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274 results for “reassessment”+ Section 56(2)(vii)clear

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Delhi274Mumbai262Bangalore110Ahmedabad107Chennai78Jaipur69Chandigarh67Hyderabad61Raipur38Amritsar33Guwahati32Kolkata27Pune26Indore23Nagpur20Jodhpur20Patna18Cochin15Agra14Lucknow14Rajkot14Surat12Ranchi7Cuttack4Allahabad4Dehradun2

Key Topics

Section 153A79Addition to Income50Section 143(3)48Section 153C37Disallowance30Section 14825Section 14724Bogus Purchases21Section 26319Section 68

BIMLA,DELHI vs. ITO WARD-38(5), NEW DELHI

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

ITA 7973/DEL/2019[2014-15]Status: DisposedITAT Delhi26 Nov 2024AY 2014-15

Bench: Shri S.Rifaur Rahman & Shri Sudhir Pareekbimla, Vs. Ito, Ward 38 (5), H.No.143, Village Hamidpur, New Delhi. Delhi – 110 036. (Pan : Bpdpb9344B) (Appellant) (Respondent) Assessee By : Shri Gautam Jain, Advocate Shri Ankit Kumar, Advocate Revenue By : Shri Kanv Bali, Sr. Dr Date Of Hearing : 18.09.2024 Date Of Order : 26.11.2024 Order Per S.Rifaur Rahman,Am: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax Appeals-13, New Delhi (Hereinafter Referred To ‘Ld. Cit (A)’) Dated 23.07.2019 For Assessment Year 2014-15. 2. Brief Facts Of The Case Are, Assessee Filed Return Of Income Declaring Total Income Of Rs.2,23,030/- On 14.08.2014. The Return Of Income Was Processed Under Section 143 (1) Of The Income-Tax Act, 1961 (For Short ‘The Act’). The Case Was Selected For Scrutiny Through Cass & Notices

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Shri Kanv Bali, Sr. DR
Section 131Section 143Section 143(2)Section 69

reassess the income of the assessee for the AY 2013-14 after due application of mind independently 5. Ld. CIT (A) observed the purchase amount at Rs.1,63,50,103/- on the basis of circle rate on which stamp duty was paid in the light of section 56(2)(vii

Showing 1–20 of 274 · Page 1 of 14

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Section 69B19
Reassessment19

MAHAVIR TRANSMISSIN LTD ,NEW DELHI vs. DCIT, CENTRAL CIRCLE-25 , NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2635/DEL/2022[2020-21]Status: DisposedITAT Delhi02 Jul 2024AY 2020-21

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

vii).] Following clause (xi) shall be inserted after clause (x) of sub-section (2) of section 56 by the Finance Act, 2018, w.e.f. 1-4-2019: (xi) any compensation or other payment, due to or received by any person, by whatever name called, in connection with the termination of his employment or the modification of the terms and conditions relating

MAHAVIR TRANSMISSION LTD,NEW DELHI vs. DCIT, CENTRAL CORCLE-25, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2633/DEL/2022[2018-19]Status: DisposedITAT Delhi02 Jul 2024AY 2018-19

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

vii).] Following clause (xi) shall be inserted after clause (x) of sub-section (2) of section 56 by the Finance Act, 2018, w.e.f. 1-4-2019: (xi) any compensation or other payment, due to or received by any person, by whatever name called, in connection with the termination of his employment or the modification of the terms and conditions relating

DCIT, CENTRAL CIRCLE-25, NEW DELHI vs. MAHAVEER TRANSMISSION LTD, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2844/DEL/2022[2017-18]Status: DisposedITAT Delhi02 Jul 2024AY 2017-18

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

vii).] Following clause (xi) shall be inserted after clause (x) of sub-section (2) of section 56 by the Finance Act, 2018, w.e.f. 1-4-2019: (xi) any compensation or other payment, due to or received by any person, by whatever name called, in connection with the termination of his employment or the modification of the terms and conditions relating

MAHAVIR TRANSMISSION LTD,NEW DELHI vs. DCIT, CENTRAL CIRCLE-25, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2634/DEL/2022[2019-20]Status: DisposedITAT Delhi02 Jul 2024AY 2019-20

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

vii).] Following clause (xi) shall be inserted after clause (x) of sub-section (2) of section 56 by the Finance Act, 2018, w.e.f. 1-4-2019: (xi) any compensation or other payment, due to or received by any person, by whatever name called, in connection with the termination of his employment or the modification of the terms and conditions relating

DCIT, CENTRAL CIRCLE-25, NEW DELHI vs. MAHAVEER TRANSMISSION LTD., NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2845/DEL/2022[2018-19]Status: DisposedITAT Delhi02 Jul 2024AY 2018-19

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

vii).] Following clause (xi) shall be inserted after clause (x) of sub-section (2) of section 56 by the Finance Act, 2018, w.e.f. 1-4-2019: (xi) any compensation or other payment, due to or received by any person, by whatever name called, in connection with the termination of his employment or the modification of the terms and conditions relating

