ITO, NEW DELHI vs. M/S. BILLET PROCON PVT. LTD., DELHI

In the result, appeal of the Revenue is dismissed

Bench: Shri Challa Nagendra Prasad\Nand\Nshri S Rifaur Rahman\N\Nita No. 1382/Del/2017\Nनिर्धारणवर्ष/Assessment Year: 2012-13\N\Nito,\Nward-5(1), Room No.379,\N3Rd Floor, C.R. Building, I.P. Estate,\Nnew Delhi.\Npan No.Aalfb8236G\Nअपीलार्थी Appellant\N\Nassessee By\Ndr. Kapil Goel, Adv.\N\Nrevenue By\Nshri Ajay Kumar Arora, Sr. Dr\N\Nसुनवाईकीतारीख / Date Of Hearing:\N27.05.2025\Nउद्घोषणाकीतारीख /Pronouncement On 25.06.2025\N\Nआदेश /Order\N\Nper C.N. Prasad, J.M.\N\Nthis Appeal Is Filed By The Revenue Against The Order Of The Ld. Cit(Appeals)-2, New Delhi Dated 30.11.2016 For The Ay 2012-13.\Nrevenue In Its Appeal Raised The Following Grounds: -\N\N1. “Whether On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Deleting The Addition Of Rs.3,52,00,000/- Made By Ao U/S 68 Of The I.T. Act On Account Of Unexplained Credits In The Form Of Share Capital/Share Premium During The Year.\N\N2. Whether On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Holding That The Assessee Has Discharged The Onus Of Proving The Identify & Creditworthiness Of The Share Subscribers & The Genuineness Of The Subscription.\"\N\N2. Ld. Counsel For The Assessee, At The Outset, Submitted That The Assessee Filed Petition Under Rule 27 Of Itat Rules As A Defense Plea To Support Ld. Cit(Appeals) Order On Legal & Jurisdictional Grounds Raised Before The Ld. Cit(Appeals) But Was Rejected Vide Para 3.

section 68 is rejected.\"\n\n7. The assessee filed petition under Rule 27 of ITAT Rules to support the Ld. CIT(Appeals) order on legal ground which was rejected by the Ld. CIT(Appeals) as stated above.\n\n8. We observed that whether the petition filed by the Assessee under Rule 27 of ITAT Rules supporting the order

DY. COMMISSIONER OF INCOME TAX, NOIDA vs. M/S RUDRA BUILDWELL HOMES PVT. LTD, DELHI

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2016-17 Vs. M/S. Rudra Buildwell Homes Dcit, Central Circle-I, Noida Pvt. Ltd., 53, Okhla Phase, Delhi Pan: Aafcr6959P (Appellant) (Respondent) With C.O. No.106/Del/2025 [Arising Out Of Ita No.602/Del/2025] Assessment Year: 2016-17 M/S. Rudra Buildwell Vs. Dcit, Central Circle-I, Homes Pvt. Ltd., Noida A-66, Sector-63, Noida Pan: Aafcr6959P (Appellant) (Respondent) Assessee By Sh. Rohit Kapoor, Adv. Sh. Veersen Agarwal, Itp Department By Sh. Rajesh Chandra, Cit(Dr) Date Of Hearing 12.08.2025 Date Of Pronouncement 29.08.2025 Order Per Satbeer Singh Godara, Jm This Revenue’S Appeal Ita No.602/Del/2025 & Assessee’S Cross Objection C.O. No. 106/Del/2025 For Assessment Year 2016-

reassessment proceedings to tax same under section 68 deserved to be quashed" Further, in the Judgment of Hon'ble High

ACIT CIRCLE-16(2), NEW DELHI vs. MAX VENTURES INVESTMENT HOLDINGS PVT. LTD., NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Shri N.K.Billaiya & Shri Kul Bharat[Assessment Year : 2010-11] Acit, Vs Max Venture Investment Holdings Circle-16(2), Pvt.Ltd., Max House, New Delhi. 1 Dr. Jha Marg, Okhla Phase-3, New Delhi-110020. Pan-Aaacd0213H Appellant Respondent Appellant By Ms. Sarita Kumari, Cit Dr Respondent By S/Shri Deepak Chopra, Adv., Rohan Khare, Adv. & Priyam Bhatnagar, Adv. Date Of Hearing 20.10.2022 Date Of Pronouncement 30.11.2022

reassessment proceedings were initiated under section 148 of the Act for the assessment year under consideration which ultimately culminated into an assessment order dated 10.04.2019 and the entire investment made by Mr. Analjit Singh was treated as cash credit under Section 68

DY COMMISSIONER OF INCOME TAX, NOIDA vs. M/S ALLURE DEVELOPERS PRIVATE LIMITED, DELHI

In the result, appeal of the Revenue in ITA No

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

reassessment proceedings to tax same under section 68 deserved to be quashed” On the above issue, the Hon'ble High

