PAMELA BHARDWAJ,KARNAL vs. ITO, WARD- 3, KARNAL

Bench: Ms. Madhumita Roy & Khettra Mohan Royassessment Year: 2014-15

207, Sector-6, Ward-3, Karnal. Urban Estate, Karnal. PAN: AKZPB 3402 G APPELLANT RESPONDENT Assessee represented by Shri Somil Agarwal, Adv; & Ms. Shilpa Gupta, CA Department represented by Ms. Monika Singh, CIT(DR) Date of hearing 03.06.2025 Date of pronouncement 25.07.2025 O R D E R PER Ms. MADHUMITA ROY, JM: The instant appeal, preferred by the assessee

O.P.YADAV,NEW DELHI vs. DCIT, CENTRAL CIRC LE-15, NEW DELHI

In the result, the appeal filed by the assessee is dismissed

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

reassessment, and the special procedure for assessing the undisclosed income of the block period under Chapter XIV-B of the Act are not only separate and distinct from each other, but if an effort is made to incorporate the scheme under Chapter XIV of the Act for the purpose of assessment of the block period there is a conflict between

LASCO CHEMIE PRIVATE LIMITED,DELHI vs. INCOME TAX OFFICER, WARD-15(2), NEW DELHI, DELHI

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

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarlasco Chemie Private Vs. Income Tax Officer, Limited, Ward-15(2), Delhi 10489 Kalptaru, Sadar Thana Road Motia Khan, New Delhi 110055 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabcl 3502 E Appellant .. Respondent

section 151 of the Act and for this reason, too, the present proceedings are illegal and bad in law. Re (j): Reassessment proceedings were completed in gross violation of principles of natural justice. P a g e | 20 Lasco Chemie (P) Ltd. (AY 2012-13) 40. Without prejudice, it is respectfully submitted that the assessment order has been passed

THE KADIYAN COOP. L&C SOCIETY LTD.,PANIPAT vs. ACIT, CIRCLE PANIPAT, PANIPAT

In the result appeal of the assessee is allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishithe Kadiyan Coop L&C Society Vs. Acit, Ltd, Circle Panipat V&Po Sewah, Panipat, Haryana Pan: Aaalt0541R (Appellant) (Respondent)

reassess existed. The Supreme Court, inter alia, held as follows (page 207 and 208) : "The existence of such alternative remedy is not however always a sufficient reason for refusing a party quick relief by a writ or order prohibiting an authority acting without jurisdiction from continuing such action. In the present case, the company contends that the conditions precedent

GOLDEN JOB FINDER P.LTD,NEW DELHI vs. ITO, WARD-11(4), NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri N.K. Billaiya & Shri K.N. Chary

Section had not been discharged. 3. That the order dated 02-01-2018 passed u/s 250 of the Act by the Learned Commissioner of Income-Tax (Appeals) -35 New Delhi is against law and facts on the file in as much as he was not justified to uphold the action of the Learned Income Tax Officer, Ward

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

207 63,02,797 10.63 iii) 2016-17 6,82,10,408 6,26,08,382 72,71,655 10.55

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

207 63,02,797 10.63 iii) 2016-17 6,82,10,408 6,26,08,382 72,71,655 10.55

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

207 63,02,797 10.63 iii) 2016-17 6,82,10,408 6,26,08,382 72,71,655 10.55

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

207 63,02,797 10.63 iii) 2016-17 6,82,10,408 6,26,08,382 72,71,655 10.55

RAM KISHORE RATHORE,NEW DELHI vs. ACIT, CIRCLE- 53(1), NEW DELHI

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

Bench: Shri H. S. Sidhui.T.A. No. 308/Del/2019 Assessment Year: 2011-12 Sh. Ram Kishore Rathore, Vs. Acit, Circle-53(1), C/O M/S Rra Taxindia New Delhi D-28, South Extension, Part-I, New Delhi (Pan:Aaapr4260P) (Assessee) (Respondent)

reassess existed. The Supreme Court, inter alia, held as follows (page 207 and 208) "The existence of such alternative remedy is not however always a sufficient reason for refusing a party quick relief by a writ or order prohibiting an authority acting without jurisdiction from continuing such action. In the present case, the company contends that the conditions precedent

