DY. COMMISSIONER OF INCOME TAX, HISAR vs. M/S. TAYAL SONS PVT. LTD., HISAR

The Appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalita No. 3323/Del/2025 (A.Y. 2019-20) Tayal Sons Private Vs Dcit Limited Income Tax Office, Sesctor14, 653A, Kath Mandi Road, Hisar, Hisar, Haryana Pan: Aabct6693E Appellant Respondent Ita No. 3467/Del/2025 (A.Y. 2019-20) Dcit Vs Tayal Sons Private Limited Income Tax Office, 653A, Kath Mandi Road, Hisar, Sesctor14, Hisar, Haryana. Pan: Aabct6693E Appellant Respondent Assessee By Sh. Sh. Salil Kapoor, Adv, Ms. Ananya Kapoor, Adv, Ms. Ishitafarsiya, Adv, Ms. Soumya Singh, Adv& Ms. Sakshirustagi. Revenue By Ms. Amisha S. Gupt, Cit (Dr) Date Of Hearing 27/11/2025 Date Of Pronouncement 28/11/2025 Order Per Yogesh Kumar, U.S. Jm: The Captioned Two Appeals Are Filed By The Assessee & Two

reassessment orrecomputation under Section 147 as well as for issuance of notice under Section 148 of the Act. Therefore, the Scheme framed by the CBDT, which covers both the aforesaid aspect of the provisions of Section 151A

DCIT, HISAR vs. TAYAL SONS PVT. LTD., HISAR

The Appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalita No. 3323/Del/2025 (A.Y. 2019-20) Tayal Sons Private Vs Dcit Limited Income Tax Office, Sesctor14, 653A, Kath Mandi Road, Hisar, Hisar, Haryana Pan: Aabct6693E Appellant Respondent Ita No. 3467/Del/2025 (A.Y. 2019-20) Dcit Vs Tayal Sons Private Limited Income Tax Office, 653A, Kath Mandi Road, Hisar, Sesctor14, Hisar, Haryana. Pan: Aabct6693E Appellant Respondent Assessee By Sh. Sh. Salil Kapoor, Adv, Ms. Ananya Kapoor, Adv, Ms. Ishitafarsiya, Adv, Ms. Soumya Singh, Adv& Ms. Sakshirustagi. Revenue By Ms. Amisha S. Gupt, Cit (Dr) Date Of Hearing 27/11/2025 Date Of Pronouncement 28/11/2025 Order Per Yogesh Kumar, U.S. Jm: The Captioned Two Appeals Are Filed By The Assessee & Two

reassessment orrecomputation under Section 147 as well as for issuance of notice under Section 148 of the Act. Therefore, the Scheme framed by the CBDT, which covers both the aforesaid aspect of the provisions of Section 151A

CHIRAG KIRPAL,DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, GURGAON

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh & Shri Vimal Kumarchirag Kirpal, Vs. Acit, C/O. Anuj Bhatia, C-3, Bali International Taxation, Nagar, New Raja Garden, Gurgaon New Delhi (Appellant) (Respondent) Pan: Bwxpk8788D Assessee By : Shri. S. K. Gupta, Ca Revenue By: Shri M. S. Nethrapal, Cit Dr Date Of Hearing 17/09/2025 Date Of Pronouncement 30/09/2025

reassessment or recomputation under Section 147 as well as for issuance of notice under Section 148 of the Act. Therefore, the Scheme framed by the CBDT, which covers both the aforesaid aspect of the provisions of Section 151A

SEEMA GOEL,DELHI vs. CIT A, DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

reassessment order under section 147 r.w.s. 144 of the Act, have been issued and passed by the AO without obtaining the valid statutory prior approval from the specified authority as provided under section 151 of the Act. (ii) That the purported approval is illegal, mechanical in nature and has been given without application of mind. 15. On the facts

SEEMA GOEL,DELHI vs. CIT A, DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

reassessment order under section 147 r.w.s. 144 of the Act, have been issued and passed by the AO without obtaining the valid statutory prior approval from the specified authority as provided under section 151 of the Act. (ii) That the purported approval is illegal, mechanical in nature and has been given without application of mind. 15. On the facts

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

reassessment order under section 147 r.w.s. 144 of the Act, have been issued and passed by the AO without obtaining the valid statutory prior approval from the specified authority as provided under section 151 of the Act. (ii) That the purported approval is illegal, mechanical in nature and has been given without application of mind. 15. On the facts

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

reassessment order under section 147 r.w.s. 144 of the Act, have been issued and passed by the AO without obtaining the valid statutory prior approval from the specified authority as provided under section 151 of the Act. (ii) That the purported approval is illegal, mechanical in nature and has been given without application of mind. 15. On the facts

MIDEA INDIA PRIVATE LIMITED,GURUGRAM vs. ASSESSING UNIT, INCOME TAX DEPARTMENT (JURISDICTIONAL ASSESSING OFFICER- DCIT, CIRCLE 1(1), GURGAON

In the result, the appeal of the assessee is allowed

reassessment or recomputation under Section 147 as well as for issuance of notice under Section 148 of the Act. Therefore, the Scheme framed by the CBDT, which covers both the aforesaid aspect of the provisions of Section 151A

COMPAREX INDIA P.LTD,NEW DELHI vs. ITO, CIRCLE-4(2), NEW DELHI

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

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

reassessment or recomputation under Section 147 as well as for issuance of notice under Section 148 of the Act. Therefore, the Scheme framed by the CBDT, which covers both the aforesaid aspect of the provisions of Section 151A

