TOYOTA BOSHOKU CORPORATION,JAPAN vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1) INTERNATIONAL TAXATION NEW DELHI, NEW DELHI

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vikas Awasthy & Shri M. Balaganesh

151 gets incorporated by reference, learned standing counsel relied on sub-section (2) to the preamended section 149. It should be noticed that the proviso to sub-section (1) of the amended section 149 does not even incorporate the whole of preamended section 149. It merely makes the time limit prescribed therein applicable to the issuance of notices for reassessment

TOYOTA BOSHOKU CORPORATION,JAPAN vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1) INTERNATIONAL TAXATION NEW DELHI, NEW DELHI

In the result, both the appeals of the Assessee are allowed

Bench: Shri Vikas Awasthy & Shri M. Balaganesh

151 gets incorporated by reference, learned standing counsel relied on sub-section (2) to the preamended section 149. It should be noticed that the proviso to sub-section (1) of the amended section 149 does not even incorporate the whole of preamended section 149. It merely makes the time limit prescribed therein applicable to the issuance of notices for reassessment

BHUSHAN GUPTA,DELHI vs. ITO, WARD 47(1), DELHI, NEW DELHI

In the result appeal of the assessee in ITA number 1112 for AY 2016-17 &

Bench: Madhumita Roy & Shri Amitabh Shukla

Section 151(i) &(ii) of the Act. Hon’ble Apex Court ruled that “…grant of sanction by the appropriate authority is a pre-condition for the assessing officer to assume jurisdiction u/s 148 to issue a reassessment

BHUSHAN GUPTA,DELHI vs. ITO, WARD 47(1), DELHI, NEW DELHI

In the result appeal of the assessee in ITA number 1112 for AY 2016-17 &

Bench: Madhumita Roy & Shri Amitabh Shukla

Section 151(i) &(ii) of the Act. Hon’ble Apex Court ruled that “…grant of sanction by the appropriate authority is a pre-condition for the assessing officer to assume jurisdiction u/s 148 to issue a reassessment

SAHIL GARG,DELHI vs. ITO WARD-43(6), DELHI

Appeal is allowed

Bench: Shri Satbeer Singh Godaraassessment Year: 2017-18 Sh. Sahil Garg, Income Tax Officer, G-930, Dsiidc Industrial Ward-43(3), Area, Narela, Delhi New Delhi Pan: Awxpg9338G (Appellant) (Respondent) Assessee By Sh. Sandeep Goel, Adv. Department By Sh. Manoj Kumar, Sr. Dr

151 gets incorporated by reference, learned standing counsel relied on sub-section (2) to the preamended section 149. It should be noticed that the proviso to sub-section (1) of the amended section 149 does not even incorporate the whole of preamended section 149. It merely makes the time limit prescribed therein applicable to the issuance of notices for reassessment

RAKESH ,COPERNICUS MARG vs. ITO WARD 43, DELHI , DELHI

Appeal is allowed

Bench: Shri Satbeer Singh Godaraassessment Year: 2018-19 Vs. Income Tax Officer, Sh. Rakesh, D-65, Pinces Park, Ward-43, Copernicus Marg, Delhi Delhi Pan: Bwppr4036R (Appellant) (Respondent) Assessee By Sh. Shikhar Garg, Ca Department By Sh. Manoj Kumar, Sr. Dr

151 gets incorporated by reference, learned standing counsel relied on sub-section (2) to the preamended section 149. It should be noticed that the proviso to sub- section (1) of the amended section 149 does not even incorporate the whole of preamended section 149. It merely makes the time limit prescribed therein applicable to the issuance of notices for reassessment

