ITO, WARD- 2(1), NOIDA vs. LOKESH KUMAR SHARMA, G B NAGAR

In the result, all the aforesaid 03 appeals filed by the Revenue stand allowed for statistical purposes

Bench: Shri H.S. Sidhu

reassessment proceedings would have been barred by time when the assessment order, which was subject matter of appeal, was passed in the light of provisions of sub section (2) of section 150. For clarity section 150 is reproduced as hereunder: "150(1

ITO, WARD- 3(3), NOIDA vs. SATISH, GAUTAM BUDH NAGAR

In the result, all the aforesaid 03 appeals filed by the Revenue stand allowed for statistical purposes

Bench: Shri H.S. Sidhu

reassessment proceedings would have been barred by time when the assessment order, which was subject matter of appeal, was passed in the light of provisions of sub section (2) of section 150. For clarity section 150 is reproduced as hereunder: "150(1

ITO, WARD-3(3), NOIDA vs. SANJAY, G B NAGAR

In the result, all the aforesaid 03 appeals filed by the Revenue stand allowed for statistical purposes

Bench: Shri H.S. Sidhu

reassessment proceedings would have been barred by time when the assessment order, which was subject matter of appeal, was passed in the light of provisions of sub section (2) of section 150. For clarity section 150 is reproduced as hereunder: "150(1

M/S HCL TECHNOLOGIES LTD.,,NOIDA vs. ACIT (TDS), NOIDA

In the result appeal of assessee is allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishihcl Technologies Ltd, Acit(Tds), Plot No. 3A, Tower 6, 14Th Floor, Vs. Noida Sector-126, Noida Pan: Aaach1645P (Appellant) (Respondent)

Section 150, as amended with effect from 1-4-1989, does not enable the Authorities to reopen assessments, which have become final due to bar of limitation prior to 1-4-1989 and this position is applicable equally to reassessments

ITO, NEW DELHI vs. M/S NEETEE CLOTHING (P) LTD.,, NEW DELHI

In the result, the appeal of the revenue is dismissed

Bench: Shri A.T. Varkey & Shri O.P. Kant

150 enacts the situation where the provisions of sub- section (1) will not be applicable. Accordingly, we find that the provisions of sub-section (1) shall not apply where the reassessment

EBRO INDIA PVT.LTD. ,DELHI vs. ACIT CIRCLE-7(1), DELHI

In the result, the ground no 4 raised by the assessee is allowed

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

150 of paperbook];  Copy of share certificates [refer pages 151-154 of paperbook]. 51. Considering the objections and the documents/ evidences placed on record by the appellant, the DRP held as under: “3.2.3 It is submitted that the assessee has issued shares to its related party, i.e. Herba Foods SLU and had other transactions as well with the 20 said

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:

1) of section 245M, the period of limitation available under this section to the Assessing Officer for making an order of assessment, reassessment or recomputation, as the case may be, shall, after the exclusion of the period under sub-section (5) of the said section, be not less than one year; and where such period of ITA Nos. 1883 & 2144/Del/2023

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:

1) of section 245M, the period of limitation available under this section to the Assessing Officer for making an order of assessment, reassessment or recomputation, as the case may be, shall, after the exclusion of the period under sub-section (5) of the said section, be not less than one year; and where such period of ITA Nos. 1883 & 2144/Del/2023

(Now known as Sony India Limited)

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154 for any assessment year the proceedings of which have been completed before the 1st day of October, 2009. (3) Where during the course of any proceeding for the assessment of income

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

1) of section 245M, the period of limitation available under this section to the Assessing Officer for making an order of assessment, reassessment or recomputation, as the case may be, shall, after the exclusion of the period under sub-section (5) of the said section, be not less than one year; and where such period of limitation is less than

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

1) of section 245M, the period of limitation available under this section to the Assessing Officer for making an order of assessment, reassessment or recomputation, as the case may be, shall, after the exclusion of the period under sub-section (5) of the said section, be not less than one year; and where such period of limitation is less than

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

1) of section 245M, the period of limitation available under this section to the Assessing Officer for making an order of assessment, reassessment or recomputation, as the case may be, shall, after the exclusion of the period under sub-section (5) of the said section, be not less than one year; and where such period of limitation is less than

COMMISSIONER OF INCOME TAX vs. PP ENGINEERING WORK

The appeal is disposed of

150(1) and section 153(3) contemplate issuance of notice under section 148 and completion of assessment, reassessment and recomputation

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

reassess the income of the other person in accordance with the provisions of section 153A, if. that Assessing Officer is satisfied that the books of account or documents or assets seized or requisitioned have a bearing on the determination of the total income of such other person for six assessment years immediately preceding the assessment year relevant to the previous

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

reassess the income of the other person in accordance with the provisions of section 153A, if. that Assessing Officer is satisfied that the books of account or documents or assets seized or requisitioned have a bearing on the determination of the total income of such other person for six assessment years immediately preceding the assessment year relevant to the previous

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

reassess the income of the other person in accordance with the provisions of section 153A, if. that Assessing Officer is satisfied that the books of account or documents or assets seized or requisitioned have a bearing on the determination of the total income of such other person for six assessment years immediately preceding the assessment year relevant to the previous

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

reassess the income of the other person in accordance with the provisions of section 153A, if. that Assessing Officer is satisfied that the books of account or documents or assets seized or requisitioned have a bearing on the determination of the total income of such other person for six assessment years immediately preceding the assessment year relevant to the previous

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

reassess the income of the other person in accordance with the provisions of section 153A, if. that Assessing Officer is satisfied that the books of account or documents or assets seized or requisitioned have a bearing on the determination of the total income of such other person for six assessment years immediately preceding the assessment year relevant to the previous