SUNITA BHARDWAJ,NEW DELHI vs. ACIT CIRCLE 63(1), NEW DELHI

section\n1\nITA No.1435/Del/2024\n[Assessment Year 2012-13]\nCIT(A), NFAC,\nDelhi order dated\n30.01.2024\n28.12.2019\n144 r.w.s.147 of the\nIncome Tax Act,\n1961.\n2.\nITA No.1434/Del/2024\n[Assessment Year 2013-14]\nCIT(A), NFAC,\nDelhi order dated\n30.01.2024\n30.03.2022\n147 r.w.s.144B of\nthe Income Tax Act,\n1961.\n3.\nITA No.1433/Del/2024\n[Assessment Year 2014-15]\nCIT(A), NFAC

INCOME TAX OFFICER, WARD 46(1), NEW DELHI, NEW DELHI vs. MAM RAJ CHUNNI LAL EXIM, NEW DELHI

In the result the appeal of the Revenue is dismissed and the cross objection of the assessee is partly allowed

Bench: Sh. Sudhir Kumar & Sh. Manish Agarwalassessment Year: 2016-17 Income Tax Officer, Vs Mam Raj Chunni Lal Exim Ward- 46 (1) Shop No. 5183, Ground New Delhi Floor, Lahori Gate, Naya Bazar, Delhi -110006 Pan No.Aaxfm0533B (Appellant) (Respondent)

section 151A which have been inserted by Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, w.e.f. 01.11.2020: Faceless assessment of income escaping assessment. 151A. (1) The Central Government may make a scheme, by notification in the Official Gazette, for the purposes of assessment, reassessment

SUNITA BHARDWAJ,NEW DELHI vs. ITO WARD 61(1), NEW DELHI

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2012-13] Sunita Bhardwaj, Vs Acit, 1/2, Taj Apartments, Circle-63(1), R.K.Puram, Sector-12, Delhi Delhi-110022. Pan-Ahfpb1928E Appellant Respondent

section 1 28.12.2019 CIT(A), NFAC, 144 r.w.s. 147 of the [Assessment Year 2012-13] Delhi order dated Income Tax Act, 30.01.2024 1961. 2. 30.03.2022 CIT(A), NFAC, 147 r.w.s. 144B of [Assessment Year 2013-14] Delhi order dated the Income Tax Act, 30.01.2024 1961. 3. 30.03.2022 CIT(A), NFAC, 147 r.w.s. 144B of [Assessment Year 2014-15] Delhi order

SUNITA BHARDWAJ,NEW DELHI vs. ITO WARD 61(1), NEW DELHI

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2012-13] Sunita Bhardwaj, Vs Acit, 1/2, Taj Apartments, Circle-63(1), R.K.Puram, Sector-12, Delhi Delhi-110022. Pan-Ahfpb1928E Appellant Respondent

section 1 28.12.2019 CIT(A), NFAC, 144 r.w.s. 147 of the [Assessment Year 2012-13] Delhi order dated Income Tax Act, 30.01.2024 1961. 2. 30.03.2022 CIT(A), NFAC, 147 r.w.s. 144B of [Assessment Year 2013-14] Delhi order dated the Income Tax Act, 30.01.2024 1961. 3. 30.03.2022 CIT(A), NFAC, 147 r.w.s. 144B of [Assessment Year 2014-15] Delhi order

SUMAN KISHORE,NEW DELHI vs. ITO, NEW DELHI

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2012-13] Sunita Bhardwaj, Vs Acit, 1/2, Taj Apartments, Circle-63(1), R.K.Puram, Sector-12, Delhi Delhi-110022. Pan-Ahfpb1928E Appellant Respondent

section 1 28.12.2019 CIT(A), NFAC, 144 r.w.s. 147 of the [Assessment Year 2012-13] Delhi order dated Income Tax Act, 30.01.2024 1961. 2. 30.03.2022 CIT(A), NFAC, 147 r.w.s. 144B of [Assessment Year 2013-14] Delhi order dated the Income Tax Act, 30.01.2024 1961. 3. 30.03.2022 CIT(A), NFAC, 147 r.w.s. 144B of [Assessment Year 2014-15] Delhi order

COLVIN CARE PVT LTD,GURGAON vs. DCIT, CIRCLE- 4(2), DELHI

In the result, appeal of the assessee is partly allowed

Bench: Shri Challa Nagendra Prasad & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2016-17] Colvin Care Pvt. Ltd. Dcit, Circle-4(2), C-531, 2Nd Floor, Sushant Lok-1, C.R. Building, I.P. Estate, Gurgaon, Haryana-1220002 Vs Delhi-110002 Pan-Aajcc0406C Appellant Respondent Appellant/Assessee By Shri Mukesh Jain, Ca & Shri Samyak Jain, Adv. Respondent/Revenue By Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 01.04.2026 Date Of Pronouncement 08.04.2026

151A of the Income Tax Act, 1961. Thus, the initiation of proceeding u/s 148 of the Act is void ab-initio in toto and consequential Assessment Order is liable to be quashed. 10. That having regard to the facts and circumstances of the case, the Ld. CIT(A) erred in upholding the addition made by the Ld. AO on account

HCL TECHNOLOGIES NORWAY AS ,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, similar grounds of appeal, in all the captioned

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

reassessment proceedings have been initiated and final assessment order has been passed in contravention of the procedure prescribed under section 151A

HCL SINGAPORE PTE. LTD (SUCCESSOR TO AXON SOLUTIONS SINGAPORE PTE LIMITED),DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, similar grounds of appeal, in all the captioned

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

reassessment proceedings have been initiated and final assessment order has been passed in contravention of the procedure prescribed under section 151A

HCL AUSTRALIA SERVICES PTY LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, similar grounds of appeal, in all the captioned

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

reassessment proceedings have been initiated and final assessment order has been passed in contravention of the procedure prescribed under section 151A