SHRI VALMIK THAPAR,NEW DELHI vs. DCIT, NEW DELHI

Appeals are disposed of by this common order as indicated above

Bench: Hon’Ble Justice P.P. Bhatt & Shri Prashant Maharishi(Through Video Conferencing) Shri Valmik Thapar, Vs. Acit, 19, Kautilya Marg, Circle-53(1), New Delhi New Delhi (Appellant) (Respondent) Shri Valmik Thapar, Vs. Dcit, M/S. R. N. Khanna & Company, Ca, Circle-32(1), 14-15F, Shivam House, Connaught New Delhi Place, New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Acit, Vs. Shri Valmik Thapar, Circle-53(1), 19, Kautilya Marg, New Delhi New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Assessee By : Shri Salil Agarwal, Senior Advocate Along With Shri Shailesh Gupta, Shri Mahur Agarwal, Advocates Revenue By: Shri H. K. Choudhary, Cit Dr Date Of Hearing 11/06/2021 (Last Hearing) Date Of Pronouncement 11/06/2021. O R D E R Per Prashant Maharishi, A. M. 1. These Are Three Appeals For Two Assessment Years Pertaining To One Assessee, Mr. Valmik Thapar, A Resident, Individual [Assessee]. Assessee Filed Ita Number

Section and was without jurisdiction and was liable to be quashed as such.” 5. Relying heavily on the decision of the Honourable Supreme Court in case of National Thermal Power Co Ltd versus Commissioner of Income Tax [229 ITR 383], assessee submitted that assessee is challenging the reopening of the assessment proceedings, which is a jurisdictional ground, which

ACIT, NEW DELHI vs. SH. VALMIK THAPAR, NEW DELHI

Appeals are disposed of by this common order as indicated above

Bench: Hon’Ble Justice P.P. Bhatt & Shri Prashant Maharishi(Through Video Conferencing) Shri Valmik Thapar, Vs. Acit, 19, Kautilya Marg, Circle-53(1), New Delhi New Delhi (Appellant) (Respondent) Shri Valmik Thapar, Vs. Dcit, M/S. R. N. Khanna & Company, Ca, Circle-32(1), 14-15F, Shivam House, Connaught New Delhi Place, New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Acit, Vs. Shri Valmik Thapar, Circle-53(1), 19, Kautilya Marg, New Delhi New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Assessee By : Shri Salil Agarwal, Senior Advocate Along With Shri Shailesh Gupta, Shri Mahur Agarwal, Advocates Revenue By: Shri H. K. Choudhary, Cit Dr Date Of Hearing 11/06/2021 (Last Hearing) Date Of Pronouncement 11/06/2021. O R D E R Per Prashant Maharishi, A. M. 1. These Are Three Appeals For Two Assessment Years Pertaining To One Assessee, Mr. Valmik Thapar, A Resident, Individual [Assessee]. Assessee Filed Ita Number

Section and was without jurisdiction and was liable to be quashed as such.” 5. Relying heavily on the decision of the Honourable Supreme Court in case of National Thermal Power Co Ltd versus Commissioner of Income Tax [229 ITR 383], assessee submitted that assessee is challenging the reopening of the assessment proceedings, which is a jurisdictional ground, which

SH. VALMIK THAPAR,NEW DELHI vs. ACIT, NEW DELHI

Appeals are disposed of by this common order as indicated above

Bench: Hon’Ble Justice P.P. Bhatt & Shri Prashant Maharishi(Through Video Conferencing) Shri Valmik Thapar, Vs. Acit, 19, Kautilya Marg, Circle-53(1), New Delhi New Delhi (Appellant) (Respondent) Shri Valmik Thapar, Vs. Dcit, M/S. R. N. Khanna & Company, Ca, Circle-32(1), 14-15F, Shivam House, Connaught New Delhi Place, New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Acit, Vs. Shri Valmik Thapar, Circle-53(1), 19, Kautilya Marg, New Delhi New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Assessee By : Shri Salil Agarwal, Senior Advocate Along With Shri Shailesh Gupta, Shri Mahur Agarwal, Advocates Revenue By: Shri H. K. Choudhary, Cit Dr Date Of Hearing 11/06/2021 (Last Hearing) Date Of Pronouncement 11/06/2021. O R D E R Per Prashant Maharishi, A. M. 1. These Are Three Appeals For Two Assessment Years Pertaining To One Assessee, Mr. Valmik Thapar, A Resident, Individual [Assessee]. Assessee Filed Ita Number

Section and was without jurisdiction and was liable to be quashed as such.” 5. Relying heavily on the decision of the Honourable Supreme Court in case of National Thermal Power Co Ltd versus Commissioner of Income Tax [229 ITR 383], assessee submitted that assessee is challenging the reopening of the assessment proceedings, which is a jurisdictional ground, which

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)

section 1448 of IT Act, the case was duly transferred to the jurisdiction AO, who has no previous idea about the assessment proceedings in the case. However it is pointed out, that, even during the DRP stage and even after providing opportunity by AO, the assessee could not submit any evidence with respect to bank statement of assessee and also

