BSES YAMUNA POWER LTD.,NEW DELHI vs. DCIT, CIRCLE- 5(1), NEW DELHI

The appeal of the assessee is allowed on legal issues

Bench: Shri Anubhav Sharma & Shri Manish Agarwalbses Rajdhani Power Ltd., Dy. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd., Asst. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Yamuna Power Dy. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd. & Ors Vs. Acit Bses Yamuna Power Asst. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv., Sh. Deepesh Jain, Adv. & Sh. Shivam Gupta, Ca Department By Mr. Javed Akhtar, Cit-Dr Date Of Hearing 20/02/2025 Date Of Pronouncement 16/04/2025 O R D E R

160 (refer second last para) observing as under: The notice under section 148 of LT Act, 1961 has been issued after taking into consideration the fact of the case that the assessee has failed to disclose fully and truly material facts. In view of the above facts notice issued under section 148 of LT Act, 1961 is valid and justified

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 would be as per First Proviso to Section I53C even when this Proviso cannot override the main proviso of Section 153C(1), which clearly mentions net calculation of block period has to be done from the year of search? 3. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) was justified

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment proceedings beyond the period of four years from the end of the relevant assessment year, where the assessment has been previously undertaken under section 143(3) of the Act unless the income has escaped assessment by reason of the "failure of the assessee to disclose fully and truly all material facts necessary for assessment" In the present case, during

DCIT, CENTRAL CIRCLE-20, NEW DELHI vs. LOTUS HERBALS P.LTD, DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment proceedings beyond the period of four years from the end of the relevant assessment year, where the assessment has been previously undertaken under section 143(3) of the Act unless the income has escaped assessment by reason of the "failure of the assessee to disclose fully and truly all material facts necessary for assessment" In the present case, during

DCIT, CENTRAL CIRCLE-20, DELHI vs. LOTUS HERBALS PVT. LTD, DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment proceedings beyond the period of four years from the end of the relevant assessment year, where the assessment has been previously undertaken under section 143(3) of the Act unless the income has escaped assessment by reason of the "failure of the assessee to disclose fully and truly all material facts necessary for assessment" In the present case, during

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment proceedings beyond the period of four years from the end of the relevant assessment year, where the assessment has been previously undertaken under section 143(3) of the Act unless the income has escaped assessment by reason of the "failure of the assessee to disclose fully and truly all material facts necessary for assessment" In the present case, during

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment proceedings beyond the period of four years from the end of the relevant assessment year, where the assessment has been previously undertaken under section 143(3) of the Act unless the income has escaped assessment by reason of the "failure of the assessee to disclose fully and truly all material facts necessary for assessment" In the present case, during

COSMIC INFORMATICS PVT. LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE - 2, NEW DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment proceedings beyond the period of four years from the end of the relevant assessment year, where the assessment has been previously undertaken under section 143(3) of the Act unless the income has escaped assessment by reason of the "failure of the assessee to disclose fully and truly all material facts necessary for assessment" In the present case, during

COSMIC INFORMATICS PVT. LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE - 2, NEW DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment proceedings beyond the period of four years from the end of the relevant assessment year, where the assessment has been previously undertaken under section 143(3) of the Act unless the income has escaped assessment by reason of the "failure of the assessee to disclose fully and truly all material facts necessary for assessment" In the present case, during

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

160 (Delhi)[03-04-2024] wherein the court in the case\nconcerning section 153C (Assessment of income of any other person), has examined\nthis issue, after considering the history of amendments made under Section 153A\nand 153C by various Finance Acts, including the Finance Act, 2017. In this context,\nthe court discussed the meaning of the term "relevant assessment year

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

160 (Delhi)[03-04-2024] wherein the court in the case\nconcerning section 153C (Assessment of income of any other person), has examined\nthis issue, after considering the history of amendments made under Section 153A\nand 153C by various Finance Acts, including the Finance Act, 2017. In this context,\nthe court discussed the meaning of the term "relevant assessment year

RAJESH BATRA,NEW DELHI vs. ITO WARD 29(1), DELHI

In the result ITA No.4420/Del/2025 is allowed

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A Nos.4419, 4420 & 4421/Del/2025 िनधा"रणवष"/Assessment Years:2012-13, 2014-15 & 2015-16 बनाम Shri Rajesh Batra, Income Tax Officer, B-96, Shivalik, New Delhi. Vs. Ward 29(1), Pan No.Aahpb4919N Delhi. अपीलाथ" Appellant ""यथ"/Respondent

reassessment notice. 80. In Ashish Agarwal (supra), this Court directed that Section 148 noticeswhich were challenged before various High Courts "shall be deemed to havebeen issued under section 148-A of the Income-tax Act as substituted by theFinance Act, 2021 and construed or treated to be show-cause notices interms of Section 148-A(b)." Further, this Court dispensed