NEELAM JAIN,DELHI vs. INCOME TAX OFFICER WARD 36(1) CIVIC CENTRE,NEW DELHI 110002, DELHI

Appeal is allowed

Bench: Shri Satbeer Singh Godaraassessment Year: 2017-18 Vs. Income Tax Officer, Neelam Jain, 374, Veer Apartment, Ward-36(1), Sector-103, Rohini, New Delhi Delhi Pan: Ajppj0908E (Appellant) (Respondent) Assessee By Sh. Pranshu Singhal, Ca Department By Sh. Manoj Kumar, Sr. Dr

151 gets incorporated by reference, learned standing counsel relied on sub-section (2) to the preamended section 149. It should be noticed that the proviso to sub- section (1) of the amended section 149 does not even incorporate the whole of preamended section 149. It merely makes the time limit prescribed therein applicable to the issuance of notices for reassessment

NISHCHINT BAGGA,NEW DELHI vs. ITO, WARD- 23(1), NEW DELHI

Appeal is allowed

Bench: Shri Satbeer Singh Godaraassessment Year: 2017-18 Vs. Income Tax Officer, Neelam Jain, 374, Veer Apartment, Ward-36(1), Sector-103, Rohini, New Delhi Delhi Pan: Ajppj0908E (Appellant) (Respondent) Assessee By Sh. Pranshu Singhal, Ca Department By Sh. Manoj Kumar, Sr. Dr

151 gets incorporated by reference, learned standing counsel relied on sub-section (2) to the preamended section 149. It should be noticed that the proviso to sub- section (1) of the amended section 149 does not even incorporate the whole of preamended section 149. It merely makes the time limit prescribed therein applicable to the issuance of notices for reassessment

SATHI BHAI SATHYAVRITHAN,DELHI vs. INCOME TAX OFFICER WARD 68(1), CIVIC CENTRE,NEW DELHI 110002, DELHI

Appeal is allowed

Bench: Shri Satbeer Singh Godaraassessment Year: 2017-18 Vs. Income Tax Officer, Sathi Bhai Sathyavrithan, Rz 31-32, Roshan Mandi Ward-68(1), Surya Kiran Hospital, New Delhi Najafgarh, New Delhi Pan: Ayqps2816L (Appellant) (Respondent) Assessee By Sh. Pranshu Singhal, Ca Department By Sh. Manoj Kumar, Sr. Dr

151 gets incorporated by reference, learned standing counsel relied on sub-section (2) to the preamended section 149. It should be noticed that the proviso to sub- section (1) of the amended section 149 does not even incorporate the whole of preamended section 149. It merely makes the time limit prescribed therein applicable to the issuance of notices for reassessment

PUNYA STHALI TIRTH TRUST,UTTAR PRADESH vs. ITO WARD (EXEMPTION) WARD 2(4), DELHI

Appeal is allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2017-18 Punya Sthali Tirth Trust, Vs. Income Tax Officer, Gang Nahar Road, Ward (Exemption) - 2(4), Muradnagar, Delhi Uttar Pradesh Pan: Aabtp8479P (Appellant) (Respondent)

151 gets incorporated by reference, learned standing counsel relied on sub-section (2) to the preamended section 149. It should be noticed that the proviso to sub- section (1) of the amended section 149 does not even incorporate the whole of preamended section 149. It merely makes the time limit prescribed therein applicable to the issuance of notices for reassessment

SATENDRA PAL SINGH,NEW DELHI vs. ITO, WARD 36(1), DELHI, DELHI

Appeal is allowed

Bench: Shri Satbeer Singh Godaraassessment Year: 2016-17 Sh. Satendra Pal Singh, Vs. Income Tax Officer, 155, Village-Dhaka, Ward-36(1), New Delhi Delhi Pan: Autps1163K (Appellant) (Respondent) Assessee By Sh. Satyajeet Goel, Adv. Department By Sh. Manoj Kumar, Sr. Dr

151 gets incorporated by reference, learned standing counsel relied on sub-section (2) to the preamended section 149. It should be noticed that the proviso to sub- section (1) of the amended section 149 does not even incorporate the whole of preamended section 149. It merely makes the time limit prescribed therein applicable to the issuance of notices for reassessment

