ARGOS HOLDINGS PTE. LTD.,SINGAPORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE INT TAX 1(1)(1), DELHI, DELHI

In the result, appeal filed by the assessee is partly allowed

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

5 read with Section 6. (See: GVK Industries Ltd. v. ITO [(2011) 332 ITR 130 (SC)]). Even in respect of foreign companies, jurisdiction can only be assumed where residence is established under Section 6(3), or income is deemed to accrue or arise in India under Section 9. Service of a notice under Section 148 upon an assessee outside India

BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-18, NEW DELHI

In the result, the appeals of the revenue in ITA No

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

5. On 31-3-1994, the appellant was served with impugned notices under section 148 of the Act for 16 assessment years, ie, 1968-69 to 1971-72 and the assessment years 1981-82 10 1992-93. 6. The appellant, in the High Court, assailed the notices issued under section 148 for reassessment the assessment years

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

5. On 31-3-1994, the appellant was served with impugned notices under section 148 of the Act for 16 assessment years, ie, 1968-69 to 1971-72 and the assessment years 1981-82 10 1992-93. 6. The appellant, in the High Court, assailed the notices issued under section 148 for reassessment the assessment years

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:

5. In this regard, the provisions of Section 153C are as under: “Time limit for completion of assessment, reassessment and re- computation. 153. (1) No order of assessment shall be made under section 143 or section 144 at any time after the expiry of twenty-one months from the end of the assessment year in which the income was first

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:

5. In this regard, the provisions of Section 153C are as under: “Time limit for completion of assessment, reassessment and re- computation. 153. (1) No order of assessment shall be made under section 143 or section 144 at any time after the expiry of twenty-one months from the end of the assessment year in which the income was first

CHIRAG KIRPAL,DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, GURGAON

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh & Shri Vimal Kumarchirag Kirpal, Vs. Acit, C/O. Anuj Bhatia, C-3, Bali International Taxation, Nagar, New Raja Garden, Gurgaon New Delhi (Appellant) (Respondent) Pan: Bwxpk8788D Assessee By : Shri. S. K. Gupta, Ca Revenue By: Shri M. S. Nethrapal, Cit Dr Date Of Hearing 17/09/2025 Date Of Pronouncement 30/09/2025

5. Mr. Sandeep Goyal, Advocate for the petitioner(s) submits that notice dated 28.03.2024 issued under Section 148 is in contravention of notification dated 29.03.2022 as well as Section 151A of 1961 Act whereby concept of Faceless Assessment has been introduced. A Division Bench of Telangana High Court in 'Kankanala Ravindra Reddy v. Income-Tax Officer [2023] 156 taxmann.com 178/295

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

5. Mr. Sandeep Goyal, Advocate for the petitioner(s) submits that notice dated 28.03.2024 issued under Section 148 is in contravention of notification dated 29.03.2022 as well as Section 151A of 1961 Act whereby concept of Faceless Assessment has been introduced. A Division Bench of Telangana High Court in 'KankanalaRavindra Reddy v. Income-Tax Officer [2023] 156 taxmann.com 178/295 Taxman

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

5. Mr. Sandeep Goyal, Advocate for the petitioner(s) submits that notice dated 28.03.2024 issued under Section 148 is in contravention of notification dated 29.03.2022 as well as Section 151A of 1961 Act whereby concept of Faceless Assessment has been introduced. A Division Bench of Telangana High Court in 'KankanalaRavindra Reddy v. Income-Tax Officer [2023] 156 taxmann.com 178/295 Taxman

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

5. Mr. Sandeep Goyal, Advocate for the petitioner(s) submits that notice dated 28.03.2024 issued under Section 148 is in contravention of notification dated 29.03.2022 as well as Section 151A of 1961 Act whereby concept of Faceless Assessment has been introduced. A Division Bench of Telangana High Court in 'KankanalaRavindra Reddy v. Income-Tax Officer [2023] 156 taxmann.com 178/295 Taxman

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

5. Mr. Sandeep Goyal, Advocate for the petitioner(s) submits that notice dated 28.03.2024 issued under Section 148 is in contravention of notification dated 29.03.2022 as well as Section 151A of 1961 Act whereby concept of Faceless Assessment has been introduced. A Division Bench of Telangana High Court in 'KankanalaRavindra Reddy v. Income-Tax Officer [2023] 156 taxmann.com 178/295 Taxman

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

5) of that section, on or after the 1st day of April, 2021, in the case of the assessee; or (iii) the Assessing Officer is satisfied, with the prior approval of the Principal Commissioner or Commissioner, that any money, bullion, jewellery or other valuable article or thing, seized or requisitioned under section 132 or section 132A in 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

reassess the income of the other person in accordance with the person for the relevant assessment year or years referred to in sub- section (1) of section 153A. This amendment will take effect from 1st October, 2014." 43. It was consequent to the passing of the aforesaid Act that Section 153C came to incorporate provisions relating to the AO being

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 the income of the other person in accordance with the person for the relevant assessment year or years referred to in sub- section (1) of section 153A. This amendment will take effect from 1st October, 2014." 43. It was consequent to the passing of the aforesaid Act that Section 153C came to incorporate provisions relating to the AO being

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 the income of the other person in accordance with the person for the relevant assessment year or years referred to in sub- section (1) of section 153A. This amendment will take effect from 1st October, 2014." 43. It was consequent to the passing of the aforesaid Act that Section 153C came to incorporate provisions relating to the AO being

PRATISHTHA IMAGES PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

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

43. It was consequent to the passing of the aforesaid Act that Section 153C came to incorporate provisions relating to the AO being satisfied that the books of accounts, documents or assets seized or requisitioned must "have a bearing on the determination of the total income of such other person" for the six preceding AYs' or the "relevant assessment year

PRATISHTHA IMAGES PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

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

43. It was consequent to the passing of the aforesaid Act that Section 153C came to incorporate provisions relating to the AO being satisfied that the books of accounts, documents or assets seized or requisitioned must "have a bearing on the determination of the total income of such other person" for the six preceding AYs' or the "relevant assessment year

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

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

43. It was consequent to the passing of the aforesaid Act that Section 153C came to incorporate provisions relating to the AO being satisfied that the books of accounts, documents or assets seized or requisitioned must "have a bearing on the determination of the total income of such other person" for the six preceding AYs' or the "relevant assessment year

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

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

43. It was consequent to the passing of the aforesaid Act that Section 153C came to incorporate provisions relating to the AO being satisfied that the books of accounts, documents or assets seized or requisitioned must "have a bearing on the determination of the total income of such other person" for the six preceding AYs' or the "relevant assessment year

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

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

43. It was consequent to the passing of the aforesaid Act that Section 153C came to incorporate provisions relating to the AO being satisfied that the books of accounts, documents or assets seized or requisitioned must "have a bearing on the determination of the total income of such other person" for the six preceding AYs' or the "relevant assessment year