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

MAGNOLIA MARTINIQUE CLOTHING PRIVATE LIMITED,DELHI vs. DCIT, CENTRAL CIRCLE 17, NEW DELHI, DELHI

In the result, all the appeals filed by the assessee are partly allowed

Bench: Shri Satbeer Singh Godara & Shri S.Rifaur Rahman

reassessment proceeding, initiated under section 148A despite the fact that the notice under section 148 issued on 30.06.2021 was beyond the permissible limitation period as per amended section 149(1)(b), and no valid "asset” representing escaped income exceeding Rs.50 lakhs was identified. 3. The CIT (A) failed to appreciate that the Assessing Officer did not possess any books

MAGNOLIA MARTINIQUE CLOTHING PRIVATE LIMITED,DELHI vs. DCIT, CENTRAL CIRCLE 17, NEW DELHI, DELHI

In the result, all the appeals filed by the assessee are partly allowed

Bench: Shri Satbeer Singh Godara & Shri S.Rifaur Rahman

reassessment proceeding, initiated under section 148A despite the fact that the notice under section 148 issued on 30.06.2021 was beyond the permissible limitation period as per amended section 149(1)(b), and no valid "asset” representing escaped income exceeding Rs.50 lakhs was identified. 3. The CIT (A) failed to appreciate that the Assessing Officer did not possess any books

MAGNOLIA MARTINIQUE CLOTHING PRIVATE LIMITED,DELHI vs. DCIT, CENTRAL CIRCLE-17, NEW DELHI, DELHI

In the result, all the appeals filed by the assessee are partly allowed

Bench: Shri Satbeer Singh Godara & Shri S.Rifaur Rahman

reassessment proceeding, initiated under section 148A despite the fact that the notice under section 148 issued on 30.06.2021 was beyond the permissible limitation period as per amended section 149(1)(b), and no valid "asset” representing escaped income exceeding Rs.50 lakhs was identified. 3. The CIT (A) failed to appreciate that the Assessing Officer did not possess any books

MAGNOLIA MARTINIQUE CLOTHING PRIVATE LIMITED,DELHI vs. DCIT, CENTRAL CIRCLE 17, NEW DELHI, DELHI

In the result, all the appeals filed by the assessee are partly allowed

Bench: Shri Satbeer Singh Godara & Shri S.Rifaur Rahman

reassessment proceeding, initiated under section 148A despite the fact that the notice under section 148 issued on 30.06.2021 was beyond the permissible limitation period as per amended section 149(1)(b), and no valid "asset” representing escaped income exceeding Rs.50 lakhs was identified. 3. The CIT (A) failed to appreciate that the Assessing Officer did not possess any books

MOTHERSON SUMI SYSTEMS LIMITED,NEW DELHI vs. DCIT, NEW DELHI

In the result, appeal of the assessee is allowed for statistical purposes

Bench: Shri Shamim Yahya & Ms. Astha Chandraasstt. Year: 2010-11

reassessment year 1998-99, where it has declined the benefit to the assessee cannot be found fault with. But there is change in the law for the assessment year 2001-02. Section 10(B)(1) and (4) reads as under- "Section 108: Special provisions in respect off newly established hundred per cent export oriented undertakings (1) Subject to the provisions

S C JHONSON PRODUCTS PVT LTD,GURGAON vs. ACIT CIRCLE-22(2), NEW DELHI

In the result, appeal of the assessee is allowed

reassessment proceedings initiated were bad in law due to a mechanical approval process and a lack of application of mind by the authorities. The issues related to the scheme of amalgamation and its accounting treatment were also considered.", "result": "Partly Allowed", "sections": [ "147", "148", "143(3)", "151(2)", "80IB", "80IC", "139(1)", "234B", "234C", "234D

SHRI CHETAN SETH,NEW DELHI vs. ITO, NEW DELHI

The appeals of the assessee are partly allowed

Bench: Shri Satbeer Singh Godara\Nand\Nshri Brajesh Kumar Singh\Nita Nos.1808/Del/2023 & 2983, 2984 & 2985/Del/2015\N[Assessment Years: 2004-05, 2005-06, 2006-07 & 2007-08]\Nshri Chetan Seth,\Nplot No.14, Lcs, Sector-B-1,\Nvasant Kunj,\Nnew Delhi-110070\Npan-Aolps2992A\Nappellant\Nincome Tax Officer,\Nward-15(3),\Nvs New Delhi\Nrespondent\Nappellant By\Nrespondent By\Nshri Arun Kishore, Ca &\Nshri Alok Suri, Ca\Nshri Rajesh Kumar Dhanesta, Sr.\N(Dr)\Ndate Of Hearing\Ndate Of Pronouncement\N28.03.2025\N25.06.2025\Norder\Nper Brajesh Kumar Singh, Am,\Nthese Four Appeals Filed By The Assessee Are Directed Against The\Norder Of Ld. Commissioner Of Income Tax (Appeals)-7, Delhi, Dated\N24.02.2015 For Ay 2004-05, 27.02.2015 For Ay 2005-06, 2006-07 And\N2007-08 Respectively Arising Out Of Assessment Orders Passed U/S 147/144\Nof The Income Tax Act, 1961 (Hereinafter Referred To ‘The Act') Dated\N31.10.2011 For All The Above Assessment Years, Respectively. Since, The\Nissues Are Common & Connected, Hence, These Appeals Were Heard\Ntogether & Are Disposed Of By This Common Order.\N2. First, We Shall Take Up The Ita No.1808/Del/2023 Pertaining To Ay\N2004-05.\N2.