RAJESH BATRA,NEW DELHI vs. ITO WARD 29(1), DELHI

In the result ITA No.4420/Del/2025 is allowed

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A Nos.4419, 4420 & 4421/Del/2025 िनधा"रणवष"/Assessment Years:2012-13, 2014-15 & 2015-16 बनाम Shri Rajesh Batra, Income Tax Officer, B-96, Shivalik, New Delhi. Vs. Ward 29(1), Pan No.Aahpb4919N Delhi. अपीलाथ" Appellant ""यथ"/Respondent

reassessment notice. 80. In Ashish Agarwal (supra), this Court directed that Section 148 noticeswhich were challenged before various High Courts "shall be deemed to havebeen issued under section 148-A of the Income-tax Act as substituted by theFinance Act, 2021 and construed or treated to be show-cause notices interms of Section 148-A(b)." Further, this Court dispensed

RAJESH BATRA,NEW DELHI vs. ITO, WARD 29(1), DELHI

In the result ITA No.4420/Del/2025 is allowed

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A Nos.4419, 4420 & 4421/Del/2025 िनधा"रणवष"/Assessment Years:2012-13, 2014-15 & 2015-16 बनाम Shri Rajesh Batra, Income Tax Officer, B-96, Shivalik, New Delhi. Vs. Ward 29(1), Pan No.Aahpb4919N Delhi. अपीलाथ" Appellant ""यथ"/Respondent

reassessment notice. 80. In Ashish Agarwal (supra), this Court directed that Section 148 noticeswhich were challenged before various High Courts "shall be deemed to havebeen issued under section 148-A of the Income-tax Act as substituted by theFinance Act, 2021 and construed or treated to be show-cause notices interms of Section 148-A(b)." Further, this Court dispensed

DCIT CIRCLE 43(1), NEW DELHI vs. CHARU GOEL, DELHI

In the result,the appeal filed by the Revenue and the Cross

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.4863/Del/2024 िनधा"रणवष"/Assessment Year: 2014-15 Dcit, Vs. Charu Goel, Circle 43(1), 6/22, East Punjabi Bagh, 1704, 17Th Floor, E 2 Block, New Delhi. Civic Centre, New Delhi. Pan No.Aalpg3062F अपीलाथ" Appellant ""यथ"/Respondent & Co No.16/Del/2025 (Arising Out Of Ita No.4863/Del/2024) िनधा"रणवष"/Assessment Year: 2014-15 बनाम Charu Goel, Dcit, 6/22, East Punjabi Bagh, Vs. Circle 43(1), 1704, 17Th Floor, E 2 Block, New Delhi. Pan No.Aalpg3062F Civic Centre, New Delhi. अपीलाथ" Appellant ""यथ"/Respondent

reassessment notice. 80. In Ashish Agarwal (supra), this Court directed that Section 148 noticeswhich were challenged before various High Courts "shall be deemed to havebeen issued under section 148-A of the Income-tax Act as substituted by theFinance Act, 2021 and construed or treated to be show-cause notices interms of Section 148-A(b)." Further, this Court dispensed

INCOME TAX OFFICER, WARD-20(3), DELHI, NEW DELHI vs. RMP HOLDINGS PVT LTD, NEW DELHI

In the result the appeal of the Revenue is dismissed

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2017-18 Ito, Vs. Rmp Holdings Pvt. Ltd. New Delhi 138-C, Block -B Group -4 Dilshad Garden New Delhi Pan No.Aaacr5533N (Appellant) (Respondent)

reassessment notice. 80. In Ashish Agarwal (supra), this Court directed that Section 148 notices which were challenged before various High Courts "shall be deemed to have been issued under section 148-A of the Income-tax Act as substituted by the Finance Act, 2021 and construed or treated to be show-cause notices in terms of Section

INCOME TAX OFFICE WARD -1 SONEPAT, SONEPAT, HARYANA vs. OM MINIRALS, DELHI

In the result, the appeal of the Revenue is dismissed and the Cross Objection of the assessee is allowed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

160/- being 200% of tax payable on under reported income in consequences of misreporting thereof. 12. It was argued that conclusion of under-reported income in penalty order is wrong in view of the provision of section 270A(2)(a) of the Act. Calculation of under reported income was not made as per provision of section 270A(3)(ii). Calculation

RAGHAV BAHL,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1, NOIDA

In the result, the captioned appeals filed by the assessees are allowed

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2013-14 A.Y. 2014-15 A.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2019-20 A.Y. 2018-19

reassessment proceedings under Section 153A of the Act accepting the claim of interest income under Section 24B of the Act upon examination of the issue after verification of the details filed by the Assessee. The Ld. AR submitted before us that under the present facts and circumstances of the matter it cannot be said that no inquiries what-so-ever

RITU KAPUR,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1, NOIDA , NOIDA

In the result, the captioned appeals filed by the assessees are allowed

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2013-14 A.Y. 2014-15 A.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2019-20 A.Y. 2018-19

reassessment proceedings under Section 153A of the Act accepting the claim of interest income under Section 24B of the Act upon examination of the issue after verification of the details filed by the Assessee. The Ld. AR submitted before us that under the present facts and circumstances of the matter it cannot be said that no inquiries what-so-ever