TAYAL SONS PRIVATE LIMITED,HISAR vs. DCIT, HISAR

The Appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalita No. 3323/Del/2025 (A.Y. 2019-20) Tayal Sons Private Vs Dcit Limited Income Tax Office, Sesctor14, 653A, Kath Mandi Road, Hisar, Hisar, Haryana Pan: Aabct6693E Appellant Respondent Ita No. 3467/Del/2025 (A.Y. 2019-20) Dcit Vs Tayal Sons Private Limited Income Tax Office, 653A, Kath Mandi Road, Hisar, Sesctor14, Hisar, Haryana. Pan: Aabct6693E Appellant Respondent Assessee By Sh. Sh. Salil Kapoor, Adv, Ms. Ananya Kapoor, Adv, Ms. Ishitafarsiya, Adv, Ms. Soumya Singh, Adv& Ms. Sakshirustagi. Revenue By Ms. Amisha S. Gupt, Cit (Dr) Date Of Hearing 27/11/2025 Date Of Pronouncement 28/11/2025 Order Per Yogesh Kumar, U.S. Jm: The Captioned Two Appeals Are Filed By The Assessee & Two

276' has held that notice under Section 148 of 1961 Act cannot be issued by Jurisdictional Assessing Officer(for short 'JAO') after introduction of concept of faceless assessment under Section 151A read with Section 144B of 1961 Act. 6. Per contra, Mr.Amanpreet Singh, and Mr.Vaibhav Gupta, Standing Counsels for the respondents submit that Gauhati High Court and Telangana High Court

TAYAL SONS PRIVATE LIMITED,HISAR vs. DCIT, HISAR

The Appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalita No. 3323/Del/2025 (A.Y. 2019-20) Tayal Sons Private Vs Dcit Limited Income Tax Office, Sesctor14, 653A, Kath Mandi Road, Hisar, Hisar, Haryana Pan: Aabct6693E Appellant Respondent Ita No. 3467/Del/2025 (A.Y. 2019-20) Dcit Vs Tayal Sons Private Limited Income Tax Office, 653A, Kath Mandi Road, Hisar, Sesctor14, Hisar, Haryana. Pan: Aabct6693E Appellant Respondent Assessee By Sh. Sh. Salil Kapoor, Adv, Ms. Ananya Kapoor, Adv, Ms. Ishitafarsiya, Adv, Ms. Soumya Singh, Adv& Ms. Sakshirustagi. Revenue By Ms. Amisha S. Gupt, Cit (Dr) Date Of Hearing 27/11/2025 Date Of Pronouncement 28/11/2025 Order Per Yogesh Kumar, U.S. Jm: The Captioned Two Appeals Are Filed By The Assessee & Two

276' has held that notice under Section 148 of 1961 Act cannot be issued by Jurisdictional Assessing Officer(for short 'JAO') after introduction of concept of faceless assessment under Section 151A read with Section 144B of 1961 Act. 6. Per contra, Mr.Amanpreet Singh, and Mr.Vaibhav Gupta, Standing Counsels for the respondents submit that Gauhati High Court and Telangana High Court

DCIT, HISAR vs. TAYAL SONS PVT. LTD., HISAR

The Appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalita No. 3323/Del/2025 (A.Y. 2019-20) Tayal Sons Private Vs Dcit Limited Income Tax Office, Sesctor14, 653A, Kath Mandi Road, Hisar, Hisar, Haryana Pan: Aabct6693E Appellant Respondent Ita No. 3467/Del/2025 (A.Y. 2019-20) Dcit Vs Tayal Sons Private Limited Income Tax Office, 653A, Kath Mandi Road, Hisar, Sesctor14, Hisar, Haryana. Pan: Aabct6693E Appellant Respondent Assessee By Sh. Sh. Salil Kapoor, Adv, Ms. Ananya Kapoor, Adv, Ms. Ishitafarsiya, Adv, Ms. Soumya Singh, Adv& Ms. Sakshirustagi. Revenue By Ms. Amisha S. Gupt, Cit (Dr) Date Of Hearing 27/11/2025 Date Of Pronouncement 28/11/2025 Order Per Yogesh Kumar, U.S. Jm: The Captioned Two Appeals Are Filed By The Assessee & Two

276' has held that notice under Section 148 of 1961 Act cannot be issued by Jurisdictional Assessing Officer(for short 'JAO') after introduction of concept of faceless assessment under Section 151A read with Section 144B of 1961 Act. 6. Per contra, Mr.Amanpreet Singh, and Mr.Vaibhav Gupta, Standing Counsels for the respondents submit that Gauhati High Court and Telangana High Court