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3, DELHI vs. PANKAJ GOEL, DELHI

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2017-18 Dy. Commissioner Of Vs. Sh. Pankaj Goel, Income Tax, 662/3A, Ghati Road, Central Circle-3, Anand Paravt, Central Delhi, Delhi New Delhi Pan: Aswpg8949E (Appellant) (Respondent) With C.O. No.236/Del/2025 [Arising Out Of Ita No.4159/Del/2025] Assessment Year: 2017-18 Sh. Pankaj Goel, Vs. Dy. Commissioner Of Income 662/3A, Ghati Road, Tax, Anand Paravt, Central Circle-3, Central Delhi, Delhi New Delhi Pan: Aswpg8949E (Appellant) (Respondent) Assessee By Ms. Mansi Jain, Adv. Sh. Siddharth Bajaj, Adv. Department By Sh. Siddharth Bhim Singh Meena, Cit(Dr) Date Of Hearing 08.12.2025 Date Of Pronouncement 17.12.2025 Order Per Satbeer Singh Godara, Jm This Revenue’S Appeal Ita No.4159/Del/2025 Along With Assessee’S Cross Objection C.O. No. 236/Del/2025 For Assessment & C.O. No.236/Del/2025

151 gets incorporated by reference, learned standing counsel relied on sub-section (2) to the preamended section 149. It should be noticed that the proviso to sub- section (1) of the amended section 149 does not even incorporate the whole of preamended section 149. It merely makes the time limit prescribed therein applicable to the issuance of notices for reassessment

INCOME TAX OFFICER WARD 10(1) DELHI, DELHI vs. ARUNA GUPTA, DELHI

Bench: Sh. Satbeer Singh Godaraita No. 687/Del/2025 : Asstt. Year: 2017-18 Income Tax Officer, Vs Aruna Gupta, Ward-10(1), B-1/45, Safdarjung Enclave, New Delhi-110002 New Delhi-110029 (Appellant) (Respondent) Pan No. Aakpg2642L Co No. 49/Del/2025 : Asstt. Year: 2017-18 Aruna Gupta, Vs Income Tax Officer, B-1/45, Safdarjung Enclave, Ward-10(1), New Delhi-110029 New Delhi-110002 (Appellant) (Respondent) Pan No. Aakpg2642L Assessee By: Dr. Rakesh Gupta, Adv. & Sh. Deepesh Garg, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 01.07.2025 Date Of Pronouncement: 01.07.2025 Order This Revenue’S Appeal & Assessee’S Cross Objection Co No. 49/Del/2025 For Assessment Year 2017-18 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1071333531(1) Dated 18.12.2024, In Proceedings U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

151 gets incorporated by reference, learned standing counsel relied on sub-section (2) to the preamended section 149. It should be noticed that the proviso to sub-section (1) of the amended section 149 does not even incorporate the whole of preamended section 149. It merely makes the time limit prescribed therein applicable to the issuance of notices for reassessment

BASUDEO SONI,NEW DELHI vs. ITO WARD 35(1) , NEW DELHI

Appeal is allowed in above terms

Bench: Sh. Satbeer Singh Godaraita No. 4894/Del/2025 : Asstt. Year : 2016-17 Basudeo Soni, Vs Income Tax Officer, C/O B-50, Lgf, South Extension-Ii, Ward-35(1), New Delhi-110049 New Delhi (Appellant) (Respondent) Pan No. Agyps4983N Assessee By: Sh. Saantanu Jain, Adv. & Ms. Jahanvi Khanna, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 22.09.2025 Date Of Pronouncement: 22.09.2025

151 gets incorporated by reference, learned standing counsel relied on sub-section (2) to the preamended section 149. It should be noticed that the proviso to sub-section (1) of the amended section 149 does not even incorporate the whole of preamended section 149. It merely makes the time limit prescribed therein applicable to the issuance of notices for reassessment