DY. COMMISSIONER OF INCOME TAX, NOIDA vs. STAR LANDCRAFT PRIVATE LIMITED, GHAZIABAD

In the result, appeal of the Revenue in ITA No

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

reassessment proceedings to tax same under section 68 deserved to be quashed” On the above issue, the Hon'ble High

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1 NOIDA, NOIDA vs. M/S ACE RESIDENCY PVT. LTD, GHAZIABAD

In the result, appeal of the Revenue in ITA No

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

reassessment proceedings to tax same under section 68 deserved to be quashed” On the above issue, the Hon'ble High

DY. COMMISSIONER OF INCOME TAX, NOIDA vs. STAR LANDCRAFT PRIVATE LIMITED, GHAZIABAD

In the result, appeal of the Revenue in ITA No

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

reassessment proceedings to tax same under section 68 deserved to be quashed” On the above issue, the Hon'ble High

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1 NOIDA, NOIA vs. M/S AJAY REALCON PVT. LTD., NOIDA

In the result, appeal of the Revenue in ITA No

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

reassessment proceedings to tax same under section 68 deserved to be quashed” On the above issue, the Hon'ble High

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1 NOIDA, NOIDA vs. M/S ALLURE DEVELOPERS PRIVATE LIMITED, NOIDA

In the result, appeal of the Revenue in ITA No

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

reassessment proceedings to tax same under section 68 deserved to be quashed” On the above issue, the Hon'ble High

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1 NOIDA, NOIDA vs. M/S ALLURE DEVELOPERS PVT. LTD, NEW DELHI

In the result, appeal of the Revenue in ITA No

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

reassessment proceedings to tax same under section 68 deserved to be quashed” On the above issue, the Hon'ble High

ACIT, CIRCLE-18(2), NEW DELHI vs. NIIT TECHNOLOGIES LTD., NEW DELHI

In the result, appeal of the Revenue in ITA No

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

reassessment proceedings to tax same under section 68 deserved to be quashed” On the above issue, the Hon'ble High

SEEMA GOEL,DELHI vs. CIT A, DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

section 148 notices issued on 21st & 20th July, 2022, case-wise respectively. This is for the precise reason that the department already appears to have conceded the very issue of limitation aspect in Union of India Vs Rajiv Bansal (2024) 469 ITR 46 (SC) that the provision of Taxation and Other Laws [Relaxation and Amendment of Certain Provisions

SEEMA GOEL,DELHI vs. CIT A, DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

section 148 notices issued on 21st & 20th July, 2022, case-wise respectively. This is for the precise reason that the department already appears to have conceded the very issue of limitation aspect in Union of India Vs Rajiv Bansal (2024) 469 ITR 46 (SC) that the provision of Taxation and Other Laws [Relaxation and Amendment of Certain Provisions

K K SPUN INDIA LIMITED,DELHI vs. DCIT, JHANDEWALAN DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

section 148 notices issued on 21st & 20th July, 2022, case-wise respectively. This is for the precise reason that the department already appears to have conceded the very issue of limitation aspect in Union of India Vs Rajiv Bansal (2024) 469 ITR 46 (SC) that the provision of Taxation and Other Laws [Relaxation and Amendment of Certain Provisions

K K SPUN INDIA LIMITED,DELHI vs. DCIT CENTRAL CIRCLE-2 NEW DELHI, JHANDEWALAN DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

section 148 notices issued on 21st & 20th July, 2022, case-wise respectively. This is for the precise reason that the department already appears to have conceded the very issue of limitation aspect in Union of India Vs Rajiv Bansal (2024) 469 ITR 46 (SC) that the provision of Taxation and Other Laws [Relaxation and Amendment of Certain Provisions

ACE MEGA STRUCTURES PRIVATE LIMITED,UTTAR PRADESH vs. DCIT/ACIT CEN CIR, NOIDA, NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

reassessment proceedings to tax same under section 68 deserved to be quashed” On the above issue, the Hon'ble High

DY. COMMISSIONER OF INCOME TAX, NOIDA vs. M/S ACE MEGA STRUCTURE PRIVATE LIMITED, NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

reassessment proceedings to tax same under section 68 deserved to be quashed” On the above issue, the Hon'ble High

ACIT, NEW DELHI vs. FILATEX INDIA LIMITED, DELHI

reassessment order deserves to be quashed.\n51.\nOn the other hand, Ld. Sr. DR for the Revenue supported the\norder of the lower authorities and stated that once the case is re-\nopened, the AO has jurisdiction to consider and decide all the issues\nwhich have come to his knowledge. He thus, requested for the\nconfirmation of the initiation