DY. COMMISSIONER OF INCOME TAX, HISAR vs. M/S. TAYAL SONS PVT. LTD., HISAR

The Appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalita No. 3323/Del/2025 (A.Y. 2019-20) Tayal Sons Private Vs Dcit Limited Income Tax Office, Sesctor14, 653A, Kath Mandi Road, Hisar, Hisar, Haryana Pan: Aabct6693E Appellant Respondent Ita No. 3467/Del/2025 (A.Y. 2019-20) Dcit Vs Tayal Sons Private Limited Income Tax Office, 653A, Kath Mandi Road, Hisar, Sesctor14, Hisar, Haryana. Pan: Aabct6693E Appellant Respondent Assessee By Sh. Sh. Salil Kapoor, Adv, Ms. Ananya Kapoor, Adv, Ms. Ishitafarsiya, Adv, Ms. Soumya Singh, Adv& Ms. Sakshirustagi. Revenue By Ms. Amisha S. Gupt, Cit (Dr) Date Of Hearing 27/11/2025 Date Of Pronouncement 28/11/2025 Order Per Yogesh Kumar, U.S. Jm: The Captioned Two Appeals Are Filed By The Assessee & Two

276' has held that notice under Section 148 of 1961 Act cannot be issued by Jurisdictional Assessing Officer(for short 'JAO') after introduction of concept of faceless assessment under Section 151A read with Section 144B of 1961 Act. 6. Per contra, Mr.Amanpreet Singh, and Mr.Vaibhav Gupta, Standing Counsels for the respondents submit that Gauhati High Court and Telangana High Court

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

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

reassessment proceedings. 8. In light of the above, it is respectfully submitted that the consolidated approval granted by the Additional Commissioner of Income Tax for AYs 2012-13 to 2020- 21 and AY 2023-24 is illegal, invalid, and bad in law. Judicial Precedents against Consolidated/Mechanical Approval under Section 153D of the Act. 9. In this regard, reliance is placed

DCIT, NEW DELHI vs. M/S. VENUS OVERSEAS PVT. LTD., NEW DELHI

In the result, appeals of the Revenue are dismissed

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble

276, 277, 278 & 280/DEL/2015 [A.Ys 2006-07, 2007-08, 2008-09 & 2010-11] DCIT Vs. Venus Overseas Pvt. Ltd., Central Circle – 31, 112, DDA HOG Market, New Delhi Rajendra Palace, New Delhi PAN No. AAACV 0872 E [Appellant] [Respondent] Date of Hearing : 20.08.2020 Date of Pronouncement : 25.08.2020 Assessee by : Ms. Sunita Singh, CIT-D.R Revenue by : Shri Kapil Goel

DCIT, NEW DELHI vs. M/S. VENUS OVERSEAS PVT. LTD., NEW DELHI

In the result, appeals of the Revenue are dismissed

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble

276, 277, 278 & 280/DEL/2015 [A.Ys 2006-07, 2007-08, 2008-09 & 2010-11] DCIT Vs. Venus Overseas Pvt. Ltd., Central Circle – 31, 112, DDA HOG Market, New Delhi Rajendra Palace, New Delhi PAN No. AAACV 0872 E [Appellant] [Respondent] Date of Hearing : 20.08.2020 Date of Pronouncement : 25.08.2020 Assessee by : Ms. Sunita Singh, CIT-D.R Revenue by : Shri Kapil Goel

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

276/- (2117597-736321). 3. The Ld. PCIT observed that as per the provisions of Section 263, if an order is passed without proper enquiry it will be held as erroneous. He further observed that as the assessment order under Section 147 read with Section 144B of the Act by AO was passed on 30.3.2022 without proper perusal and investigation

ASHOK KUMAR BANSAL,GURGAON vs. PR, CIT CENTRAL, DELHI-1, DELHI

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

reassessment proceedings under Section 153C r.w.s 143(3) of the Act on the necessary evidences furnished by the assessee in support of the acquisition and sale on diamonds proof whereof alleged to have been found during the course of search of locker the order impugned is liable to be quashed. 12. It appears on record that a notice dated

ASHOK KUMAR BANSAL,GURGAON vs. PR, CIT CENTRAL DELHI-1, DELHI

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

reassessment proceedings under Section 153C r.w.s 143(3) of the Act on the necessary evidences furnished by the assessee in support of the acquisition and sale on diamonds proof whereof alleged to have been found during the course of search of locker the order impugned is liable to be quashed. 12. It appears on record that a notice dated

ASHOK KUMAR BANSAL,GURGAON vs. PR, CIT CENTRAL DELHI-1, DELHI

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

reassessment proceedings under Section 153C r.w.s 143(3) of the Act on the necessary evidences furnished by the assessee in support of the acquisition and sale on diamonds proof whereof alleged to have been found during the course of search of locker the order impugned is liable to be quashed. 12. It appears on record that a notice dated

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

276/- (2117597-736321). 3. The Ld. PCIT observed that as per the provisions of Section 263, if an order is passed without proper enquiry it will be held as erroneous. He further observed that as the assessment order under Section 147 read with Section 144B of the Act by FAO was passed on 30.3.2022 without proper perusal and investigation