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

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

65,527/- to the income declared in the return filed in response to notice u/s 148 by estimating the profits on undisclosed sales. 5. Against the said order, assessee filed an appeal before Ld. CIT(A) who vide order dated 28.02.2025, quashed reassessment order on the ground of limitations. 6. Aggrieved by the order of Ld. CIT(A), revenue

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

65 lakh made under Section 132(4) of the Act and incorporated in the ROI. 6. On perusal of the assessment order framed under S. 153A, it is noticed that the Assessing Officer in paragraph 3 of the assessment order has admitted that the disclosure made under Section 132(4) of Rs.65 lakh was duly included in the return

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT CC-2 , FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

65 lakh made under Section 132(4) of the Act and incorporated in the ROI. 6. On perusal of the assessment order framed under S. 153A, it is noticed that the Assessing Officer in paragraph 3 of the assessment order has admitted that the disclosure made under Section 132(4) of Rs.65 lakh was duly included in the return

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

65 lakh made under Section 132(4) of the Act and incorporated in the ROI. 6. On perusal of the assessment order framed under S. 153A, it is noticed that the Assessing Officer in paragraph 3 of the assessment order has admitted that the disclosure made under Section 132(4) of Rs.65 lakh was duly included in the return

A2Z MAINTENANCE & ENGINEERING SERVICES LTD.,GURGAON vs. DCIT, CENTRAL CIRCLE-II, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

65 lakh made under Section 132(4) of the Act and incorporated in the ROI. 6. On perusal of the assessment order framed under S. 153A, it is noticed that the Assessing Officer in paragraph 3 of the assessment order has admitted that the disclosure made under Section 132(4) of Rs.65 lakh was duly included in the return

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. CCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

65 lakh made under Section 132(4) of the Act and incorporated in the ROI. 6. On perusal of the assessment order framed under S. 153A, it is noticed that the Assessing Officer in paragraph 3 of the assessment order has admitted that the disclosure made under Section 132(4) of Rs.65 lakh was duly included in the return

DCIT-CENTRAL CIRCLE-2, FARIDABAD vs. A2Z INFRA ENGINEERS LTD., GURGAON

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

65 lakh made under Section 132(4) of the Act and incorporated in the ROI. 6. On perusal of the assessment order framed under S. 153A, it is noticed that the Assessing Officer in paragraph 3 of the assessment order has admitted that the disclosure made under Section 132(4) of Rs.65 lakh was duly included in the return

DCIT CC-2 , FARIDABAD vs. A2Z MAINTENANCE AND ENGINEERING SERVICES LTD., GURGAON

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

65 lakh made under Section 132(4) of the Act and incorporated in the ROI. 6. On perusal of the assessment order framed under S. 153A, it is noticed that the Assessing Officer in paragraph 3 of the assessment order has admitted that the disclosure made under Section 132(4) of Rs.65 lakh was duly included in the return

INFRA ENGINEERS LTD.,GURGAON vs. DCIT, CC-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

65 lakh made under Section 132(4) of the Act and incorporated in the ROI. 6. On perusal of the assessment order framed under S. 153A, it is noticed that the Assessing Officer in paragraph 3 of the assessment order has admitted that the disclosure made under Section 132(4) of Rs.65 lakh was duly included in the return

(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 the proceedings of which have been completed before the 1st day of October, 2009. (3) Where during the course of any proceeding for the assessment of income

PR. COMMISSIONER OF INCOME TAX-19 vs. SHRI ANKUR AGGARWAL

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE NAJMI WAZIRI

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in this sub-section pending on the date of initiation of the search under Section 132 or making of requisition under Section 132A, as the case may be, shall abate.” What is clear from this is that Section 153A

PR. COMMISSIONER OF INCOME TAX-19 vs. SHRI NEERAJ JINDAL

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE NAJMI WAZIRI

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in this sub-section pending on the date of initiation of the search under Section 132 or making of requisition under Section 132A, as the case may be, shall abate.” What is clear from this is that Section 153A

PR. COMMISSIONER OF INCOME TAX-19 vs. SHRI ANKUR AGGARWAL

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE NAJMI WAZIRI

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in this sub-section pending on the date of initiation of the search under Section 132 or making of requisition under Section 132A, as the case may be, shall abate.” What is clear from this is that Section 153A

PR. COMMISSIONER OF INCOME TAX -7 vs. SUMITOMO CORPORATION INDIA (P) LTD.

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE RAVINDER DUDEJA

reassessment or recomputation, as the case may be, shall, after the exclusion of the period under sub-section (5) of the said section, be not less than one year; and where such period of limitation is less than one year, it shall be deemed to have been extended to one year: Provided also that for the purposes of determining

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MICROSOFT INDIA ( R & D) PVT. LTD.

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

reassessment or recomputation, as the case may be, shall, after the exclusion of the period under sub-section (5) of the said section, be not less than one year; and where such period of limitation is less than one year, it shall be deemed to have been extended to one year: Provided also that for the purposes of determining