PR. COMMISSIONER OF INCOME TAX -7 vs. SUMITOMO CORPORATION INDIA (P) LTD.

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE RAVINDER DUDEJA

3) and sub-section (8) 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: Provided further that where the period available

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MICROSOFT INDIA ( R & D) PVT. LTD.

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

3) and sub-section (8) 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: Provided further that where the period available

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MARUTI SUZUKI INDIA LTD.

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

3) and sub-section (8) 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: Provided further that where the period available

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 :

3) of the Acton 27.12 2022. Legal framework for initiation of proceeding under section 153C 6.5 Section 153C of the Act provides as under: (1) Notwithstanding anything contained in section 139, section 147, section 148. section 149, section 151 and section 153. where the Assessing Officer is satisfied that.— (a) any money, bullion, jewellery or other valuable article or thing

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

reassessment matters nor vests any such power in the Id. CIT(A), Even other wise the Instruction cannot substitute the independent statutory preconditions under Sections 147/148 read with Section 149, which provides the timelines for issuance of notice of Jurisdiction is assumed for reopening a particular assessment year. Even the power vested with Id. CIT(A) are reopening. Provision

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

reassessment matters nor vests any such power in the Id. CIT(A), Even other wise the Instruction cannot substitute the independent statutory preconditions under Sections 147/148 read with Section 149, which provides the timelines for issuance of notice of Jurisdiction is assumed for reopening a particular assessment year. Even the power vested with Id. CIT(A) are reopening. Provision

SEEMA GOEL,DELHI vs. CIT A, DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

3(1) of TOLA overrides Section 149 of the Income Tax Act only to the extent of relaxing the time limit for issuance of a reassessment

SEEMA GOEL,DELHI vs. CIT A, DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

3(1) of TOLA overrides Section 149 of the Income Tax Act only to the extent of relaxing the time limit for issuance of a reassessment

K K SPUN INDIA LIMITED,DELHI vs. DCIT, JHANDEWALAN DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

3(1) of TOLA overrides Section 149 of the Income Tax Act only to the extent of relaxing the time limit for issuance of a reassessment

K K SPUN INDIA LIMITED,DELHI vs. DCIT CENTRAL CIRCLE-2 NEW DELHI, JHANDEWALAN DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

3(1) of TOLA overrides Section 149 of the Income Tax Act only to the extent of relaxing the time limit for issuance of a reassessment

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

3) or a reassessment under section 147. They also contended that if the stand of the respondents were to be accepted, been gathered, the same would clearly result in manifest arbitrariness. 32. It was further argued that at the stage of Section 153A, the AO of the searched person is only liable to be satisfied that the material gathered

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

3) or a reassessment under section 147. They also contended that if the stand of the respondents were to be accepted, been gathered, the same would clearly result in manifest arbitrariness. 32. It was further argued that at the stage of Section 153A, the AO of the searched person is only liable to be satisfied that the material gathered

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

3) or a reassessment under section 147. They also contended that if the stand of the respondents were to be accepted, been gathered, the same would clearly result in manifest arbitrariness. 32. It was further argued that at the stage of Section 153A, the AO of the searched person is only liable to be satisfied that the material gathered

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:

3) and sub-section (8) 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: Provided further that where the period available

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:

3) and sub-section (8) 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: Provided further that where the period available

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

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

3) of the Act. By Finance Act 2021, section 148 has been amended and as per the new section limitation were provided in section 149 where section 149(1) (b) first proviso provided as under: “Provided that no notice under section 148 shall be issued at any time in a case for the relevant assessment year beginning on or before

INCOME TAX OFFICER WARD-2(2)(1), GHAZIABAD, GHAZIABAD vs. VIKAS SHARMA, GHAZIABAD

In the result, the appeal filed by the Revenue in AY 2013-14 is dismissed

Bench: SHRIS.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

149(1) as well as the period liable to be excluded in light of Section 3 of TOLA. The Supreme Court has ultimately held that the period between 20 March 2020 to 30 June 2021 would clearly be entitled to be excluded for the purposes of answering the question of limitation for commencement of reassessment

INCOME TAX OFFICER WARD-2(2)(1), GHAZIABAD, GHAZIABAD vs. VIKAS SHARMA, GHAZIABAD

In the result, the appeal filed by the Revenue in AY 2013-14 is dismissed

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

149(1) as well as the period liable to be excluded in light of Section 3 of TOLA. The Supreme Court has ultimately held that the period between 20 March 2020 to 30 June 2021 would clearly be entitled to be excluded for the purposes of answering the question of limitation for commencement of reassessment