RAJINDER PRASHAD,DELHI vs. INCOME TAX OFFICER , DELHI

Appeal is allowed in above terms

Bench: Sh. Satbeer Singh Godaraita No. 5393/Del/2025 : Asstt. Year : 2018-19 Rajinder Prashad, Vs Income Tax Officer, Bd-4, 2Nd Floor, Pitampura, Ward-47(1), New Delhi-110034 New Delhi-110001 (Appellant) (Respondent) Pan No. Aafpp2498A Assessee By: Sh. Pranshu Singhal, Ca & Sh. Rahul Bhardwaj, Adv. Revenue By : Sh. Piyush Sinha, Sr. Dr Date Of Hearing: 29.09.2025 Date Of Pronouncement: 29.09.2025

151 gets incorporated by reference, learned standing counsel relied on sub-section (2) to the preamended section 149. It should be noticed that the proviso to sub-section (1) of the amended section 149 does not even incorporate the whole of preamended section 149. It merely makes the time limit prescribed therein applicable to the issuance of notices for reassessment

SATISH CHOPRA (INDIVIDUAL),NEW DELHI vs. ITO WARD 29(1), NEW DELHI

Appeal is allowed in above terms

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

151 gets incorporated by reference, learned standing counsel relied on sub-section (2) to the preamended section 149. It should be noticed that the proviso to sub-section (1) of the amended section 149 does not even incorporate the whole of preamended section 149. It merely makes the time limit prescribed therein applicable to the issuance of notices for reassessment

AMRIT PAL SINGH CHADHA,GURGAON vs. ACIT, CENTRAL CIRCLE-19, NEW DELHI

Appeal is allowed in above terms

Bench: Sh. Satbeer Singh Godaraita No. 2794/Del/2025 : Asstt. Year: 2014-15 Amrit Pal Singh, Vs Acit, 4410, Dlf, Phase-Iv, Central Circle-19, Gurgaon, Haryana-122002 New Delhi-110055 (Appellant) (Respondent) Pan No. Aewpc3215P Assessee By: Sh. Amar Jeet Singh, Ca Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 21.07.2025 Date Of Pronouncement: 21.07.2025 Order This Assessee’S Appeal For Assessment Year 2014-15 Arises Against The Cit(A)-27, New Delhi’S Din & Order No. Itba/Apl/M/250/2024-25/1073779465(1) Dated 27.02.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

151 gets incorporated by reference, learned standing counsel relied on sub-section (2) to the preamended section 149. It should be noticed that the proviso to sub-section (1) of the amended section 149 does not even incorporate the whole of preamended section 149. It merely makes the time limit prescribed therein applicable to the issuance of notices for reassessment

S.K. BHATIA & SONS HUF,DELHI vs. ITO,WARD- 34(1), DELHI

Appeal is allowed in above terms

Bench: Sh. Satbeer Singh Godaraita No. 1800/Del/2025 : Asstt. Year: 2017-18 S. K. Bhatia & Sons Huf, Vs Income Tax Officer, A-197, Whs Timber Market, Kirti Ward-34(1), Nagar, Moti Nagar, New Delhi New Delhi-110015 (Appellant) (Respondent) Pan No. Aavhs7168G Assessee By: Sh. Ayush Garg, Ca & Sh. Aditya Garg, Ca Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 03.07.2025 Date Of Pronouncement: 03.07.2025 Order This Assessee’S Appeal For Assessment Year 2017-18 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1073655510(1) Dated 24.02.2025, In Proceedings U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short “The Act”).

151 gets incorporated by reference, learned standing counsel relied on sub-section (2) to the preamended section 149. It should be noticed that the proviso to sub-section (1) of the amended section 149 does not even incorporate the whole of preamended section 149. It merely makes the time limit prescribed therein applicable to the issuance of notices for reassessment