SANDEEP KAPUR,GURUGRAM vs. COMMISSIONER OF INCOME TAX (APPEALS), DELHI

In the result the appeal of the assessee is allowed

Bench: Shri Sudhir Kumar & Shri Manish Agarwalassessment Year: 2015-16

276/- after making the addition of Rs.65,32,626/- u/s 69A of the Act. 4. Aggrieved the order of the AO the assessee preferred the appeal before the NFAC who vide order dated 26-02-2025 dismissed the appeal of the assessee. Being aggrieved the order of the Ld. NFAC the assessee is in appeal before the Tribunal

SUNRISE PORPBUILD PVT LTD,DELHI vs. ACIT, CENTRAL CIRCLE-2, FARIDABAD

In the result, Appeals in ITA

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ita No. 1258/Del/2025 (A.Y. 2012-13) M/S Sunrise Propbuild Pvt. Ltd. V Assistant Commissioner Of House No. B-4, 1St Floor, Shop S Income Tax, Central Circle-Ii, No. 25, Ashirward Complex, Faridabad, Village Pitampura, New Delhi- Haryana-121001 110034 Pan: Aapcs2201K Appellant Respondent Assessee By Sh. S. S. Nagar, Ca Revenue By Ms.Suman Malik, Cit Dr Date Of Hearing 08/09/2025 Date Of Pronouncement 26/11/2025

reassessment proceedings u/s 147 of the Act was based on borrowed satisfaction and without application of mind. 6.2 That on the facts and in the circumstances of the case, the Ld. CIT-(A) has erred in upholding the order of Ld. A.O without Sunrise Propbuild Pvt. Ltd. Vs. ACIT considering the fact that the reasons u/s 148 were recorded merely

SUNRISE PROPBUILD PVT LTD.,DELHI vs. ACIT, CENTRAL CIRCLE-2, FARIDABAD

In the result, Appeals in ITA

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ita No. 1258/Del/2025 (A.Y. 2012-13) M/S Sunrise Propbuild Pvt. Ltd. V Assistant Commissioner Of House No. B-4, 1St Floor, Shop S Income Tax, Central Circle-Ii, No. 25, Ashirward Complex, Faridabad, Village Pitampura, New Delhi- Haryana-121001 110034 Pan: Aapcs2201K Appellant Respondent Assessee By Sh. S. S. Nagar, Ca Revenue By Ms.Suman Malik, Cit Dr Date Of Hearing 08/09/2025 Date Of Pronouncement 26/11/2025

reassessment proceedings u/s 147 of the Act was based on borrowed satisfaction and without application of mind. 6.2 That on the facts and in the circumstances of the case, the Ld. CIT-(A) has erred in upholding the order of Ld. A.O without Sunrise Propbuild Pvt. Ltd. Vs. ACIT considering the fact that the reasons u/s 148 were recorded merely

AGS DEVELOPERS PVT LTD ,JASOLA DELHI vs. INCOME TAX OFFICER WARD 1 (4), NEW DELHI

In the result, the appeal of the assessee is partly allowed

Bench: Shri Kul Bharat[Assessment Year : 2008-09] Ags Developers Pvt.Ltd., Vs Ito, H.No.47, Pocket Ii, Ward -1(4), Near Appollo Hospital, Jasola, New Delhi. New Delhi-110076. Pan-Aafca1795G Appellant Respondent Appellant By Shri Sandeep Goel, Adv. Respondent By Shri Siddharth B.S. Meena, Sr.Dr Date Of Hearing 04.09.2024 Date Of Pronouncement 18.10.2024

reassessment under section 147. Hon'ble Delhi High Court in CIT Vs RRJ securities Ltd [2015] taxmann.com391 has discussed in detail as to when the AO assumes jurisdiction under section 153C. Though that decision has been rendered in a different context but lays down clear guidelines for the AOs to proceed under section 153C. Further CASE LAWS on merits: There

MR. JAGAT SINGH,,DELHI vs. ACIT, NEW DELHI

Bench: Shri N. K. Saini & Ms Suchitra Kambleita No. 3037/Del/2015 ( A.Y 2005-06) Ita No. 3039/Del/2015 ( A.Y 2007-08)

276 ITR 549, that for applying section 69 of the Act, the Assessing Officer must first come to a finding that the assessee made investments which were not recorded in the books of account and thereafter call for an explanation from the assessee about the nature and source of the investments. It is thus implicit that the Assessing Officer

MR. JAGAT SINGH,,DELHI vs. ACIT, NEW DELHI

Bench: Shri N. K. Saini & Ms Suchitra Kambleita No. 3037/Del/2015 ( A.Y 2005-06) Ita No. 3039/Del/2015 ( A.Y 2007-08)

276 ITR 549, that for applying section 69 of the Act, the Assessing Officer must first come to a finding that the assessee made investments which were not recorded in the books of account and thereafter call for an explanation from the assessee about the nature and source of the investments. It is thus implicit that the Assessing Officer