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, tax shall be calculated on the aggregate of the total income as assessed in the earlier proceeding for assessment under section 143 or section 144 or section 147 and the income disclosed in the application as if such aggregate were the total income. FORM NO. 34B [See rules 44C and 44CA] Form of application for settlement of case under

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, tax shall be calculated on the aggregate of the total income as assessed in the earlier proceeding for assessment under section 143 or section 144 or section 147 and the income disclosed in the application as if such aggregate were the total income. FORM NO. 34B [See rules 44C and 44CA] Form of application for settlement of case under

DEVKI NANDAN BINDAL,NEW DELHI vs. ITO, WARD- 46(3), NEW DELHI

In the result, appeal of the Assessee allowed

Bench: Shri Bhavnesh Saini & Shri B.R.R. Kumar

section 143(3) of the Income- Tax Act, 1961. The Hon’ble Bombay High Court in the case of Siemens Information System Ltd., vs. ACIT & Others (2007) 39 ITA.No.4271/Del./2019 Shri Devki Nandan Bindal, Delhi. 293 ITR 548 (Bom.) held that “when notice for reassessment basing on non-existing reasons and provisions inapplicable at relevant time – Not constituting reasons

Smt. Meera Kapoor vs. Commissioner Of Income Tax

Section 148 of the Act. The reason was that the notice was issued to the Appellant by an officer who did not have any jurisdiction, in her case. Thus, it is submitted by the appellant that the notice issued by ACIT, Circle 30(1) and the consequential assessment is illegal and bad in law. 6. The assessee relied

ACIT, CC- 15, NEW DELHI vs. SALONI NARANG, NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2012-13] Asst. Commissioner Of Income Saloni Narang, Tax, Central Circle-15, 5, Dr. G.G. Narang Marg, Room No.353, E-2, Ara Vs Cavalary Lane, Centre, Jhandewalan Ext. Delhi-110007 New Delhi-110055 Pan-Aafpn2692C Appellant Respondent Assessee By Dr. Rakesh Gupta, Adv. & Shri Somil Agarwal, Adv. Revenue By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 31.07.2025 Date Of Pronouncement 27.10.2025

207 (Delhi), had an occasion to deal with an identical situation and held that even dehors Rule 27 of the Income Tax Appellate Tribunal Rules, 1963,it is open to the respondent in an appeal before the Tribunal to raise new grounds in defense of the order appealed against ,noting that the Tribunal has inherent powers

SH. SANJAY DALMIA,NEW DELHI vs. DCIT, NEW DELHI

In the result all the appeal filed by the assessee are dismissed

Bench: Shri H.S.Sidhu & Shri Prashant Maharishi

reassessment made in respect of an assessment year under this section, the tax shall be chargeable at the rate or rates as applicable to such assessment year. ‖ 3. Thus, under the presently applicable provisions, the CBDT itself is not stating that notices u/ss 143/142 of the Act to be issued as was required under the earlier block assessment scheme

BONJOUR ESTATES (P) LIMITED,NEW DELHI vs. PR.CIT-1, NEW DELHI

In the result appeal of the assessee partly allowed

Bench: Shri Chandra Mohan Garg & Shri B.R.R. Kumarassessment Year: 2010-11 M/S. Bonjour Estates (P) Ltd., The Pcit (1), C-444, Defence Colony, New New Delhi 110002 Delhi 110024 Vs. Pan Aaecn 4851 H (Appellant) (Respondent) For Assessee : Shri Neeraj Mangla, Ca For Revenue : Shri P. Praveen Sidharth, Cit Dr

207 (Kerala) 8. L.G. Electronics India (P) Ltd. Vs. Pr. CIT [2017] 79 taxmann.com 418 (Allahabad) Page 5 of 21 9. Louis Berger Group Inc. Vs. Asst. Director of Income tax (International Taxation), Hyderabad [2014] 51 taxmann.com 121 (Hyderabad - Trib.) 6. Drawing our attention towards judgment of Hon’ble Supreme Court in the case of Commissioner of Income

FLOVEL ENERGY PVT LTD,NEW DELHI vs. ACIT CIRCLE-9(1), NEW DELHI

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

section 292BB, as notice u/s 143(2) of the Act was duly served upon it and appellant has appeared and cooperated during the assessment proceedings. 6.4 Considering the above facts, AO has correctly initiated the reassessment proceedings in the case of the appellant and objection raised by the appellant on the initiation of reassessment proceedings are not maintainable