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 u/s 147 r.w.s. 148 which is special mechanism for bringing to tax the income discovered in consequence of a search. Although Sec.148 (inserted w.e.f. 01.04.2021) does not begin with a non- obstante clause similar to the erstwhile section 153A, its context and Explanation- 2 makes it clear that where a search is initiated, the jurisdiction thereafter must flow through

ACE MEGA STRUCTURES PRIVATE LIMITED,UTTAR PRADESH vs. DCIT/ACIT CEN CIR, NOIDA, NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

reassessment proceedings to tax same under section 68 deserved to be quashed” On the above issue, the Hon'ble High Court of Mumbai in the case of Principal Commissioner of Income-tax vs. Bairagra Builders (P.) Ltd. reported at [2024] 164 taxmann.com 162 (Bombay) has held as under: "Where assessee had taken unsecured loan from two companies and had submitted

DY. COMMISSIONER OF INCOME TAX, NOIDA vs. M/S ACE MEGA STRUCTURE PRIVATE LIMITED, NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

reassessment proceedings to tax same under section 68 deserved to be quashed” On the above issue, the Hon'ble High Court of Mumbai in the case of Principal Commissioner of Income-tax vs. Bairagra Builders (P.) Ltd. reported at [2024] 164 taxmann.com 162 (Bombay) has held as under: "Where assessee had taken unsecured loan from two companies and had submitted

VENETIAN LDF PROJECTS LLP,GURGAON vs. ACIT CIRCLE-4(1), GURGAON

In the result, grounds raised by the assessee are dismissed

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

164 of 2019 (Guj)  Bagrrys India Ltd., v. Pr.CIT: ITA No.3785 of 3018 (Del)  M/s Arun Kumar Garg HUF vs. Pr.CIT (ITA No. 3391/Del/2018 (Del)  Pr. CIT vs. Indian Farmers & Fertilizers Co-operative Ltd.: ITA No. 597/2017 (Del)  Amira Enterprises Ltd vs PCIT in ITA No 3206/Del/2017 dated 29/11/2017 (Del)  Narayan Tatu Rane v. ITO: [2016] 70 taxmann.com

AMAZON SMART COMMERCE SOLUTIONS PRIVATE LIMITED,DELHI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI-1, DELHI

In the result, grounds raised by the assessee are dismissed

164 of 2019 (Guj)\nBagrrys India Ltd., v. Pr.CIT: ITA No.3785 of 3018 (Del)\n– M/s Arun Kumar Garg HUF vs. Pr.CIT (ITA No. 3391/Del/2018 (Del)\n– Pr. CIT vs. Indian Farmers & Fertilizers Co-operative Ltd.: ITA No. 597/2017 (Del)\n– Amira Enterprises Ltd vs PCIT in ITA No 3206/Del/2017 dated 29/11/2017 (Del)\n– Narayan Tatu Rane

(Now known as Sony India Limited)

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154 for any assessment year the proceedings of which have been completed before the 1st day of October, 2009. (3) Where during the course of any proceeding for the assessment of income

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

2) of the Act was issued on 22.02.2023\nfollowed by various notices issued u/s 142(1) seeking multiple\ninformation/documents from time to time which were duly complied with. Ld. AO\nafter considering the submissions made, passed the reassessment order u/s 147 of\nthe Act dated 31.03.2023 at a total income of Rs. 3,20,56,960/- by making addition

BIMLA,DELHI vs. ITO WARD-38(5), NEW DELHI

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

Bench: Shri S.Rifaur Rahman & Shri Sudhir Pareekbimla, Vs. Ito, Ward 38 (5), H.No.143, Village Hamidpur, New Delhi. Delhi – 110 036. (Pan : Bpdpb9344B) (Appellant) (Respondent) Assessee By : Shri Gautam Jain, Advocate Shri Ankit Kumar, Advocate Revenue By : Shri Kanv Bali, Sr. Dr Date Of Hearing : 18.09.2024 Date Of Order : 26.11.2024 Order Per S.Rifaur Rahman,Am: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax Appeals-13, New Delhi (Hereinafter Referred To ‘Ld. Cit (A)’) Dated 23.07.2019 For Assessment Year 2014-15. 2. Brief Facts Of The Case Are, Assessee Filed Return Of Income Declaring Total Income Of Rs.2,23,030/- On 14.08.2014. The Return Of Income Was Processed Under Section 143 (1) Of The Income-Tax Act, 1961 (For Short ‘The Act’). The Case Was Selected For Scrutiny Through Cass & Notices

reassess the income of the assessee for the AY 2013-14 after due application of mind independently 5. Ld. CIT (A) observed the purchase amount at Rs.1,63,50,103/- on the basis of circle rate on which stamp duty was paid in the light of section 56(2)(vii)(b)(ii) of the Act and directed the difference

