RAJAN GUPTA vs. COMMISSIONER OF INCOME TAX

The appeal is allowed as aforesaid

1), [(1A), (1B),] [(2), (2A) and (4)] available to the Assessing Officer for making an order of assessment, reassessment or recomputation, as the case may be, is less than sixty days, such remaining period shall be extended to sixty days and the aforesaid period of limitation shall be deemed to be extended accordingly.‖ The above provisions fall in Chapter

LENIENT CONSULTANTS PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-2, NOIDA

In the result, the appeal of the Assessee is partly allowed\nas indicated above

145 taxmann.com 288) (All.);\n4. Hon'ble Third Member in the case of Shri Dheeraj\nChoudhary vs. ACIT in ITA Nos.6158 to 6160 and 6214 to\n6216/Del/2018 dated 12.09.2025.\n5. Tish Consultants P. Ltd. vs. DCIT ITA Nos.2310 &\n2311/Del/2025 dated 16.06.2025.\nThe Hon'ble Jurisdictional High Court in the case of PCIT\nvs. Siddharth Gupta (supra) held as under

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

reassessment such provisions already exist u/s 142(1) of 148 of the Act. Thus, it is mandatory for an AO, after recording a satisfaction u/s 153C of the Act, to initiate assessment proceedings, to mandatorily issue a notice u/s 153A of the Act seeking return of income for the particular period and then to proceed to make an assessment only

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

reassessment such provisions already exist u/s 142(1) of 148 of the Act. Thus, it is mandatory for an AO, after recording a satisfaction u/s 153C of the Act, to initiate assessment proceedings, to mandatorily issue a notice u/s 153A of the Act seeking return of income for the particular period and then to proceed to make an assessment only

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

reassessment such provisions already exist u/s 142(1) of 148 of the Act. Thus, it is mandatory for an AO, after recording a satisfaction u/s 153C of the Act, to initiate assessment proceedings, to mandatorily issue a notice u/s 153A of the Act seeking return of income for the particular period and then to proceed to make an assessment only

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

reassessment such provisions already exist u/s 142(1) of 148 of the Act. Thus, it is mandatory for an AO, after recording a satisfaction u/s 153C of the Act, to initiate assessment proceedings, to mandatorily issue a notice u/s 153A of the Act seeking return of income for the particular period and then to proceed to make an assessment only

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-I, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

reassessment such provisions already exist u/s 142(1) of 148 of the Act. Thus, it is mandatory for an AO, after recording a satisfaction u/s 153C of the Act, to initiate assessment proceedings, to mandatorily issue a notice u/s 153A of the Act seeking return of income for the particular period and then to proceed to make an assessment only

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

reassessment such provisions already exist u/s 142(1) of 148 of the Act. Thus, it is mandatory for an AO, after recording a satisfaction u/s 153C of the Act, to initiate assessment proceedings, to mandatorily issue a notice u/s 153A of the Act seeking return of income for the particular period and then to proceed to make an assessment only

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

reassessment such provisions already exist u/s 142(1) of 148 of the Act. Thus, it is mandatory for an AO, after recording a satisfaction u/s 153C of the Act, to initiate assessment proceedings, to mandatorily issue a notice u/s 153A of the Act seeking return of income for the particular period and then to proceed to make an assessment only

AMAZON WEB SERVICES, INC.,USA vs. ACIT, CIRCLE-1(1)(1), NEW DELHI

Accordingly, ground No. 3 along with its sub-grounds 3.1 to 3.4, ground No. 4 and ground No. 5 along with its sub-ground 5.1 r.w ground No. 2 are allowed

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

1 along with its sub-grounds 1.1 to 1.5 and ground No. 7 challenging the initiation of reassessment proceedings under Act has not been pressed. In view of this, the only issue that needs to be adjudicated is whether the “cloud service fee” received by the assessee from customers in India is liable to tax in India being

AMAZON WEB SERVICES, INC.,USA vs. ACIT CIRCLE INTERNATIONAL TAX 1(1)(1), NEW DELHI

Accordingly, ground No. 3 along with its sub-grounds 3.1 to 3.4, ground No. 4 and ground No. 5 along with its sub-ground 5.1 r.w ground No. 2 are allowed

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

1 along with its sub-grounds 1.1 to 1.5 and ground No. 7 challenging the initiation of reassessment proceedings under Act has not been pressed. In view of this, the only issue that needs to be adjudicated is whether the “cloud service fee” received by the assessee from customers in India is liable to tax in India being

JAGPAL,GURUGRAM vs. PR. COMMISSIONER OF INCOME TAX, FARIDABAD

In the result, appeal of assessee in ITA No

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

reassessment proceedings, accepted the claim of the assessee vide his order dated 21.03.2023. 5. The PCIT, Faridabad found that the AO did not conduct proper enquiry in terms of law laid down by Supreme Court and Punjab & Haryana High Court as well law provided in the Act in terms of section 56(2)(viii) r.w. 57(iv) read with section

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

reassess the total income of such other person, (the assessee in this case)in the manner provided in section 153A of the Act. So in this case before us, since the AO of the searched person as well as that of the other/third party/assessee foundation are the same, he/AO of assessee can issue notice u/s 153C of the Act only

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

reassess the total income of such other person, (the assessee in this case)in the manner provided in section 153A of the Act. So in this case before us, since the AO of the searched person as well as that of the other/third party/assessee foundation are the same, he/AO of assessee can issue notice u/s 153C of the Act only

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

reassess the total income of such other person, (the assessee in this case)in the manner provided in section 153A of the Act. So in this case before us, since the AO of the searched person as well as that of the other/third party/assessee foundation are the same, he/AO of assessee can issue notice u/s 153C of the Act only

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

reassess the total income of such other person, (the assessee in this case)in the manner provided in section 153A of the Act. So in this case before us, since the AO of the searched person as well as that of the other/third party/assessee foundation are the same, he/AO of assessee can issue notice u/s 153C of the Act only

DCIT, NEW DELHI vs. M/S. SAHARA INDIA POWER CORPORATION LTD., PUNE

In the result, the appeal filed by the revenue for the AY 2005-06 in I

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar Us

1 SC, the Apex Court held that the completion contract method adopted by the assessee for chit discount consistently over the years, is not required to be substituted by percentage completion method. In CIT v Manish Buildwell (P) Ltd (2011) 245 CTR 397 (Del), it was enunciated that project completion method is one of the recognized methods of accounting. That

SAHARA INDIA POWER CORPORATION LTD.,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

In the result, the appeal filed by the revenue for the AY 2005-06 in I

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar Us

1 SC, the Apex Court held that the completion contract method adopted by the assessee for chit discount consistently over the years, is not required to be substituted by percentage completion method. In CIT v Manish Buildwell (P) Ltd (2011) 245 CTR 397 (Del), it was enunciated that project completion method is one of the recognized methods of accounting. That