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

24-51996 of the Delhi High Court has been assailed. The main question involved is on the application and interpretation of the provisions of section 150 of the Income-tax Act, 1961 ('the Act'). The relevant facts necessary for deciding the legal question raised are as under: 1. The appellant's lands were acquired under section 6 of the Land

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

24) of the IT Act, which requires payment of interest on the additional amount determined by the Settlement Commission which exceeds the disclosure under Section 245C(1) of the IT Act. 10.4 At this stage it is required to be noted that under Section 234(2A) of the IT Act, the interest has been bifurcated into two parts i.e. (1

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

24) of the IT Act, which requires payment of interest on the additional amount determined by the Settlement Commission which exceeds the disclosure under Section 245C(1) of the IT Act. 10.4 At this stage it is required to be noted that under Section 234(2A) of the IT Act, the interest has been bifurcated into two parts i.e. (1

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

In the result, all the appeals for Assessment Years 2013-14 to 2022-23 in ITA

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 4153 & 4008/Del/2025 (Assessment Year: 2012-13 & 2018-19) Dcit, Proform Interiors Pvt. Ltd., Central Circle-20, Ground Floor, Jmd Regent Room No. 269A, 2Nd Floor, Vs. Plaza, Mg Road, Gurgaon, Ara Centre, Jhandewalan Haryana-122001. Extn., Delhi-110055. Pan-Aahcs5999J

Section in which No. Order dated order is passed 1 4153/Del/2025 Revenue 2012-13 31.03.2023 147 of the Act 2. 2708/Del/2025 Assessee 2013-14 31.03.2023 -do- 3. 2709/Del/2025 -do- 2014-15 31.03.2023 -do- 4. 2710/Del/2025 -do- 2015-16 31.03.2023 -do- 5. 2711/Del/2025 -do- 2016-17 31.03.2023 -do- 6. 2712/Del/2025 -do- 2017-18 31.03.2023 -do- 7. 2713/Del/2025

COMMISSIONER OF WEALTH TAX vs. S.S. AHLUWALIA

24 of 61 or Commissioners concerned, and if they are not in agreement, by the Board or by such Director-General, Chief Commissioner or Commissioner that the Board may by an Official Gazette specify. Sub- section (3) further stipulates that the objection to the jurisdiction could be questioned by an assessee or a person within one month from the date

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

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)

section 1448 of IT Act, the case was duly transferred to the jurisdiction AO, who has no previous idea about the assessment proceedings in the case. However it is pointed out, that, even during the DRP stage and even after providing opportunity by AO, the assessee could not submit any evidence with respect to bank statement of assessee and also

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, DELHI

24,91,433/- as against the income assessed at Rs. 88,63,835/- after appeal effect\nand thus offered additional income of INR 36,27,600/ on account of service charges\nearned from various clients for facilitating, supervising and overseeing the work\nutsourced by them to outside vendors/contractors which was inadvertently missed\nwhile filing original return of income

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. CCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

DCIT CC-2 , FARIDABAD vs. A2Z MAINTENANCE AND ENGINEERING SERVICES LTD., GURGAON

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

A2Z MAINTENANCE & ENGINEERING SERVICES LTD.,GURGAON vs. DCIT, CENTRAL CIRCLE-II, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT CC-2 , FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

DCIT-CENTRAL CIRCLE-2, FARIDABAD vs. A2Z INFRA ENGINEERS LTD., GURGAON

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

INFRA ENGINEERS LTD.,GURGAON vs. DCIT, CC-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

(Now known as Sony India Limited)

24 of 142 33. The DRP upheld the suggested transfer pricing adjustment. 34. The Tribunal in the impugned order has observed that following the majority judgment in L.G. Electronics India Pvt Ltd. (supra), the legal grounds should be decided against the assessee. On the question of nature and scope of AMP expenditure, as elucidated by the majority judgment

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

reassessment proceedings.\n8. In light of the above, it is respectfully submitted that the consolidated approval\ngranted by the Additional Commissioner of Income Tax for AYs 2012-13 to 2020-\n21 and AY 2023-24 is illegal, invalid, and bad in law.\nJudicial Precedents against Consolidated/Mechanical Approval under Section\n153D of the Act.\n9\nIn this regard, reliance is placed

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

24,91,433/- as against the income assessed at Rs. 88,63,835/- after appeal effect\nand thus offered additional income of INR 36,27,600/ on account of service charges\nearned from various clients for facilitating, supervising and overseeing the work\noutsourced by them to outside vendors/contractors which was inadvertently missed\nwhile filing original return of income