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

In the result, all the appeals for

2) of the Act was issued on 22.02.2023\nfollowed by various notices issued u/s 142(1) seeking multiple\ninformation/documents from time to time which were duly complied with. Ld. AO\nafter considering the submissions made, passed the reassessment order u/s 147 of\nthe Act dated 31.03.2023 at a total income of Rs. 3,20,56,960/- by making addition

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

2) of the Act was issued on 22.02.2023\nfollowed by various notices issued u/s 142(1) seeking multiple\ninformation/documents from time to time which were duly complied with. Ld. AO\nafter considering the submissions made, passed the reassessment order u/s 147 of\nthe Act dated 31.03.2023 at a total income of Rs. 3,20,56,960/- by making addition

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

In the result, all the appeals for

2) of the Act was issued on 22.02.2023\nfollowed by various notices issued u/s 142(1) seeking multiple\ninformation/documents from time to time which were duly complied with. Ld. AO\nafter considering the submissions made, passed the reassessment order u/s 147 of\nthe Act dated 31.03.2023 at a total income of Rs. 3,20,56,960/- by making addition

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

2), applying the\nprinciple of 'taylor v. taylor' Ch.D (431), that 'where a power is given to do a certain\nthing in a certain way, the thing must be done in that way or not at all and that\nother methods of performance are necessarily forbidden, applied to Judicial\nOfficers making a record under Section 164.'. Thus, as held

LAKHMI CHAND YADAV,FARIDABAD vs. ITO, WARD-1(4), FARIDABAD

In the result, the appeal filed by the revenue is dismissed and the substantial questions of law are answered against the revenue

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganeshita No. 516/Del/2020 : Asstt. Year : 2011-12 Lakhmi Chand Yadav, Vs Income Tax Officer, Village Mirzapur Hardet Haveli Ward-1(4), Mujehri, Faridabad, Haryana-121004 Faridabad-121001 (Appellant) (Respondent) Pan No. Aaepy4744P Assessee By : Sh. M. K. Gupta, Ca Revenue By : Sh. B. S. Anand, Sr. Dr Date Of Hearing: 25.11.2024 Date Of Pronouncement: 03.12.2024 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2011-12, Arises Against The Order Of Cit(A), Faridabad Dated 28.11.2019 In Case No. 10339/2018-19 In Proceedings U/S 143(3)/147 Of The Income Tax Act, 1961 (In Short “The Act”).

164(2) of the Act. Further, the Assessing Officer pointed out that two of the trustees are also directors of the said companies with substantial interest and the companies have e-mail ID as that of the trust and they all function from the same address. In that view of the matter the total amount

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

In the result, all the appeals for

2) of the Act was issued on 22.02.2023\nfollowed by various notices issued u/s 142(1) seeking multiple\ninformation/documents from time to time which were duly complied with. Ld. AO\nafter considering the submissions made, passed the reassessment order u/s 147 of\nthe Act dated 31.03.2023 at a total income of Rs. 3,20,56,960/- by making addition

ACIT, CIRCLE-18(2), NOIDA vs. NOIDA TOLL BRIDGE CO. LTD., NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

164 (INR 2,955 crores) as at 31 March 2013. 3. The Statement is to be read in conjunction with Notes 3, 4 and 5, which form part of the Statement These notes provide the break-up of various heads comprised in the Statement and explain the management rationale for including or excluding certain items, which we have been informed

ACIT, CIRCLE-18(2), NOIDA vs. NOIDA TOLL BRIDGE CO. LTD., NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

164 (INR 2,955 crores) as at 31 March 2013. 3. The Statement is to be read in conjunction with Notes 3, 4 and 5, which form part of the Statement These notes provide the break-up of various heads comprised in the Statement and explain the management rationale for including or excluding certain items, which we have been informed

ACIT, CIRCLE-18(2), NOIDA vs. NOIDA TOLL BRIDGE CO. LTD., NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

164 (INR 2,955 crores) as at 31 March 2013. 3. The Statement is to be read in conjunction with Notes 3, 4 and 5, which form part of the Statement These notes provide the break-up of various heads comprised in the Statement and explain the management rationale for including or excluding certain items, which we have been informed

ACIT, CIRCLE-18(2), NOIDA vs. NOIDA TOLL BRIDGE CO. LTD., NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

164 (INR 2,955 crores) as at 31 March 2013. 3. The Statement is to be read in conjunction with Notes 3, 4 and 5, which form part of the Statement These notes provide the break-up of various heads comprised in the Statement and explain the management rationale for including or excluding certain items, which we have been informed

ACIT, CIRCLE-18(2), NOIDA vs. NOIDA TOLL BRIDGE CO. LTD., NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

164 (INR 2,955 crores) as at 31 March 2013. 3. The Statement is to be read in conjunction with Notes 3, 4 and 5, which form part of the Statement These notes provide the break-up of various heads comprised in the Statement and explain the management rationale for including or excluding certain items, which we have been informed