JAGPAL,GURUGRAM vs. PR. COMMISSIONER OF INCOME TAX, FARIDABAD

In the result, appeal of assessee in ITA No

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

reassessment proceedings, accepted the claim of the assessee vide his order dated 21.03.2023. 5. The PCIT, Faridabad found that the AO did not conduct proper enquiry in terms of law laid down by Supreme Court and Punjab & Haryana High Court as well law provided in the Act in terms of section 56(2)(viii) r.w. 57(iv) read with section

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

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

reassessment is quashed, the other grounds raised by the assessee challenging the validity of the addition on merits need not be gone into and they are left open. 11. In the result, the appeal of the assessee is allowed.” 6. Further the Hon'ble Jurisdictional i.e. High Court of Punjab and Haryana in the case of Jatinder Singh Bhangu (supra

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

reassessment is quashed, the other grounds raised by the assessee challenging the validity of the addition on merits need not be gone into and they are left open. 11. In the result, the appeal of the assessee is allowed.” 6. Further the Hon'ble Jurisdictional i.e. High Court of Punjab and Haryana in the case of Jatinder Singh Bhangu (supra

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

reassessment is quashed, the other grounds raised by the assessee challenging the validity of the addition on merits need not be gone into and they are left open. 11. In the result, the appeal of the assessee is allowed.” 6. Further the Hon'ble Jurisdictional i.e. High Court of Punjab and Haryana in the case of Jatinder Singh Bhangu (supra

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

reassessment is quashed, the other grounds raised by the assessee challenging the validity of the addition on merits need not be gone into and they are left open. 11. In the result, the appeal of the assessee is allowed.” 6. Further the Hon'ble Jurisdictional i.e. High Court of Punjab and Haryana in the case of Jatinder Singh Bhangu (supra

INCOME TAX OFFICER WARD-2(2)(1), GHAZIABAD, GHAZIABAD vs. VIKAS SHARMA, GHAZIABAD

In the result, the appeal filed by the Revenue in AY 2013-14 is dismissed

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

reassessment notice under section 148 of the new regime. Thus, in this illustration, the time limit for issuance of a notice under section 148 of the new regime will end on 18 August 2022.” 8. Further we observe that Hon’ble Gujarat High Court (supra) in Southern Gujarat Chamber Trade and Industrial Development Centre vs ITO (Gujarat HC) has decided

INCOME TAX OFFICER WARD-2(2)(1), GHAZIABAD, GHAZIABAD vs. VIKAS SHARMA, GHAZIABAD

In the result, the appeal filed by the Revenue in AY 2013-14 is dismissed

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

reassessment notice under section 148 of the new regime. Thus, in this illustration, the time limit for issuance of a notice under section 148 of the new regime will end on 18 August 2022.” 8. Further we observe that Hon’ble Gujarat High Court (supra) in Southern Gujarat Chamber Trade and Industrial Development Centre vs ITO (Gujarat HC) has decided

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

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

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

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

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

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

ALANKIT FOREX INDIA LIMITED,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

ALANKIT FINSEC LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

ALANKIT FINSEC LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

ALKA AGARWAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

ALKA AGARWAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

ALANKIT FOREX INDIA LIMITED,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

ALANKIT FINSEC LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

reassess total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain