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

1) shall not apply in any case where any such assessment, reassessment or recomputation as is referred to in that sub-section relates to an assessment year in respect of which an assessment, reassessment or recomputation could not have been made at the lime the order which was the subject-matter of the appeal, reference or revision, as the case

ALI MOHAMMAD,GHAZIABAD vs. ACIT, CIRCLE-2(1)(1), GHAZIABAD

In the result, appeal of the assessee is allowed

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A No.5608/Del/2024 िनधा"रणवष"/Assessment Year: 2014-15 बनाम Ali Mohammad Acit, Mohalla Kot Kachchi Saray, Vs. Circle-2(1)(1), Murad Nagar, Ghaziabad, Ghaziabad. Uttar Pradesh. Pan No.Etopm2968E अपीलाथ" Appellant ""यथ"/Respondent

reassessment orders arc also without jurisdiction. Section 282A of the Act, 1961 has no relevance with respect to the recording of satisfaction or prior permission by the PCIT under Section 151 of the Act, 1961. Submissions on behalf of the respondents:- 10. Learned Additional Solicitor General of India has submitted that the unsigned satisfaction of the PCIT stands validated

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

In the result, all the appeals for Assessment Years 2013-14 to 2022-23 in ITA

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 4153 & 4008/Del/2025 (Assessment Year: 2012-13 & 2018-19) Dcit, Proform Interiors Pvt. Ltd., Central Circle-20, Ground Floor, Jmd Regent Room No. 269A, 2Nd Floor, Vs. Plaza, Mg Road, Gurgaon, Ara Centre, Jhandewalan Haryana-122001. Extn., Delhi-110055. Pan-Aahcs5999J

reassessment or recomputation under section 147, and subject to the provisions of section 148A, the Assessing Officer shall serve on the assessee a notice, along with a copy of the order passed, if required, under clause (d) of section 148A, requiring him to furnish within such period, as may be specified in such notice, a return of his income

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) 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 61[but on or before the 31st

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) 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 61[but on or before the 31st

CAIRN UK HOLDING LTD.,AHMEDABAD vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

In the result ground No. 5 of the appeal of the assessee is allowed

Bench: Shri H. S. Sidhu & Shri Prashant Maharishi

1. Approval required under Section 151(2) of the Act is not correctly provided Relevant Facts under consideration; 1.1. In the notice issued under Section 148 of the Act, there was no mention of the sanction / approval of the higher authorities as required under section 151(2) of the Act (refer page no. 7 of the Paper Book}. Further

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

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

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

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

ACIT, CC-30, NEW DELHI vs. AMARJYOTI VANIJYA PVT. LTD., NEW DELHI

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

reassessment of such other person has to be done in accordance with the provisions of section 153A, let us examine the prescription of the relevant parts of section 153A(1), which is as under :- “Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151

ACIT, CC-30, NEW DELHI vs. AMARJYOTI VANIJYA PVT. LTD., NEW DELHI

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

reassessment of such other person has to be done in accordance with the provisions of section 153A, let us examine the prescription of the relevant parts of section 153A(1), which is as under :- “Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151

ACIT. CENTRAL CIRCLE- 30, NEW DELHI vs. AMARJYOTI VANIJYA (P) LTD., NEW DELHI

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

reassessment of such other person has to be done in accordance with the provisions of section 153A, let us examine the prescription of the relevant parts of section 153A(1), which is as under :- “Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151

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

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

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