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 taking into consideration the other material in respect of completed assessments/unabated assessments. thereby, in respect of DCIT Vs. Ravindra Singh completed/unabated assessments, no addition can be made by the AD in absence of Meaning any incriminating material found during the course of search under Section 132 or requisition under Section 132A of the Act, 1961. However, the completed/unabated assessments

SEEMA GOEL,DELHI vs. CIT A, DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

reassessment notice under Section 148 of the new regime within the time limit surviving under the Income Tax Act read with TOLA. All notices issued beyond the surviving period are time barred and liable to be set aside; 20. In the case of Communist Party of India (Marxist) vs. CIT Exmpt. reported in [2025] 174 taxmann.com 925 (Delhi

SEEMA GOEL,DELHI vs. CIT A, DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

reassessment notice under Section 148 of the new regime within the time limit surviving under the Income Tax Act read with TOLA. All notices issued beyond the surviving period are time barred and liable to be set aside; 20. In the case of Communist Party of India (Marxist) vs. CIT Exmpt. reported in [2025] 174 taxmann.com 925 (Delhi

K K SPUN INDIA LIMITED,DELHI vs. DCIT, JHANDEWALAN DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

reassessment notice under Section 148 of the new regime within the time limit surviving under the Income Tax Act read with TOLA. All notices issued beyond the surviving period are time barred and liable to be set aside; 20. In the case of Communist Party of India (Marxist) vs. CIT Exmpt. reported in [2025] 174 taxmann.com 925 (Delhi

K K SPUN INDIA LIMITED,DELHI vs. DCIT CENTRAL CIRCLE-2 NEW DELHI, JHANDEWALAN DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

reassessment notice under Section 148 of the new regime within the time limit surviving under the Income Tax Act read with TOLA. All notices issued beyond the surviving period are time barred and liable to be set aside; 20. In the case of Communist Party of India (Marxist) vs. CIT Exmpt. reported in [2025] 174 taxmann.com 925 (Delhi

RAKESH KUMAR GUPTA,DELHI vs. LD. ITO, WARD 35(1), DELHI, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2021-22] Rakesh Kumar Gupta, Income Tax Officer, Ward-35(1), B-2/38, Ground Floor, E-2, Civic Centre, Delhi-110002 Ashok Vihar, Phase-Ii, Vs Delhi-110052 Pan-Aafhr8657H Appellant Respondent

reassessment, referred to in clause (a) of subsection (1), in a case where an order under sub- section (4) has been made accepting the application." 22. As is evident from a reading of Section 270A(1), a person would be liable to be considered to have under reported its income if the contingencies spoken of in clauses

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 ultimately stood completed under section by passing a draft assessment order under section 144C(1) of the Act on 17-03-2024 determining total income of the Assessee at Rs. 65,02,482/- after making an addition of Rs. 65 lakhs by disbelieving the gift received by the Assessee from his father in the sum of Rs. 65 lakhs

BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-18, NEW DELHI

In the result, the appeals of the revenue in ITA No

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

section 150, as amended with effect from 1-41989, docs not enable the authorities to reopen assessments, which have become final due to bar of limitation prior to 1-4-1989 and this position is applicable equally to reassessments proposed on the basis of orders passed under the Act or under any other law. 21

BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE-18, DELHI

In the result, the appeals of the revenue in ITA No

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

section 150, as amended with effect from 1-41989, docs not enable the authorities to reopen assessments, which have become final due to bar of limitation prior to 1-4-1989 and this position is applicable equally to reassessments proposed on the basis of orders passed under the Act or under any other law. 21

JINDAL STEEL & POWER LTD.,DELHI vs. DCIT, GURGAON

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

Bench: Shri R. K. Panda & Smt. Beena A. Pillaiassessment Year : 2005-06 Jindal Steel & Power Ltd., Dcit, Circle- 1(1), Jindal Centre, Gurgaon. 12, Bhikaji Cama Place, Vs. Delhi.

21. In the assessment years 2003-04 and 2004-05, despite the fact that the MBF Unit was eligible for deduction under section 80IB(5)(ii) of the Act since the said unit suffered losses. no deduction was claimed in the return of income. The said losses were completely set off by appellant with the taxable income for the respective

CIT vs. ANIL KUMAR BHATIA

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

reassess the total income, taking note of the undisclosed income, if any, unearthed during the search. For this purpose, the fetters imposed upon the Assessing Officer by the strict procedure to assume jurisdiction to reopen the assessment under Sections 147 and 148, have been removed by the non obstante clause ITA Nos. 1626, 1632, 1998, 2006, 2019 & 2020/2010 Page 21

CIT vs. ANIL KUMAR BHATIA

Section 153A, by even making reassessments without any fetters, if need be. 21. Now there can be cases where at the time

ACIT, CC-30, NEW DELHI vs. AMARJYOTI VANIJYA PVT. LTD., NEW DELHI

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

section 153C of the Act. 153C [(1)] [Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned,belongs to; or (b) any books of account or documents, seized or requisitioned, pertains

ACIT, CC-30, NEW DELHI vs. AMARJYOTI VANIJYA PVT. LTD., NEW DELHI

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

section 153C of the Act. 153C [(1)] [Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned,belongs to; or (b) any books of account or documents, seized or requisitioned, pertains

ACIT. CENTRAL CIRCLE- 30, NEW DELHI vs. AMARJYOTI VANIJYA (P) LTD., NEW DELHI

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

section 153C of the Act. 153C [(1)] [Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned,belongs to; or (b) any books of account or documents, seized or requisitioned, pertains

CHANDRA VIDYA INVESTMENT & FINANCE PVT. LTD.,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -28, DELHI, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

CHANDRA VIDYA INVESTMENT & FINANCE PVT. LTD.,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -28, DELHI, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

CHANDRA VIDYA INVESTMENT & FINANCE PVT. LTD.,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -28, DELHI, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain