ITO WARD - 23(3), NEW DELHI vs. SHREE BHAWANI POWER PROJECTS PVT LTD, NEW DELHI

In the result, both the appeals filed by the Revenue Department stands dismissed

Bench: Shri Anil Chaturvedi & Shri N.K. Choudhry

80-1B." In this case Hon'ble Supreme Court dismissed the appeal of Revenue and confirmed the view taken by Madras High Court in case of CIT v. AKS Alloys (P.) Ltd. [2012] 18 taxmann.com 25 (Mad.) holding above. The facts of the case of the appellant are pari-materia with the facts in the above case. The only

M/S. INDIA EXPOSITION MART LTD.,NEW DELHI vs. DCIT, NEW DELHI

reassessment cannot be initiated solely on the basis of an audit objection amounting to a change of opinion.", "result": "Allowed", "sections": [ "147", "148", "143(3)", "37(1)", "153(2)", "271(1)(c)", "80

SEEMA GOEL,DELHI vs. CIT A, DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

80,000/- were made in the hands of the assessee by treating the long terms capital gains as unexplained. Against the said order an appeal was filed before the Ld. CIT(A) who dismissed the appeal of the assessee. 4. Aggrieved by the said order, assessee is in appeal before the Tribunal wherein the assessee has taken following grounds

SEEMA GOEL,DELHI vs. CIT A, DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

80,000/- were made in the hands of the assessee by treating the long terms capital gains as unexplained. Against the said order an appeal was filed before the Ld. CIT(A) who dismissed the appeal of the assessee. 4. Aggrieved by the said order, assessee is in appeal before the Tribunal wherein the assessee has taken following grounds

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

80,000/- were made in the hands of the assessee by treating the long terms capital gains as unexplained. Against the said order an appeal was filed before the Ld. CIT(A) who dismissed the appeal of the assessee. 4. Aggrieved by the said order, assessee is in appeal before the Tribunal wherein the assessee has taken following grounds

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

80,000/- were made in the hands of the assessee by treating the long terms capital gains as unexplained. Against the said order an appeal was filed before the Ld. CIT(A) who dismissed the appeal of the assessee. 4. Aggrieved by the said order, assessee is in appeal before the Tribunal wherein the assessee has taken following grounds

RAKESH KUMAR GUPTA,DELHI vs. LD. ITO, WARD 35(1), DELHI, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2021-22] Rakesh Kumar Gupta, Income Tax Officer, Ward-35(1), B-2/38, Ground Floor, E-2, Civic Centre, Delhi-110002 Ashok Vihar, Phase-Ii, Vs Delhi-110052 Pan-Aafhr8657H Appellant Respondent

reassessment, referred to in clause (a) of subsection (1), in a case where an order under sub- section (4) has been made accepting the application." 22. As is evident from a reading of Section 270A(1), a person would be liable to be considered to have under reported its income if the contingencies spoken of in clauses

MAHESH KUMAR,DELHI vs. ITO,WARD-68(6), DELHI

In the result, Ground no. 3 as raised by the assessee deserves to be allowed and the impugned addition cannot be sustained

Bench: Justice (Retd.) C.V. Bhadang(), Shri Mahavir Singh & Shri Brajesh Kumar Singh[Assessment Year: 2012-13] Mahesh Kumar, Vs Ito, 6/305/1A, