SUNITA GROVAR,PANIPAT, HARYANA vs. PRINCIPAL COMMISSIONER OF INCOME-TAX, ROHTA, ROHTAK HARYANA

In the result, appeal of the assessee is allowed

Bench: Shri Vimal Kumar & Smt. Renu Jauhriassessment Year: 2018-19 Sunita Grover, Vs. Principal Commissioner Of Income T-7, Industrial Area, Panipat, Tax, Rohtak Pin: 132 103 (Haryana) Haryana Pan: Afmpg8500N (Appellant) (Respondent)

69C read with Section 115BBE of the Act (taxing the income at 60%) with respect to the entire purchase amount of Rs.3,26,40,355. The Ld. PCIT passed the impugned order u/s. 263 on 10.03.2025, setting aside the final assessment order and directed the Ld. AO to pass a fresh order. The Ld. PCIT has alleged that

COMMISSIONER OF INCOME TAX-7 vs. RRJ SECURITIES LTD.

Bench: The Tribunal, Were Filed By The Revenue (Being

reassess the income of the Assessee under Section 153C in respect of AYs 2003-04 to 2008-09? 5. Briefly stated, the relevant facts necessary to address the issues involved in the above captioned matters are as under:- 2015:DHC:8989-DB ITA 164/2015 & Other Connected Matters Page 5 of 40 5.1 Search and seizure operations were undertaken under Section

COMMISSIONER OF INCOME TAX-7 vs. RRJ SECURITIES LTD

Bench: The Tribunal, Were Filed By The Revenue (Being

reassess the income of the Assessee under Section 153C in respect of AYs 2003-04 to 2008-09? 5. Briefly stated, the relevant facts necessary to address the issues involved in the above captioned matters are as under:- 2015:DHC:8986-DB ITA 164/2015 & Other Connected Matters Page 5 of 40 5.1 Search and seizure operations were undertaken under Section

COMMISSIONER OF INCOME TAX-7 vs. RRJ SECURITIES LTD

Bench: The Tribunal, Were Filed By The Revenue (Being

reassess the income of the Assessee under Section 153C in respect of AYs 2003-04 to 2008-09? 5. Briefly stated, the relevant facts necessary to address the issues involved in the above captioned matters are as under:- 2015:DHC:8989-DB ITA 164/2015 & Other Connected Matters Page 5 of 40 5.1 Search and seizure operations were undertaken under Section

COMMISSIONER OF INCOME TAX-7 vs. RRJ SECURITIES LTD.

Bench: The Tribunal, Were Filed By The Revenue (Being

reassess the income of the Assessee under Section 153C in respect of AYs 2003-04 to 2008-09? 5. Briefly stated, the relevant facts necessary to address the issues involved in the above captioned matters are as under:- 2015:DHC:8986-DB ITA 164/2015 & Other Connected Matters Page 5 of 40 5.1 Search and seizure operations were undertaken under Section

COMMISSIONER OF INCOME TAX-7 vs. RRJ SECURITIES LTD

Bench: The Tribunal, Were Filed By The Revenue (Being

reassess the income of the Assessee under Section 153C in respect of AYs 2003-04 to 2008-09? 5. Briefly stated, the relevant facts necessary to address the issues involved in the above captioned matters are as under:- 2015:DHC:8985-DB ITA 164/2015 & Other Connected Matters Page 5 of 40 5.1 Search and seizure operations were undertaken under Section

COMMISSIONER OF INCOME TAX-7 vs. RRJ SECURITIES LTD

Bench: The Tribunal, Were Filed By The Revenue (Being

reassess the income of the Assessee under Section 153C in respect of AYs 2003-04 to 2008-09? 5. Briefly stated, the relevant facts necessary to address the issues involved in the above captioned matters are as under:- 2015:DHC:8990-DB ITA 164/2015 & Other Connected Matters Page 5 of 40 5.1 Search and seizure operations were undertaken under Section

COMMISSIONER OF INCOME TAX-7 vs. RRJ SECURITIES LTD.

