentive/ subsidy should be held to be Revenue

M/S. JINDAL PHOTO LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, all the appeals of the assessee in ITA No

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

139(5) as held by the Hon'ble Apex Court in the Wipro Ltd. (supra) judgment already discussed above. 47. With regard to the merits of the claim of sales tax subsidy being a capital receipts for the AYs 2012-13 to 2014-15, the ld DR stated that the sales tax incentive/ subsidy should be held to be Revenue

M/S. JINDAL PHOTO LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, all the appeals of the assessee in ITA No

reassessment made in pursuance to section 153A of\nthe Act, is not a denovo assessment and, therefore, it was not open to the\nassessee to claim and be allowed such deduction or allowance of\nexpenditure which it had not claimed in the original assessment\nproceedings which in the case of assessee stood completed vide order dated\n15.01.2009 passed under section

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:

5. In this regard, the provisions of Section 153C are as under: “Time limit for completion of assessment, reassessment and re- computation. 153. (1) No order of assessment shall be made under section 143 or section 144 at any time after the expiry of twenty-one months from the end of the assessment year in which the income was first