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

reassessment made under sub-section (1) has been annulled in appeal or any other legal proceeding, then, notwithstanding anything contained in sub-section (1) or Section 153

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

reassessment made under sub-section (1) has been annulled in appeal or any other legal proceeding, then, notwithstanding anything contained in sub-section (1) or Section 153

VIVO MOBILE INDIA PRIVATE LIMITED,GURGAON vs. ACIT, CIRCLE-25(1), DELHI

In the result, appeals of the Assessee are allowed

reassessment cannot be read into Section\n144C more particularly when the provisions of Section 153 are\nexcluded by the non-obstante clause in section 144C(13) and hence\nthe proceedings are not barred by limitation. Per contra, it has been\ncontended by the learned senior counsels appearing for the\nrespondent(s)/assessees that the outer time limit under Section 153

HUAWEI TELECOMMUNICATIONS (INDIA) COMPANY PRIVATE LIMITED,GURGAON vs. ACIT, CIRCLE-1(1), GURGAON

In the result, all three appeals of the assessee are allowed, and the\nstay application is dismissed as being infructuous

reassessment cannot be\nread into Section 144C more particularly when the provisions of\nSection 153 are excluded by the non-obstante clause in section\n144C(13) and hence the proceedings are not barred by limitation.\nPer contra, it has been contended by the learned senior counsels\nappearing for the respondent(s)/assessees that the outer time\nlimit under Section 153

BAXTER INDIA PRIVATE LIMITED,GURGAON, HARYANA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, NEW DELHI

In the result, appeals of the Assessee are allowed

reassessment cannot be read into Section\n144C more particularly when the provisions of Section 153 are\nexcluded by the non-obstante clause in section 144C(13) and hence\nthe proceedings are not barred by limitation. Per contra, it has been\ncontended by the learned senior counsels appearing for the\nrespondent(s)/assessees that the outer time limit under Section 153

MSD PHARMACEUTICALS PRIVATE LIMITED,NEW DELHI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 16(1), NEW DELHI

In the result, appeals of the Assessee are allowed

reassessment cannot be read into Section\n144C more particularly when the provisions of Section 153 are\nexcluded by the non-obstante clause in section 144C(13) and hence\nthe proceedings are not barred by limitation. Per contra, it has been\ncontended by the learned senior counsels appearing for the\nrespondent(s)/assessees that the outer time limit under Section 153

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

153(6) of the Act. 3. That on the facts & circumstances of the case and in law, the CIT(A) did not appreciate that a finding/direction within the meaning of section 150 of the Act can be issued only where the income of a particular assessment year is taxable, for another assessment year and / or the income assessed

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

153(6) of the Act. 3. That on the facts & circumstances of the case and in law, the CIT(A) did not appreciate that a finding/direction within the meaning of section 150 of the Act can be issued only where the income of a particular assessment year is taxable, for another assessment year and / or the income assessed

MANLIFT INDIA PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX 16(3), NEW DELHI

In the result, appeal of the Assessee is allowed

reassessment cannot be read into Section\n144C more particularly when the provisions of Section 153 are\nexcluded by the non-obstante clause in section 144C(13) and hence\nthe proceedings are not barred by limitation. Per contra, it has been\ncontended by the learned senior counsels appearing for the\nrespondent(s)/assessees that the outer time limit under Section 153

JOHNSON MATTHEY INDIA PVT. LTD.,DELHI vs. DCIT, CIRCLE-13(1), DELHI

In the result, appeal of the Assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2021-22] Johnson Matthey India Pvt. Vs. Dcit, Ltd., 5Th Floor, C/O Regus Circle-13(1) Business Center, Gurgaon C.R. Building, Delhi Road, South West Delhi- 110037. Pan-Aaacj2919A Appellant Respondent Assessee By Shri Sumit Mangal, Adv. Ms. Radhika Sharma, Adv. Ms. Soumya Pandey, Adv. Revenue By Shri S.K. Jadhav, Cit Dr Date Of Hearing 22.01.2026 Date Of Pronouncement 27.01.2026 Order Per Manish Agarwal, Am : The Captioned Appeal Is Filed By The Assessee Challenging The Final Assessment Order Passed U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 [“The Act”] Dated 23.10.2024 Pertaining To The Assessment Year 2021-22. 2. During The Course Of Hearing The Bench Has Asked The Assessee To File Specific Ground Of Appeal No.2 As Against General Ground Of Appeal No. 2 Taken. In Compliance, Assessee Vide Application Dt. 12.03.2025 Filed Under Rule 11 Of The Income Tax Appellate Tribunal Rules, 1963 Raised Additional Ground Of Appeal Under. The Additional Ground Of Appeal Taken Reads As Under: Johnson Matthey India Pvt. Ltd. Vs. Dcit

reassessment cannot be read into Section Johnson Matthey India Pvt. Ltd. Vs. DCIT 144C more particularly when the provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the proceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels appearing for the respondent(s)/assessees that

WIN MEDICARE PRIVATE LIMITED,DELHI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT (DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 25(1), DELHI), DELHI

In the result, appeal of the Assessee is allowed

reassessment cannot be read into Section 144C more\nparticularly when the provisions of Section 153 are excluded by the\nnon-obstante clause in section 144C(13) and hence the proceedings\nare not barred by limitation. Per contra, it has been contended by the\nlearned senior counsels appearing for the respondent(s)/assessees\nthat the outer time limit under Section 153

MSD PHARMACEUTICALS PRIVATE LIMITED,NEW DELHI vs. DCIT, CIRCLE-16(1), DELHI

In the result, appeals of the Assessee are allowed

reassessment cannot be read into Section\n144C more particularly when the provisions of Section 153 are\nexcluded by the non-obstante clause in section 144C(13) and hence\nthe proceedings are not barred by limitation. Per contra, it has been\ncontended by the learned senior counsels appearing for the\nrespondent(s)/assessees that the outer time limit under Section 153

ALANKIT FINSEC LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassessment made under sub-section (1) has been annulled in appeal or any other legal proceeding, then, notwithstanding anything contained in sub-section (1) or Section 153

SAKSHI AGARWAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE- 28, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassessment made under sub-section (1) has been annulled in appeal or any other legal proceeding, then, notwithstanding anything contained in sub-section (1) or Section 153

PRATISHTHA IMAGES PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassessment made under sub-section (1) has been annulled in appeal or any other legal proceeding, then, notwithstanding anything contained in sub-section (1) or Section 153

ALKA AGARWAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassessment made under sub-section (1) has been annulled in appeal or any other legal proceeding, then, notwithstanding anything contained in sub-section (1) or Section 153

PRATISHTHA IMAGES PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassessment made under sub-section (1) has been annulled in appeal or any other legal proceeding, then, notwithstanding anything contained in sub-section (1) or Section 153

PRATISHTHA IMAGES PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassessment made under sub-section (1) has been annulled in appeal or any other legal proceeding, then, notwithstanding anything contained in sub-section (1) or Section 153