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

reassessment or recomputation, as the case may be, shall, after the exclusion of the period under sub-section (5) of the said section, be not less than one year; and where such period of limitation is less than one year, it shall be deemed to have been extended to one year: Provided also that for the purposes of determining

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

reassessment or recomputation, as the case may be, shall, after the exclusion of the period under sub-section (5) of the said section, be not less than one year; and where such period of limitation is less than one year, it shall be deemed to have been extended to one year: Provided also that for the purposes of determining

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

reassessment or recomputation, as the case may be, shall, after the exclusion of the period under sub-section (5) of the said section, be not less than one year; and where such period of limitation is less than one year, it shall be deemed to have been extended to one year: Provided also that for the purposes of determining

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

197 taxman 151 has held that "as a revisional authority commissioner appeal can revise not only the ultimate computation arrived at but every process which lead to the ultimate computation or assessment". Further, the Hon'ble Kerala High Court in the case of V. SubramoniaAiyr vS. CIT 1978] 113 ITR 685 held that "the power conferred on Appellate Authority

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

197 taxman 151 has held that "as a revisional authority commissioner appeal can revise not only the ultimate computation arrived at but every process which lead to the ultimate computation or assessment". Further, the Hon'ble Kerala High Court in the case of V. SubramoniaAiyr vS. CIT 1978] 113 ITR 685 held that "the power conferred on Appellate Authority

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-I, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

197 ITR 302 (Bom). Thus, the impugned satisfaction note is illegal ab initio and the consequent all assessment orders in appeal need to be quashed. No such addition u/s 69A of the Act is permissible 8. Further, no addition u/s 69A of the Act could be made as the said section is not applicable here. The AO has also incorrectly

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

197 ITR 302 (Bom). Thus, the impugned satisfaction note is illegal ab initio and the consequent all assessment orders in appeal need to be quashed. No such addition u/s 69A of the Act is permissible 8. Further, no addition u/s 69A of the Act could be made as the said section is not applicable here. The AO has also incorrectly

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

197 ITR 302 (Bom). Thus, the impugned satisfaction note is illegal ab initio and the consequent all assessment orders in appeal need to be quashed. No such addition u/s 69A of the Act is permissible 8. Further, no addition u/s 69A of the Act could be made as the said section is not applicable here. The AO has also incorrectly

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

197 ITR 302 (Bom). Thus, the impugned satisfaction note is illegal ab initio and the consequent all assessment orders in appeal need to be quashed. No such addition u/s 69A of the Act is permissible 8. Further, no addition u/s 69A of the Act could be made as the said section is not applicable here. The AO has also incorrectly

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

197 ITR 302 (Bom). Thus, the impugned satisfaction note is illegal ab initio and the consequent all assessment orders in appeal need to be quashed. No such addition u/s 69A of the Act is permissible 8. Further, no addition u/s 69A of the Act could be made as the said section is not applicable here. The AO has also incorrectly

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

197 ITR 302 (Bom). Thus, the impugned satisfaction note is illegal ab initio and the consequent all assessment orders in appeal need to be quashed. No such addition u/s 69A of the Act is permissible 8. Further, no addition u/s 69A of the Act could be made as the said section is not applicable here. The AO has also incorrectly

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

197 ITR 302 (Bom). Thus, the impugned satisfaction note is illegal ab initio and the consequent all assessment orders in appeal need to be quashed. No such addition u/s 69A of the Act is permissible 8. Further, no addition u/s 69A of the Act could be made as the said section is not applicable here. The AO has also incorrectly

MARCONI INFRATECH (P) LTD.,GURGAON vs. ACIT CENTRAL CIRCLE-11, FARIDABAD

In the result, assessee’s all appeals are allowed

Bench: Shri S. Rifaur Rahman & Ms. Madhumita Royi.T.A. Nos. 3126 To 3132/Del/2023 (Assessment Years : 2011-12 To 2017-18) M/S. Marconi Infratech Vs. Acit (P.) Ltd., F-022, Lg, Central Circle – 11 Sushant Arcade, Sushant Faridabad Lok-1, Gurgaon Haryana – 122 002 Pan : Aagcm 1219 E (Appellant) .. (Respondent)

197 of the Finance Act, 2016 has been amended so as to omit clause (c) of the said section. 80.3 Applicability: This amendment takes effect retrospectively from 1st June, 2016. 80.4 However, in order to protect the interest of the revenue in cases where tangible evidence(s) are found during a search or seizure operation (including section 132A cases

MARCONI INFRATECH (P) LTD.,GURGAON vs. ACIT CENTRAL CIRCLE-11, FARIDABAD

In the result, assessee’s all appeals are allowed

Bench: Shri S. Rifaur Rahman & Ms. Madhumita Royi.T.A. Nos. 3126 To 3132/Del/2023 (Assessment Years : 2011-12 To 2017-18) M/S. Marconi Infratech Vs. Acit (P.) Ltd., F-022, Lg, Central Circle – 11 Sushant Arcade, Sushant Faridabad Lok-1, Gurgaon Haryana – 122 002 Pan : Aagcm 1219 E (Appellant) .. (Respondent)