Bench: The Tribunal, Were Filed By The Revenue (Being

reassess the income of the Assessee under Section 153C in respect of AYs 2003-04 to 2008-09? 5. Briefly stated, the relevant facts necessary to address the issues involved in the above captioned matters are as under:- 2015:DHC:8990-DB ITA 164/2015 & Other Connected Matters Page 5 of 40 5.1 Search and seizure operations were undertaken under Section

COMMISSIONER OF INCOME TAX-7 vs. RRJ SECURITIES LTD.

Bench: The Tribunal, Were Filed By The Revenue (Being

reassess the income of the Assessee under Section 153C in respect of AYs 2003-04 to 2008-09? 5. Briefly stated, the relevant facts necessary to address the issues involved in the above captioned matters are as under:- 2015:DHC:8985-DB ITA 164/2015 & Other Connected Matters Page 5 of 40 5.1 Search and seizure operations were undertaken under Section

ANIL KUMAR JAIN,NEW DELHI vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-26, JHANDEWALAN, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

reassessment u/s 148 qua genuineness of unsecured loan as well as purchases disclosed, considered and accepted during the original assessment under Section 143(3) of the Income Tax Act, 1961 for AY 2013-14 2. On the facts and circumstances of the case, the impugned order dated 10th December 2024 passed by the CIT(A) as well as order dated

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

reassess the total income of such other person, (the assessee in this case)in the manner provided in section 153A of the Act. So in this case before us, since the AO of the searched person as well as that of the other/third party/assessee foundation are the same, he/AO of assessee can issue notice u/s 153C of the Act only

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

reassess the total income of such other person, (the assessee in this case)in the manner provided in section 153A of the Act. So in this case before us, since the AO of the searched person as well as that of the other/third party/assessee foundation are the same, he/AO of assessee can issue notice u/s 153C of the Act only

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

reassess the total income of such other person, (the assessee in this case)in the manner provided in section 153A of the Act. So in this case before us, since the AO of the searched person as well as that of the other/third party/assessee foundation are the same, he/AO of assessee can issue notice u/s 153C of the Act only

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

reassess the total income of such other person, (the assessee in this case)in the manner provided in section 153A of the Act. So in this case before us, since the AO of the searched person as well as that of the other/third party/assessee foundation are the same, he/AO of assessee can issue notice u/s 153C of the Act only

PRAKHAR DALMIA,NEW DELHI vs. ACIT CIRCLE-34(1), NEW DELHI

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

Bench: Us & Prayed That Additional

69C of the Act, based on conjecture and surmises and without any evidence on record to substantiate the same.” 3. Further, assessee has filed a petition for admission of additional grounds of appeal before us and prayed that additional grounds may be admitted for adjudication and reliance was placed on the decision of Hon’ble Supreme Court in the case

JINDAL POLYBUTTONS PVT LTD,DELHI vs. PR CIT, ROHTAK

In the result, both the assessee's appeals stand allowed

Bench: Shri Shamim Yahya & Shri Sudhir Pareek

69C of the Act. Thus, AO has failed to bring to tax an amount of Rs.13,81,276/- (2117597-736321). 3. The Ld. PCIT observed that as per the provisions of Section 263, if an order is passed without proper enquiry it will be held as erroneous. He further observed that as the assessment order under Section 147 read with

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 initiated under section 148, which is void ab initio, as the Assessing Officer failed to record proper satisfaction and obtain mandatory prior approval of the Principal Commissioner under Explanation 2(iv) to section 148, before relying on a third-party excel sheet seized under section 132 from Mis Gaursons H-toch Promoters. 4. That the Ld. CIT(A) erred

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 initiated under section 148, which is void ab initio, as the Assessing Officer failed to record proper satisfaction and obtain mandatory prior approval of the Principal Commissioner under Explanation 2(iv) to section 148, before relying on a third-party excel sheet seized under section 132 from Mis Gaursons H-toch Promoters. 4. That the Ld. CIT(A) erred