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 or re-computation exceeds the tax on the total income determined under sub-section (1) of section 143 or on the basis of the regular assessment aforesaid. (4) Where, as a result of an order under section 154 or section 155 or section 250 or section 254 or section 260 or section 262 or section 263

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:

reassessment, as the case may be, under the said 46[sub-sections (1), (1A), (2), (3) and (3A)], shall be extended by twelve months. (5) Where effect to an order under section 250 or section 254 or section 260 or section 262 or section 263

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:

reassessment, as the case may be, under the said 46[sub-sections (1), (1A), (2), (3) and (3A)], shall be extended by twelve months. (5) Where effect to an order under section 250 or section 254 or section 260 or section 262 or section 263

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)

263 upheld the decision of the Delhi High Court, stating that there can be no addition in the hands of a company for moneys received towards share capital. The Court held that, if necessary, the Revenue may reopen the assessment of the shareholders to bring to tax the alleged undisclosed amount.  CIT v. ARL Infratech

(Now known as Sony India Limited)

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year, proceedings for which have been completed before the 1st day of July, 2012. *Inserted by the Finance Act, 2002, w.e.f. 1-6-2002. *** Inserted by the Finance

JCIT(OSD), JHANDEWALAN vs. NARENDRA AGGARWAL, FARIDABAD

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

Bench: Shri Sudhir Kumar & Shri Manish Agarwaljcit (Osd), Jhandewalan, Vs. Narendra Aggarwal, Delhi H.No. 467, Sector-21-A, Fardidabad, Haryana (Pan: Aagpa1441D) (Appellant) (Respondent) Assessee By : Dr.Rakesh Gupta, Adv., Sh. Somil Agarwal, Adv., Saksham Agarwal, Ca & Deepesh Garg, Adv. Revenue By : Ms. Amisha S. Gupt, Cit Dr Date Of Hearing : 04.11.2025 Date Of Order : 19.12.2025 O R D E R Per Sudhir Kumar, Jm :

reassessment is required to be made. 10 6.8 Further, notice under section 153C of the Act could be issued for only such assessment years being unabated/completed years in respect of which there was incriminating material in possession of this legal position has been settled by the Apex court in PCIT Vs Abhisar Build well (P.) Ltd [2023] 149 taxmann.com

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)

1), shall stand revived with effect from the date of receipt of the order of such annulment by the Commissioner. Therefore, the intention of the legislation seems to be that in case of search only the pending assessment/ reassessment proceedings shall abate and the AD would assume the jurisdiction to assess or reassess the 'total income' for the entire

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)

1), shall stand revived with effect from the date of receipt of the order of such annulment by the Commissioner. Therefore, the intention of the legislation seems to be that in case of search only the pending assessment/ reassessment proceedings shall abate and the AD would assume the jurisdiction to assess or reassess the 'total income' for the entire

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)

1), shall stand revived with effect from the date of receipt of the order of such annulment by the Commissioner. Therefore, the intention of the legislation seems to be that in case of search only the pending assessment/ reassessment proceedings shall abate and the AD would assume the jurisdiction to assess or reassess the 'total income' for the entire

JINDAL POLYBUTTONS PVT LTD,DELHI vs. PR CIT, ROHTAK

In the result, both the assessee's appeals stand allowed

Bench: Shri Shamim Yahya & Shri Sudhir Pareek

1-2) 2. The impugned order under Section 263 passed by Ld. PCIT, Rohtak was originated from the re-assessment order passed by the AO under Section 148 of the Income Tax Act, 1961 on 30.03.2022. 3. The reassessment

JINDAL POLYBUTTONS PVT LTD,DELHI vs. PCIT, ROHTAK

In the result, both the assessee's appeals stand allowed

Bench: Shri Shamim Yahya & Shri Sudhir Pareek

1-2) 2. The impugned order under Section 263 passed by Ld. PCIT, Rohtak was originated from the re-assessment order passed by the AO under Section 148 of the Income Tax Act, 1961 on 30.03.2022. 3. The reassessment

VED PRAKASH & SONS LIUMBERS PVT LTD,KARNAL vs. PR. CIT, KARNAL

In the result, the assessee’s appeal is allowed

Bench: Shri M Balaganeh & Shri Vimal Kumarassessment Year: 2014-15

reassessment afresh by the Ld. AO. 20. Hon’ble Delhi High Court in the case of Principal Commissioner of Income Tax vs. M/s Cliks Finance Pvt. Ltd. [2012] (3) TMI 227 dated 01/03/2024 has held as under:- “19. A bare reading of sub-Section (1) of Section 263

VENETIAN LDF PROJECTS LLP,GURGAON vs. ACIT CIRCLE-4(1), GURGAON

In the result, grounds raised by the assessee are dismissed

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

section 263 of the Act. 45 173 In fact, it is pertinent to note that section 263 nowhere refers to an assessment order passed by the NaFAC under section 144B of the Faceless Assessment Scheme to be subjected to revisionary jurisdiction. It only confers revisionary jurisdiction to revise any order passed by the ‘Assessing Officer’ or the ‘Transfer Pricing Officer

AMAZON SMART COMMERCE SOLUTIONS PRIVATE LIMITED,DELHI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI-1, DELHI

In the result, grounds raised by the assessee are dismissed

section 263 of the Act is without jurisdiction and bad in law, since the pre-requisite twin conditions for invoking jurisdiction under the said section have not been fulfilled qua the order of the AO.\nRe (f): Assessment completed by NaFAC cannot be subjected to revisionary proceedings\n166 It is of utmost important to note that in the present case

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

263 CTR (Gui) 362 which according to the Revenue held to the contrary. 29. The Supreme Court noted that the appeals relating to four of the AYs i.e. 2000-01 to 2003-04 were covered by the notice under Section 153C of the Act. In dealing with the question as to whether the ITAT was right in permitting the Assessee

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

263 CTR (Gui) 362 which according to the Revenue held to the contrary. 29. The Supreme Court noted that the appeals relating to four of the AYs i.e. 2000-01 to 2003-04 were covered by the notice under Section 153C of the Act. In dealing with the question as to whether the ITAT was right in permitting the Assessee

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

263 CTR (Gui) 362 which according to the Revenue held to the contrary. 29. The Supreme Court noted that the appeals relating to four of the AYs i.e. 2000-01 to 2003-04 were covered by the notice under Section 153C of the Act. In dealing with the question as to whether the ITAT was right in permitting the Assessee

MUKUL ROHATGI,NEW DELHI vs. ACIT CIRCLE 61(1), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Mahavir Singh & Shri Manish Agarwal

263 of the Act, the assessment order is deemed erroneous insofar as it is prejudicial to the interest of the Revenue due to lack of such enquiry/verification. Learned Counsel for the assessee stated that this property is being assessed regularly and assessee is declaring the ALV of this property at ₹1.20 lakhs and even in assessment year

AMBIENCE DEVELOPERS AND INFRASTRUCTURE PRIVATE LIMITED,DELHI vs. PCIT (CENTRAL) DELHI-2, JHANDEWALAN NEW DELHI, DELHI

1. अगर जमीन बयश्चदा मिलकीयत के सवाल पर या चुक्या कानूनी प\nकब्जा खरीदार से निकल जावेगा तो वापसी कुल जर बय मय र्चा रजिस्ट्री जो खरीद\nने अलग किया है मय लागत की दोगर जायदाद हर क्सिम जिम्मेवार होगी । खरीदार\n*से वास्ता न होगा । यह बयनामा बाबत जमीन ।। बीघा १ बिस्वा पुख्ता का 1/6\nहिस्सा मय हकूक दाखिल