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

245C 48.1 The provisions contained in sub-section (3) of section 234B of the Income-tax Act, before its amendment by the Act, provided that where the total income is increased on reassessment under section 147 or section 153A the assessee shall be liable for interest at the rate of 1

RAJAN GUPTA vs. COMMISSIONER OF INCOME TAX

The appeal is allowed as aforesaid

reassessment, which may be pending before an income-tax authority on the date on which an application under sub-section (1) of section 245C

BIJAY KUMAR SONI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-14, NEW DELHI

The appeal of the Revenue is dismissed as infructuous

Bench: Dr. B. R. R. Kumarsh. Sudhir Kumarita No. 1883/Del/2023 : Asstt. Year : 2017-18 Bijay Kumar Soni, Vs Dcit, C/O Anil Jain Dd & Co., Central Circle-14, 611, Surya Kiran Building, 19, New Delhi-110055 K. G. Marg, New Delhi-110001 (Appellant) (Respondent) Pan No. Aolps5917H Ita No. 2144/Del/2023 : Asstt. Year : 2017-18 Dcit, Vs Bijay Kumar Soni, Central Circle-14, 61/14, Block No. 61, Ram Jas, New Delhi-110055 Karol Bagh, New Delhi-110005 (Appellant) (Respondent) Pan No. Aolps5917H Assessee By : Sh. Anil Jain, Ca Revenue By : Ms. Monika Dhami, Cit-Dr Date Of Hearing: 01.08.2023 Date Of Pronouncement: 06.09.2023 Order Per Dr. B. R. R. Kumar:

245C and ending with the date on which the order under sub-section (1) of section 245D is received by the Principal Commissioner or Commissioner under sub-section (2) of that section; or (viii) the period commencing from the date on which an application is made before the Authority for Advance Rulings 55[or before the Board for Advance Rulings

DCIT CENTRAL CIRCLE-14, NEW DELHI vs. SH. VIJAY KUMAR SONI, NEW DELHI

The appeal of the Revenue is dismissed as infructuous

Bench: Dr. B. R. R. Kumarsh. Sudhir Kumarita No. 1883/Del/2023 : Asstt. Year : 2017-18 Bijay Kumar Soni, Vs Dcit, C/O Anil Jain Dd & Co., Central Circle-14, 611, Surya Kiran Building, 19, New Delhi-110055 K. G. Marg, New Delhi-110001 (Appellant) (Respondent) Pan No. Aolps5917H Ita No. 2144/Del/2023 : Asstt. Year : 2017-18 Dcit, Vs Bijay Kumar Soni, Central Circle-14, 61/14, Block No. 61, Ram Jas, New Delhi-110055 Karol Bagh, New Delhi-110005 (Appellant) (Respondent) Pan No. Aolps5917H Assessee By : Sh. Anil Jain, Ca Revenue By : Ms. Monika Dhami, Cit-Dr Date Of Hearing: 01.08.2023 Date Of Pronouncement: 06.09.2023 Order Per Dr. B. R. R. Kumar:

245C and ending with the date on which the order under sub-section (1) of section 245D is received by the Principal Commissioner or Commissioner under sub-section (2) of that section; or (viii) the period commencing from the date on which an application is made before the Authority for Advance Rulings 55[or before the Board for Advance Rulings

DCIT, CENTRAL CIRCLE- 18, NEW DELHI vs. NKG INFRASTRUCTURE LTD., NEW DELHI

In the result, the appeals of the Revenue are dismissed

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 7101/Del/2017 : Asstt. Year : 2011-12 Ita No. 7102/Del/2017 : Asstt. Year : 2012-13 Ita No. 7103/Del/2017 : Asstt. Year : 2013-14 Dcit, Vs Nkg Infrastructure Ltd., Central Circle-18, 6, Todermal Lane, Ground Floor, New Delhi Near Bengali Market, New Delhi (Appellant) (Respondent) Pan No. Aaccn1659D Assessee By : Sh. Akshit Jain, Ca & Sh. Rajat Jain, Ca Revenue By : Ms. Sarita Kumari, Cit Dr Date Of Hearing: 08.02.2022 Date Of Pronouncement: 11.03.2022

1) of section 153A, within a period of two years from the end of the financial year in which the last of the authorizations for search under section 132 or for requisition under section 132A was executed; xxx xxx xxx xxx xxx xxx (3) The provisions of this section, as they stood immediately before the commencement of the Finance

DCIT, CENTRAL CIRCLE- 18, NEW DELHI vs. NKG INFRASTRUCTURE LTD., NEW DELHI

In the result, the appeals of the Revenue are dismissed

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 7101/Del/2017 : Asstt. Year : 2011-12 Ita No. 7102/Del/2017 : Asstt. Year : 2012-13 Ita No. 7103/Del/2017 : Asstt. Year : 2013-14 Dcit, Vs Nkg Infrastructure Ltd., Central Circle-18, 6, Todermal Lane, Ground Floor, New Delhi Near Bengali Market, New Delhi (Appellant) (Respondent) Pan No. Aaccn1659D Assessee By : Sh. Akshit Jain, Ca & Sh. Rajat Jain, Ca Revenue By : Ms. Sarita Kumari, Cit Dr Date Of Hearing: 08.02.2022 Date Of Pronouncement: 11.03.2022