234D", "244A", "143(1)", "143(3)", "153", "154", "155", "150(1)", "150(2)" ], "issues": "1. Condonation of delay in filing appeal due to alleged negligence of previous counsel. 2. Taxability of loan/advances as deemed dividend under Section 2(22)(e) in the hands of the shareholder. 3. Validity of reassessment

EBRO INDIA PVT.LTD. ,DELHI vs. ACIT CIRCLE-7(1), DELHI

In the result, the ground no 4 raised by the assessee is allowed

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

234D of the Act. Re: Ground of Appeal No.7:Penalty u/s 271AAC and 270A 88. The assessing officer grossly erred on facts and in law in initiating penalty under sections 271AAC and 270A of the Act.” 11. On the other hand, ld. DR for the Revenue argued the matter and filed the written submissions which are reproduced below :- “After

ACIT, NEW DELHI vs. M/S. BHUSHAN STEEL LTD., NEW DELHI

In the result, appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2006-07] S. C. Johnson Pvt. Ltd., Vs Dcit, 5Th Floor, Plot No.68, Circle-7(1), Sector-44, Gurugram, New Delhi Haryana-122003. Pan-Aaacl3128M Appellant Respondent [Assessment Year : 2007-08] S. C. Johnson Pvt. Ltd., Vs Acit, 5Th Floor, Plot No.68, Circle-22(2), Sector-44, Gurugram, New Delhi Haryana-122003. Pan-Aaacl3128M Appellant Respondent [Assessment Year : 2008-09] S. C. Johnson Pvt. Ltd., Vs Add.Cit, 5Th Floor, Plot No.68, Special Range-8, Sector-44, Gurugram, New Delhi Haryana-122003. Pan-Aaacl3128M Appellant Respondent Appellant By Shri K. M. Gupta, Adv. & Ms. Shruti Khimta, Ar Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 02.06.2025 Date Of Pronouncement 28.08.2025

reassessment proceedings was merely on the basis of change of opinion on the same set of facts which were existing and considered at the time of original assessment concluded under section 143(3) of the Act. 1.5 That the Ld. CIT(A) erred in law in not appreciating that the satisfaction to be recorded under section

S.C., JOHNSON PVT. LTD.,GURGAON vs. ADDI. CIT SPECIAL RANGE-8, NEW DELHI

reassessment proceedings was merely on the basis of change of\nopinion on the same set of facts which were existing and considered\nat the time of original assessment concluded under section 143(3) of\nthe Act.\n\n1.5 That the Ld. CIT(A) erred in law in not appreciating that the\nsatisfaction to be recorded under section

S.C., JOHNSON PVT. LTD.,GURGAON HARYANA vs. DCIT CIRCLE 7(1), NEW DELHI

reassessment proceedings was merely on the basis of change of\nopinion on the same set of facts which were existing and considered\nat the time of original assessment concluded under section 143(3) of\nthe Act.\n\n1.5 That the Ld. CIT(A) erred in law in not appreciating that the\nsatisfaction to be recorded under section

MODI ENTERTAINMENT LTD vs. DCIT CIRCLE 5 (1),

In the result, the appeal of the assessee on this ground is dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

reassessment being based merely on change of opinion, was bad in law and void ab- initio. 2. That the CIT(A) erred on facts and in law in confirming the action of the assessing officer in making an addition of Rs.19,40,928/ while computing 'book profit under section 115JB of the Income Tax Act, 1961('the Act'), on account

MOL CORPORATION,NEW DELHI vs. DCIT, CIRCLE- 2(2)(1), INTL. TAXATION, NEW DELHI

In the result, assessee’s appeals are allowed

reassessment under section 147 of the Act. Ld. DRP order and final assessment order dated 30.7.2019 are unjust. had in law as there are no valid 'reasons to believe' that income has escaped assessment. 3. Without prejudice to other grounds, Ld. DRP and Ld. AO failed 10 appreciate that in any case income is not chargeable in appellant's hands

MOL CORPORATION,NEW DELHI vs. DCIT, CIRCLE- 2(2)(1), INTL. TAXATION, NEW DELHI

In the result, assessee’s appeals are allowed

reassessment under section 147 of the Act. Ld. DRP order and final assessment order dated 30.7.2019 are unjust. had in law as there are no valid 'reasons to believe' that income has escaped assessment. 3. Without prejudice to other grounds, Ld. DRP and Ld. AO failed 10 appreciate that in any case income is not chargeable in appellant's hands

MICROSOFT REGIONAL SALES CORPORATION,NEW DELHI vs. DCIT (INTERNATIONAL TAXATION), CIRCLE-2(2)(1), NEW DELHI

In the result, assessee’s appeals are allowed

reassessment under section 147 of the Act. Ld. DRP order and final assessment order dated 30.7.2019 are unjust. had in law as there are no valid 'reasons to believe' that income has escaped assessment. 3. Without prejudice to other grounds, Ld. DRP and Ld. AO failed 10 appreciate that in any case income is not chargeable in appellant's hands

JINDAL POLY FILMS LTD.,NEW DELHI vs. ACIT, NEW DELHI

Bench: Shri S. Rifaur Rahman & Ms. Madhumita Royasstt. Yr: 2006-07

234D of the Act. The appellant craves leave to add, amend, alter or vary from the above grounds of appeal at or before the time of hearing.” 3. Facts of the case, in brief, are that the assessee is a company engaged in the business of manufacturing of Polyester chips, Biaxially Oriented Polyester Film, Biaxially Oriented Poly Propylene Film, Metalised