197 of the Finance Act, 2016 has been amended so as to omit clause (c) of the said section. 80.3 Applicability: This amendment takes effect retrospectively from 1st June, 2016. 80.4 However, in order to protect the interest of the revenue in cases where tangible evidence(s) are found during a search or seizure operation (including section 132A cases

MARCONI INFRATECH (P) LTD.,GURGAON vs. ACIT CENTRAL CIRCLE-11, FARIDABAD

In the result, assessee’s all appeals are allowed

Bench: Shri S. Rifaur Rahman & Ms. Madhumita Royi.T.A. Nos. 3126 To 3132/Del/2023 (Assessment Years : 2011-12 To 2017-18) M/S. Marconi Infratech Vs. Acit (P.) Ltd., F-022, Lg, Central Circle – 11 Sushant Arcade, Sushant Faridabad Lok-1, Gurgaon Haryana – 122 002 Pan : Aagcm 1219 E (Appellant) .. (Respondent)

197 of the Finance Act, 2016 has been amended so as to omit clause (c) of the said section. 80.3 Applicability: This amendment takes effect retrospectively from 1st June, 2016. 80.4 However, in order to protect the interest of the revenue in cases where tangible evidence(s) are found during a search or seizure operation (including section 132A cases

MARCONI INFRATECH (P) LTD.,GURGAON vs. ACIT CENTRAL CIRCLE-11, FARIDABAD

In the result, assessee’s all appeals are allowed

Bench: Shri S. Rifaur Rahman & Ms. Madhumita Royi.T.A. Nos. 3126 To 3132/Del/2023 (Assessment Years : 2011-12 To 2017-18) M/S. Marconi Infratech Vs. Acit (P.) Ltd., F-022, Lg, Central Circle – 11 Sushant Arcade, Sushant Faridabad Lok-1, Gurgaon Haryana – 122 002 Pan : Aagcm 1219 E (Appellant) .. (Respondent)

197 of the Finance Act, 2016 has been amended so as to omit clause (c) of the said section. 80.3 Applicability: This amendment takes effect retrospectively from 1st June, 2016. 80.4 However, in order to protect the interest of the revenue in cases where tangible evidence(s) are found during a search or seizure operation (including section 132A cases

MARCONI INFRATECH (P) LTD.,GURGAON vs. ACIT CENTRAL CIRCLE-11, FARIDABAD

In the result, assessee’s all appeals are allowed

Bench: Shri S. Rifaur Rahman & Ms. Madhumita Royi.T.A. Nos. 3126 To 3132/Del/2023 (Assessment Years : 2011-12 To 2017-18) M/S. Marconi Infratech Vs. Acit (P.) Ltd., F-022, Lg, Central Circle – 11 Sushant Arcade, Sushant Faridabad Lok-1, Gurgaon Haryana – 122 002 Pan : Aagcm 1219 E (Appellant) .. (Respondent)

197 of the Finance Act, 2016 has been amended so as to omit clause (c) of the said section. 80.3 Applicability: This amendment takes effect retrospectively from 1st June, 2016. 80.4 However, in order to protect the interest of the revenue in cases where tangible evidence(s) are found during a search or seizure operation (including section 132A cases

MARCONI INFRATECH (P) LTD.,GURGAON vs. ACIT CENTRAL CIRCLE-11, FARIDABAD

In the result, assessee’s all appeals are allowed

Bench: Shri S. Rifaur Rahman & Ms. Madhumita Royi.T.A. Nos. 3126 To 3132/Del/2023 (Assessment Years : 2011-12 To 2017-18) M/S. Marconi Infratech Vs. Acit (P.) Ltd., F-022, Lg, Central Circle – 11 Sushant Arcade, Sushant Faridabad Lok-1, Gurgaon Haryana – 122 002 Pan : Aagcm 1219 E (Appellant) .. (Respondent)

197 of the Finance Act, 2016 has been amended so as to omit clause (c) of the said section. 80.3 Applicability: This amendment takes effect retrospectively from 1st June, 2016. 80.4 However, in order to protect the interest of the revenue in cases where tangible evidence(s) are found during a search or seizure operation (including section 132A cases

MARCONI INFRATECH (P) LTD.,GURGAON vs. ACIT CENTRAL CIRCLE-11, FARIDABAD

In the result, assessee’s all appeals are allowed

Bench: Shri S. Rifaur Rahman & Ms. Madhumita Royi.T.A. Nos. 3126 To 3132/Del/2023 (Assessment Years : 2011-12 To 2017-18) M/S. Marconi Infratech Vs. Acit (P.) Ltd., F-022, Lg, Central Circle – 11 Sushant Arcade, Sushant Faridabad Lok-1, Gurgaon Haryana – 122 002 Pan : Aagcm 1219 E (Appellant) .. (Respondent)

197 of the Finance Act, 2016 has been amended so as to omit clause (c) of the said section. 80.3 Applicability: This amendment takes effect retrospectively from 1st June, 2016. 80.4 However, in order to protect the interest of the revenue in cases where tangible evidence(s) are found during a search or seizure operation (including section 132A cases