MAHAVIR TRANSMISSION LTD,NEW DELHI vs. DCIT, CENTRAL CIRCLE-25, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2632/DEL/2022[2017-18]Status: DisposedITAT Delhi02 Jul 2024AY 2017-18

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

vii).] Following clause (xi) shall be inserted after clause (x) of sub-section (2) of section 56 by the Finance Act, 2018, w.e.f. 1-4-2019: (xi) any compensation or other payment, due to or received by any person, by whatever name called, in connection with the termination of his employment or the modification of the terms and conditions relating

DCIT, CENTRAL CIRCLE-25, NEW DELHI vs. MAHAVEER TRANSMISSION LTD, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2846/DEL/2022[2019-20]Status: DisposedITAT Delhi02 Jul 2024AY 2019-20

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

vii).] Following clause (xi) shall be inserted after clause (x) of sub-section (2) of section 56 by the Finance Act, 2018, w.e.f. 1-4-2019: (xi) any compensation or other payment, due to or received by any person, by whatever name called, in connection with the termination of his employment or the modification of the terms and conditions relating

COMMISSIONER OF WEALTH TAX vs. S.S. AHLUWALIA

ITA/255/2002HC Delhi14 Mar 2014
Section 142(1)Section 143(1)Section 143(2)Section 148

vii) Upon receipt of notice under Section 142(1), the respondent had objected to the jurisdiction of the AO, Delhi. The respondent assessee denied receipt of notice under Section 148 of the Act issued by AO, Delhi for the three assessment years. The respondent had correctly objected to the assumption of jurisdiction by the AO, Delhi within the statutory time

NARESH KUMAR MORYA,NARELA vs. INCOME TAX OFFICER, WARD 61(1), CIVIC CENTRE

In the result, the appeal of the assessee is allowed

ITA 2292/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Jan 2026AY 2017-18

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhannaresh Kumar Morya, Vs. Income Tax Officer, Rajiv Colony, Narela, Ward-61(1), New Delhi Delhi (Appellant) (Respondent) Pan: Ahupm7348A

For Appellant: Shri H. S. Hooda, AdvFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 147Section 148Section 151Section 50CSection 50C(1)Section 56(2)(vii)Section 56(2)(x)

reassessment proceedings, the learned AO showcaused the assessee as to why the differential consideration of Rs. 3,32,960 (52,32,960 minus Rs. 49 lakhs) be not treated as income from other sources as per the provisions of Section 56(2)(vii

RHYTHM POLYMERS PVT. LTD.,NEW DELHI vs. PR, CIT DELHI-7, DELHI

In the result, appeal of the assessee is allowed

ITA 423/DEL/2022[2015-16]Status: DisposedITAT Delhi19 Sept 2023AY 2015-16

Bench: Dr. Brr Kumar & Ms. Astha Chandraasstt. Year 2015-16

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 263Section 56(2)(vii)

reassessment under Section 263 of the Act 5. On the facts and circumstances of the case, the learned Pr. CIT has erred both on facts and in law in ignoring the contention of the appellant that the proceeding under Section 263 cannot be used for substituting option of the A.O. by that of the Pr. CIT 6. On the facts

BALLU SINGH,GURGAON vs. ITO WARD -65(5), NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 799/DEL/2020[2008-09]Status: DisposedITAT Delhi15 May 2023AY 2008-09

Bench: Shri Kul Bharat

Section 133(6)Section 143(2)Section 143(3)Section 144Section 147Section 148Section 44ASection 69A

56-60) & Axis Bank Limited (paper book page no. 61- 65)] and on 02/01/2016 by SBI (paper book page no. 51-55)] and later on furnished to the Ld. AO'. Obviously, there was no tangible materials in the possession of Ld. AO on the basis of which he makes a belief as to escapement of income. Reasons recorded

BALLU SINGH,GURGAON vs. ITO WARD -65(5), NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 800/DEL/2020[2009-10]Status: DisposedITAT Delhi15 May 2023AY 2009-10

Bench: Shri Kul Bharat

Section 133(6)Section 143(2)Section 143(3)Section 144Section 147Section 148Section 44ASection 69A

56-60) & Axis Bank Limited (paper book page no. 61- 65)] and on 02/01/2016 by SBI (paper book page no. 51-55)] and later on furnished to the Ld. AO'. Obviously, there was no tangible materials in the possession of Ld. AO on the basis of which he makes a belief as to escapement of income. Reasons recorded

ITO, WARD-52(1), NEW DELHI vs. ARTI JINDAL , DELHI

ITA 1502/DEL/2021[2014-2015]Status: DisposedITAT Delhi02 Nov 2023AY 2014-2015

Bench: Shri N. K. Billaiya & Shri Anubhav Sharma

Section 143(1)Section 143(3)Section 148

vii)(c) of the Act in the hands of assessee. The assessee, being director of Glebe and having substantial shareholding d) (till transfer of her shares to the Trust) in Glebe, has benefited within the terms of section 2(24)(iv) of the Act read with section 56(1) of the Act; The Specified Shares received by Glebe, having

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

The appeal of the Revenue is dismissed as infructuous

ITA 1883/DEL/2023[2017-18]Status: DisposedITAT Delhi06 Sept 2024AY 2017-18

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:

