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

c) if as on the date the assessment under section 153A or section 153C was passed, a notice under section 148 could have been issued as per the law then in force, then fresh proceedings for reassessment of such income not arising from the incriminating material found in search can now be initiated pursuant to the findings of this

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

c) if as on the date the assessment under section 153A or section 153C was passed, a notice under section 148 could have been issued as per the law then in force, then fresh proceedings for reassessment of such income not arising from the incriminating material found in search can now be initiated pursuant to the findings of this

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, DELHI

149(1)(b) of the old regime.\n15. The Appeal of the revenue in ITA No.4153/Del/2025 for Assessment Year\n2012-13 is dismissed.\n16. Now coming to the remaining appeals of the assessee and Revenue for\n Assessment Years 2013-14 to 2022-23 in ITA Nos. 2708/Del/2025 to\n2713/Del/2025, ITA 4008/Del/2025 and ITA No.2714 to 2717/Del/2025

AMIT BANSAL,HARYANA vs. ACIT, CENTRAL CIRCLE-16, DELHI

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

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

1)(c) cannot automatically imposed. 19. The whole matter can be examined from a different perspective as well. Section 153A provides the procedure for completion of assessment where a search is initiated under Section 132 or books of account, or other documents or any assets are requisitioned under Section 132A after 31.05.2003. In such cases, the Assessing Officer shall issue

SURESH CHAND BANSAL,HARYANA vs. ACIT, CENTRAL CIRCLE-16 , DELHI

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

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

1)(c) cannot automatically imposed. 19. The whole matter can be examined from a different perspective as well. Section 153A provides the procedure for completion of assessment where a search is initiated under Section 132 or books of account, or other documents or any assets are requisitioned under Section 132A after 31.05.2003. In such cases, the Assessing Officer shall issue

AMIT BANSAL,HARYANA vs. ACIT CENTRAL CIRCLE-16, DELHI

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

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

1)(c) cannot automatically imposed. 19. The whole matter can be examined from a different perspective as well. Section 153A provides the procedure for completion of assessment where a search is initiated under Section 132 or books of account, or other documents or any assets are requisitioned under Section 132A after 31.05.2003. In such cases, the Assessing Officer shall issue

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

149\n2025-26\n1\n2024-25\n2\n2023-24\n3\n2022-23\n4\n2021-22\n5\n2020-21\n6\n2019-20\n7\n2018-19\n8\n2017-18\n9\n2016-17\n10\n2015-16\n11 (beyond terminal\npoint of 10 years)\n14. Mr. Chawla, the learned counsel appearing for the Revenue, fairly states that\nthere is no cavil with the said

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

149 of the Act\nas amended by Finance Act 2021\nRelevant Assessment year for Without prejudice\ninitiating proceedings under Section computation of 10\n148 of the Act\n14. Mr. Chawla, the learned counsel appearing for the Revenue, fairly states that\nthere is no cavil with the said tabular statement and that the issue is covered by the\ndecisions of this

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

149\n2025-26\n1\n2024-25\n2\n2023-24\n3\n2022-23\n4\n2021-22\n5\n2020-21\n6\n2019-20\n7\n2018-19\n8\n2017-18\n9\n2016-17\n10\n2015-16\n11 (beyond terminal\npoint of 10 years)\n14. Mr. Chawla, the learned counsel appearing for the Revenue, fairly states that\nthere is no cavil with the said

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

In the result, all the appeals for

Section 119 of the Act as noticed above, we find that while Section\n119(1) of the Act, restrains the Board from issuing any instructions to subordinate\nauthorities, which may lay down instructions of such a nature requiring the Income\nTax Authorities to make particular assessment in a particular manner or to\ninterfere with the discretion of the Joint Commissioner

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, DELHI

In the result, all the appeals for

Section 119 of the Act as noticed above, we find that while Section\n119(1) of the Act, restrains the Board from issuing any instructions to subordinate\nauthorities, which may lay down instructions of such a nature requiring the Income\nTax Authorities to make particular assessment in a particular manner or to\ninterfere with the discretion of the Joint Commissioner

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

In the result, all the appeals for

149\n2025-26\n1\n2024-25\n2\n2023-24\n3\n2022-23\n4\n2021-22\n5\n2020-21\n6\n2019-20\n7\n2018-19\n8\n2017-18\n9\n2016-17\n10\n2015-16\n11 (beyond terminal\npoint of 10 years)\n14. Mr. Chawla, the learned counsel appearing for the Revenue, fairly states that\nthere is no cavil with the said

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

In the result, all the appeals for

149(1), as it came to be placed and introduced in the statute\nbook by virtue of Finance Act, 2021, neither effaces nor removes from\ncontemplation the First Proviso to Section 1530(1).\nConsequently, in cases where a search is conducted after 31 March 2021, the said\nProviso would have to be construed and tested with reference to the date

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-19, DELHI, NEW DELHI vs. M/S JKM INFRA PROJECTS LTD., NOIDA, UTTAR PRADESH

In the result, the appeal of the revenue is dismissed and Cross

Bench: Shri M. Balaganesh & Shri Sudhir Kumaracit, Vs. M/S. Jkm Infra Projects Ltd, Central Circle-19, Sector-9, Noida Delhi Maharishinagar, Maharishi Nagar, So Gautam Budh Nagar, Up 201304 (Appellant) (Respondent) Pan: Aabcj3577H Co 132/Del/2025 (In Ita No. 3031/Del/2025) (Assessment Year: 2013-14) M/S. Jkm Infra Projects Ltd, Vs. Acit, Sector-9, Noida Central Circle-19, Maharishinagar, Maharishi Delhi Nagar, So Gautam Budh Nagar, Up 201304 (Appellant) (Respondent) Pan: Aabcj3577H

1) Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003 [but on or before the 31st

DCIT CENTRAL CIRCLE-14, NEW DELHI vs. SH. VIJAY KUMAR SONI, 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:

c) to whom any books of account or documents seized or requisitioned pertains or pertain to, or any information contained therein, relates to; or] 58[(xiii) the period commencing from the date on which the Assessing Officer makes a reference to the Principal Commissioner or Commissioner under the second proviso to sub- section (3) of section 143 and ending with

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:

c) to whom any books of account or documents seized or requisitioned pertains or pertain to, or any information contained therein, relates to; or] 58[(xiii) the period commencing from the date on which the Assessing Officer makes a reference to the Principal Commissioner or Commissioner under the second proviso to sub- section (3) of section 143 and ending with

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

c) of sub-section (1) of section 132 have not been satisfied vis- a-vis the petitioner so as to confer legality upon the seizure of the documents in question. In our opinion, it is not necessary for the Revenue authorities to have reasons to believe that the petitioner would not produce any books of account or document or that

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

c) of sub-section (1) of section 132 have not been satisfied vis- a-vis the petitioner so as to confer legality upon the seizure of the documents in question. In our opinion, it is not necessary for the Revenue authorities to have reasons to believe that the petitioner would not produce any books of account or document or that

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

c) of sub-section (1) of section 132 have not been satisfied vis- a-vis the petitioner so as to confer legality upon the seizure of the documents in question. In our opinion, it is not necessary for the Revenue authorities to have reasons to believe that the petitioner would not produce any books of account or document or that