DEPUTY COMMISSIONER, DELHI vs. RAVINDRA SINGH, GREATER NOIDA

In the result, the Appeals of the Revenue in I

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 2456/Del/2023 (A.Y 2011-12) I.T.A. No. 2457/Del/2023 (A.Y 2012-13) I.T.A. No. 2458/Del/2023 (A.Y 2013-14) I.T.A. No. 2459/Del/2023 (A.Y 2014-15)

reassess the total income. 3. The Ld. CIT(A) has erred in reaching the conclusion that the assessment is time barred as the demand notice was served after the assessment order whereas as per section 156

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 proceedings. The provisions of section 151 A of the Act mandates that the notice under section 148 of the Act could be issued by the faceless authority only and not by the Learned JAO. The plain reading of section 151 A read with section 144B of the Act makes it very clear in this regard. Hence, the Learned

TAYAL SONS PRIVATE LIMITED,HISAR vs. DCIT, 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 proceedings. The provisions of section 151 A of the Act mandates that the notice under section 148 of the Act could be issued by the faceless authority only and not by the Learned JAO. The plain reading of section 151 A read with section 144B of the Act makes it very clear in this regard. Hence, the Learned

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 proceedings. The provisions of section 151 A of the Act mandates that the notice under section 148 of the Act could be issued by the faceless authority only and not by the Learned JAO. The plain reading of section 151 A read with section 144B of the Act makes it very clear in this regard. Hence, the Learned

TAYAL SONS PRIVATE LIMITED,HISAR vs. DCIT, 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 proceedings. The provisions of section 151 A of the Act mandates that the notice under section 148 of the Act could be issued by the faceless authority only and not by the Learned JAO. The plain reading of section 151 A read with section 144B of the Act makes it very clear in this regard. Hence, the Learned

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 proceedings. The provisions of section 151 A of the Act mandates that the notice under section 148 of the Act could be issued by the faceless authority only and not by the Learned JAO. The plain reading of section 151 A read with section 144B of the Act makes it very clear in this regard. Hence, the Learned

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

156 of WP 31.10.2018 Annexure P-10 on pg. 226 of WP 9 Final assessment order u/s 143(3) rws 254 of the Act 20.11.2018 Annexure P-11 on pg. 200 of WP November 2018 (undated) Annexure P- 28.12.2018 Annexure P - 9 on pg. 320 of WP 30.12.2018 Annexure P - 9 on pg. 224 of WP 25.12.2018 Annexure

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

156 of WP 31.10.2018 Annexure P-10 on pg. 226 of WP 9 Final assessment order u/s 143(3) rws 254 of the Act 20.11.2018 Annexure P-11 on pg. 200 of WP November 2018 (undated) Annexure P- 28.12.2018 Annexure P - 9 on pg. 320 of WP 30.12.2018 Annexure P - 9 on pg. 224 of WP 25.12.2018 Annexure

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

156 of WP 31.10.2018 Annexure P-10 on pg. 226 of WP 9 Final assessment order u/s 143(3) rws 254 of the Act 20.11.2018 Annexure P-11 on pg. 200 of WP November 2018 (undated) Annexure P- 28.12.2018 Annexure P - 9 on pg. 320 of WP 30.12.2018 Annexure P - 9 on pg. 224 of WP 25.12.2018 Annexure

MAHARASHTRA FEEDS P. LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE, FARIDABAD

In the result, the appeals of the assessee are allowed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

reassessment or re-computation exceeds the tax on the total income determined under sub-section (1) of section 143 or on the basis of the regular assessment aforesaid. (4) Where, as a result of an order under section 154 or section 155 or section 250 or section 254 or section 260 or section 262 or section 263 or section

MAHARASHTRA FEEDS P. LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE, FARIDABAD

In the result, the appeals of the assessee are allowed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

reassessment or re-computation exceeds the tax on the total income determined under sub-section (1) of section 143 or on the basis of the regular assessment aforesaid. (4) Where, as a result of an order under section 154 or section 155 or section 250 or section 254 or section 260 or section 262 or section 263 or section

PR. COMMISSIONER OF INCOME TAX CENTRAL 2 NEW DELHI vs. MEETA GUTGUTIA PROP M/S FERSN N PETALS

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE CHANDER SHEKHAR

156 vendor partners outside India as mentioned in your group profile.” That question was based on the information collected from the Assessee‟s website. On the other hand, the Assessee filed an affidavit dated 18th March, 2010 before the CIT(A) pointing out that there were different numbers of owned/controlled outlets and franchisee outlets during the various AYs. From that

PR COMMISSIONER OF INCOME TAX CENTRAL -2 vs. MEETA GUTGUTIA PROP M/S FERNS N PETALS

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE CHANDER SHEKHAR

156 vendor partners outside India as mentioned in your group profile.” That question was based on the information collected from the Assessee‟s website. On the other hand, the Assessee filed an affidavit dated 18th March, 2010 before the CIT(A) pointing out that there were different numbers of owned/controlled outlets and franchisee outlets during the various AYs. From that

PR. COMMISSIONER OF INCOME TAX CENTRAL 2 NEW DELHI vs. MEETA GUTGUTIA PROP M/S FERNS N PETALS

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE CHANDER SHEKHAR

156 vendor partners outside India as mentioned in your group profile.” That question was based on the information collected from the Assessee‟s website. On the other hand, the Assessee filed an affidavit dated 18th March, 2010 before the CIT(A) pointing out that there were different numbers of owned/controlled outlets and franchisee outlets during the various AYs. From that

M/S. LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT (INTERNATIONAL TAXATION), NOIDA

In the result all the 9 appeals filed by the assessee are allowed with above direction for statistical purposes

Bench: Smt Diva Singh & Shri Prashant Maharishi

156,97,45,016. The Appellant also requested for copy of reasons recorded for initiating the reassessment proceedings which were provided vide letter dated 21.11.2014. In the reasons recorded for initiating reassessment proceedings, it was observed that on the basis of statements of key officials recorded and materials impounded during the course of survey conducted under section

LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT, CIRCLE- 2(2)(1), INTERNATIONAL TAXATION , NEW DELHI

In the result all the 9 appeals filed by the assessee are allowed with above direction for statistical purposes

Bench: Smt Diva Singh & Shri Prashant Maharishi

156,97,45,016. The Appellant also requested for copy of reasons recorded for initiating the reassessment proceedings which were provided vide letter dated 21.11.2014. In the reasons recorded for initiating reassessment proceedings, it was observed that on the basis of statements of key officials recorded and materials impounded during the course of survey conducted under section

LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT, CIRCLE- NOIDA, INTERNATIONAL TAXATION, NOIDA

In the result all the 9 appeals filed by the assessee are allowed with above direction for statistical purposes

Bench: Smt Diva Singh & Shri Prashant Maharishi

156,97,45,016. The Appellant also requested for copy of reasons recorded for initiating the reassessment proceedings which were provided vide letter dated 21.11.2014. In the reasons recorded for initiating reassessment proceedings, it was observed that on the basis of statements of key officials recorded and materials impounded during the course of survey conducted under section

M/S. GLOBAL REALTY CREATIONS LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the 4 Appeals filed by the Assessee stand allowed

Bench: Shri H.S. Sidhu & Shri O.P. Kant

section 132 of the Act but the reassessment and change of opinion has been made as such the order passed is illegal and therefore, is liable to be quashed. 2. The Ld. CIT(A) erred in law and facts by confirmed the addition of Rs. 1,85,75,000/- as unexplained cash credit u/s.68