For Appellant: Sh. Anil Jain, CAFor Respondent: Ms. Monika Dhami, CIT-DR
Section 139Section 143Section 143(3)Section 144Section 147Section 148Section 153CSection 254Section 263Section 264

reassessment shall be completed in accordance with the provisions of this section as it stood immediately before its substitution by the Finance Act, 2016 (28 of 2016). Explanation 1.—For the purposes of this section, in computing the period of limitation— ITA Nos. 1883 & 2144/Del/2023 8 Vijay Kumar Soni (i) the time taken in reopening the whole or any part

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

The appeal of the Revenue is dismissed as infructuous

ITA 2144/DEL/2023[2017-18]Status: DisposedITAT Delhi06 Sept 2024AY 2017-18

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:

For Appellant: Sh. Anil Jain, CAFor Respondent: Ms. Monika Dhami, CIT-DR
Section 139Section 143Section 143(3)Section 144Section 147Section 148Section 153CSection 254Section 263Section 264

reassessment shall be completed in accordance with the provisions of this section as it stood immediately before its substitution by the Finance Act, 2016 (28 of 2016). Explanation 1.—For the purposes of this section, in computing the period of limitation— ITA Nos. 1883 & 2144/Del/2023 8 Vijay Kumar Soni (i) the time taken in reopening the whole or any part

INCOME TAX OFFICER, DELHI vs. RATNA AGGARWAL, DELHI

ITA 21/DEL/2025[2018-19]Status: DisposedITAT Delhi04 Feb 2026AY 2018-19

Bench: Shri Anubhav Sharma & Shri Manish Agarwalincome Tax Officer Vs. Ratna Aggarwal Room No. 1210, E-2, Krishna Nagar, Block, Civic Center, New Delhi – 110051 Minto Road, New Delhi – 110002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aefpa6066B Appellant .. Respondent

For Appellant: Sh. Mayank Patawali, AdvFor Respondent: Sh. Krishna Kumar Ramawat, Sr
Section 147Section 148Section 2(47)Section 56(2)

reassessment proceeding assessee revised computation claiming that the said property were received by her in family settlement and therefore the value of the property is not taxable, however, AO did not agree and made addition of the same. 3. The case of the assessee is that immovable property was received by Shri Rajiv Agarwal by way of registered gift deed

DELIGHT PROPCON PRIVATE LIMITED,DELHI vs. ACIT, CENTRAL CIRCLE-2, FARIDABAD

In the result, Appeal of the Assessee is partly allowed

ITA 1267/DEL/2025[2011-12]Status: DisposedITAT Delhi26 Nov 2025AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.M/S Delight Propcon Private Vs Assistant Commissioner Of Limited Shop No. 68, Building Income Tax, No. 38, Surya House, Near Central Circle-Ii, New Cgo Pnb Devil Road, Khanpur, Complex, N. H. Iv, Nit New Delhi Faridabad, Haryana-121001 Pan: Aadcd6203E Appellant Respondent Assessee By Sh. S. S. Nagar, Ca Revenue By Sh. Suman Malik, Cit(Dr) Date Of Hearing 08/09/2025 Date Of Pronouncement 26/11/2025 Order

Section 143(2)Section 147Section 148Section 151Section 153CSection 68

vii)(b) of the Act are also not applicable in case of partnership firm or LLP and the assessee is a LLP. The Section 56(2)(x) which may be applicable in case of partnership firm or LLP was introduced with effect from A.Y. 2018-19 while the present case is with regard to A.Y. 2015-16. Thus

TRANS WORLD INTERNATIONAL LLC,WILMINGTON, DELAWARE, USA vs. DEPUTY COMMISSIONER OF INCOME TA, CIRCLE 3(1)(1), INTERNATIONAL TAXATION, CIVIC CENTRE, NEAR MINTO ROAD, NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 2146/DEL/2024[2015-16]Status: DisposedITAT Delhi18 Jun 2025AY 2015-16

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 147Section 148

vii. Trademark or viii. Similar property 3.9. Thereafter, the Assessing Officer referring to the Explanation-6 inserted by the Legislature to specifically clarify that the expression ‘process’ used in Explanation-2 would include and should be deemed to have always included transmission by satellite (including up- linking, amplification, conversion for down-linking of any signal), cable, optic-fibre

COMPUTER MODELLING GROUP LIMITED,CANADA vs. ACIT, CIRCLE-1(2)(1), INT. TAXATION, NEW DELHI

In the result, all the four appeals of the assessee for AY 2012-13,

ITA 2305/DEL/2022[2019-20]Status: DisposedITAT Delhi03 May 2024AY 2019-20

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

Section 143(3)Section 144CSection 144C(13)Section 153Section 234ASection 234BSection 250Section 271(1)(c)Section 44B

56,543/-under Section 44BB of the Act, is wrong and bad in law as the same cannot be taxed at all in the absence of any Permanent Establishment ('PE') of the Appellant in India in terms of the beneficial provisions under India-Canada DTAA. 2. That the Ld. DRP has grossly erred on in law by blindly relying upon