ACIT, NEW DELHI vs. SH. EMPIRE CASTING PVT. LTD., NEW DELHI

In the result, the appeal of the revenue and C

Bench: : Shri Bhavnesh Saini & Shri L.P. Sahu

reassessment for some of the years of other person, more so. when section 153C('l) has been expressly made to accord with the provisions of section 153A. We, therefore, jettison the contention urged on behalf of the Assessee as sans merit. Recently same view is also expressed by Hon'ble ITAT Banglore Bench in the case of Nandini Delux

BIHARI CHARITABLE TRUST,DELHI vs. ITO(E), WARD GHAZIABAD, GHAZIABAD

In the result the appeal of the assessee in ITA No

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

234 of the Paper Book shows the address as 65, AGCR Enclave, Delhi – 110092. The Gift Deed, which triggered the reassessment proceedings is at pages 22 to 221 of the Paper Book wherein the name of the assessee- trust has been mentioned at address 65, AGCR Enclave, Delhi – 110092, Shri Rakesh Kumar Gupta at 7/20, Raj Nagar, Ghaziabad, meaning thereby

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:

Section 147 of the Act does not postulate conferment of power upon the assessing officer to initiate reassessment proceedings upon his mere change of opinion.” The aforesaid decision of the Delhi High Court has Court has been affirmed by the Supreme Court in CIT vs. Kelvinator of India Ltd: 320 ITR 561(SC). Reliance is also placed on the decision

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:

Section 147 of the Act does not postulate conferment of power upon the assessing officer to initiate reassessment proceedings upon his mere change of opinion.” The aforesaid decision of the Delhi High Court has Court has been affirmed by the Supreme Court in CIT vs. Kelvinator of India Ltd: 320 ITR 561(SC). Reliance is also placed on the decision

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:

Section 147 of the Act does not postulate conferment of power upon the assessing officer to initiate reassessment proceedings upon his mere change of opinion.” The aforesaid decision of the Delhi High Court has Court has been affirmed by the Supreme Court in CIT vs. Kelvinator of India Ltd: 320 ITR 561(SC). Reliance is also placed on the decision

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:

Section 147 of the Act does not postulate conferment of power upon the assessing officer to initiate reassessment proceedings upon his mere change of opinion.” The aforesaid decision of the Delhi High Court has Court has been affirmed by the Supreme Court in CIT vs. Kelvinator of India Ltd: 320 ITR 561(SC). Reliance is also placed on the decision

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:

Section 147 of the Act does not postulate conferment of power upon the assessing officer to initiate reassessment proceedings upon his mere change of opinion.” The aforesaid decision of the Delhi High Court has Court has been affirmed by the Supreme Court in CIT vs. Kelvinator of India Ltd: 320 ITR 561(SC). Reliance is also placed on the decision

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:

Section 147 of the Act does not postulate conferment of power upon the assessing officer to initiate reassessment proceedings upon his mere change of opinion.” The aforesaid decision of the Delhi High Court has Court has been affirmed by the Supreme Court in CIT vs. Kelvinator of India Ltd: 320 ITR 561(SC). Reliance is also placed on the decision

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:

Section 147 of the Act does not postulate conferment of power upon the assessing officer to initiate reassessment proceedings upon his mere change of opinion.” The aforesaid decision of the Delhi High Court has Court has been affirmed by the Supreme Court in CIT vs. Kelvinator of India Ltd: 320 ITR 561(SC). Reliance is also placed on the decision

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

234(2A) of the IT Act, the interest has been bifurcated into two parts i.e. (1) upto the stage of section 245C(1) application and (2) in the event of any additional determination of income of the disclosure under section 245(1) of the IT Act As observed hereinabove, if the submission on behalf of the petitioners is accepted

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

234(2A) of the IT Act, the interest has been bifurcated into two parts i.e. (1) upto the stage of section 245C(1) application and (2) in the event of any additional determination of income of the disclosure under section 245(1) of the IT Act As observed hereinabove, if the submission on behalf of the petitioners is accepted

CAIRN UK HOLDING LTD.,AHMEDABAD vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

In the result ground No. 5 of the appeal of the assessee is allowed

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

Section 148, the reassessment had been initiated without any basis and information and as such the same is liable to be quashed. Furthermore, as noted above, no new documents were discovered by the survey proceedings in January 2014 - all of the documents in question had been in the hands of the government in 2006. The reason that

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

234 of WP 28.06.2019 Annexure P-13 on pg. 300 of WP 12 Notice u/s 263 of the Act issued by the AO 04.03.2021 Annexure P-1 on pg. 30 of WP 04.03.2021 Annexure P- 1 on pg. 31 of WP 04.03.2021 Annexure P- 1 on pg. 29 of WP 04.03.2021 Annexure

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

234 of WP 28.06.2019 Annexure P-13 on pg. 300 of WP 12 Notice u/s 263 of the Act issued by the AO 04.03.2021 Annexure P-1 on pg. 30 of WP 04.03.2021 Annexure P- 1 on pg. 31 of WP 04.03.2021 Annexure P- 1 on pg. 29 of WP 04.03.2021 Annexure

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

234 of WP 28.06.2019 Annexure P-13 on pg. 300 of WP 12 Notice u/s 263 of the Act issued by the AO 04.03.2021 Annexure P-1 on pg. 30 of WP 04.03.2021 Annexure P- 1 on pg. 31 of WP 04.03.2021 Annexure P- 1 on pg. 29 of WP 04.03.2021 Annexure

DCIT, NEW DELHI vs. M/S. DSL SOFTWARE LTD., NEW DELHI

In the result, all the three appeals of the Revenue and cross objection of the assessee are dismissed

Bench: : Shri Amit Shukla & Shri L.P. Sahu

234 ITR 170 (Del), CIT vs. Mittal Casting Ltd. : 124 Taxman 11 (Del) and Anant Raj Industries Ltd. [ITA No. 342/2009 (Del)] ITA Nos. 3722, 3723/Del/2014, 2310/Del/12 & CO. No.258/Del/2012 15 In the facts of the ease of the appellant the claim of deduction under section 80HHE and section 10A of the Act in respect of various undertakings was evident

ACIT, NEW DELHI vs. M/S. DSL SOFTWARE LTD., NEW DELHI

In the result, all the three appeals of the Revenue and cross objection of the assessee are dismissed

Bench: : Shri Amit Shukla & Shri L.P. Sahu

234 ITR 170 (Del), CIT vs. Mittal Casting Ltd. : 124 Taxman 11 (Del) and Anant Raj Industries Ltd. [ITA No. 342/2009 (Del)] ITA Nos. 3722, 3723/Del/2014, 2310/Del/12 & CO. No.258/Del/2012 15 In the facts of the ease of the appellant the claim of deduction under section 80HHE and section 10A of the Act in respect of various undertakings was evident

DCIT, NEW DELHI vs. M/S. DSL SOFTWARE LTD., NEW DELHI

In the result, all the three appeals of the Revenue and cross objection of the assessee are dismissed

Bench: : Shri Amit Shukla & Shri L.P. Sahu

234 ITR 170 (Del), CIT vs. Mittal Casting Ltd. : 124 Taxman 11 (Del) and Anant Raj Industries Ltd. [ITA No. 342/2009 (Del)] ITA Nos. 3722, 3723/Del/2014, 2310/Del/12 & CO. No.258/Del/2012 15 In the facts of the ease of the appellant the claim of deduction under section 80HHE and section 10A of the Act in respect of various undertakings was evident