1) of section 153A, within a period of two years from the end of the financial year in which the last of the authorizations for search under section 132 or for requisition under section 132A was executed; xxx xxx xxx xxx xxx xxx (3) The provisions of this section, as they stood immediately before the commencement of the Finance

DCIT, CENTRAL CIRCLE- 18, NEW DELHI vs. NKG INFRASTRUCTURE LTD., NEW DELHI

In the result, the appeals of the Revenue are dismissed

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 7101/Del/2017 : Asstt. Year : 2011-12 Ita No. 7102/Del/2017 : Asstt. Year : 2012-13 Ita No. 7103/Del/2017 : Asstt. Year : 2013-14 Dcit, Vs Nkg Infrastructure Ltd., Central Circle-18, 6, Todermal Lane, Ground Floor, New Delhi Near Bengali Market, New Delhi (Appellant) (Respondent) Pan No. Aaccn1659D Assessee By : Sh. Akshit Jain, Ca & Sh. Rajat Jain, Ca Revenue By : Ms. Sarita Kumari, Cit Dr Date Of Hearing: 08.02.2022 Date Of Pronouncement: 11.03.2022

1) of section 153A, within a period of two years from the end of the financial year in which the last of the authorizations for search under section 132 or for requisition under section 132A was executed; xxx xxx xxx xxx xxx xxx (3) The provisions of this section, as they stood immediately before the commencement of the Finance

ACIT,, NEW DELHI vs. M/S LIPI FINSTOCK LTD.,, NEW DELHI

In the result, the Appeal filed by the Revenue is dismissed

Bench: Shri Anil Chaturvedi & Shri Yogesh Kumar U.S.

245C of the Income Tax Act, 1961. The Settlement Commission has not admitted the application of the assessee on the grounds that the assessee does not qualify as a “related” person to the “specified person”. The A.O. also made addition of Rs. 1,00,000/- on account of additional income reflected in its settlement application before the Income Tax Settlement

ASHISH KALRA,NEW DELHI vs. ACIT, CENTRAL CIRCLE-4, NEW DELHI

In the result, the appeal of the assessee for Assessment Year 2008-09 in ITA

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.4309/Del/2019 (Assessment Year 2009-10) Mr. Ashish Kalra Acit, C-3/313, Mig Flats, Janakpuri, Central Circle-4, New Delhi-110058. Vs. New Delhi. Pan-Aippk0526N (Appellant) (Respondent) Assessee By Shri Tarandeep Singh, Adv. Department By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 16/07/2025 Date Of Pronouncement 14/10/2025 O R D E R Per Manish Agarwal, Am: These Two Appeals Are Filed By The Assessee Against The Common Order Of Ld. Commissioner Of Income Tax (Appeals)-23, New Delhi [Cit(A), In Short] Dated 28.01.2019 In Appeal No. 159/2016-17 & 3/2017-18 For Asst. Years 2008-09 & 2009-10 Respectively, Both Arising Out Of Order Passed U/S 147 R.W.S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’). 2. Since, Both The Appeals Are Having Identical Issues, Therefore, They Are Adjudicated By A Common Order. First We Take Up The Appeal For Assessment Year 2008-09 In Ita No.4308/Del/2019. Ashish Kalra Vs. Acit

reassessment proceedings u/s 147 even if the proceedings u/s 153C could be initiated. Therefore, in the light of above judgment, we hereby held that the action of the AO in reopening the assessment u/s 147 on the basis of the documents found from the possession of the 3rd person cannot be held as bad in law and, accordingly, the ground

ASHISH KALRA,NEW DELHI vs. ACIT, CENTRAL CIRCLE-4, NEW DELHI

In the result, the appeal of the assessee for Assessment Year 2008-09 in ITA

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.4309/Del/2019 (Assessment Year 2009-10) Mr. Ashish Kalra Acit, C-3/313, Mig Flats, Janakpuri, Central Circle-4, New Delhi-110058. Vs. New Delhi. Pan-Aippk0526N (Appellant) (Respondent) Assessee By Shri Tarandeep Singh, Adv. Department By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 16/07/2025 Date Of Pronouncement 14/10/2025 O R D E R Per Manish Agarwal, Am: These Two Appeals Are Filed By The Assessee Against The Common Order Of Ld. Commissioner Of Income Tax (Appeals)-23, New Delhi [Cit(A), In Short] Dated 28.01.2019 In Appeal No. 159/2016-17 & 3/2017-18 For Asst. Years 2008-09 & 2009-10 Respectively, Both Arising Out Of Order Passed U/S 147 R.W.S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’). 2. Since, Both The Appeals Are Having Identical Issues, Therefore, They Are Adjudicated By A Common Order. First We Take Up The Appeal For Assessment Year 2008-09 In Ita No.4308/Del/2019. Ashish Kalra Vs. Acit

reassessment proceedings u/s 147 even if the proceedings u/s 153C could be initiated. Therefore, in the light of above judgment, we hereby held that the action of the AO in reopening the assessment u/s 147 on the basis of the documents found from the possession of the 3rd person cannot be held as bad in law and, accordingly, the ground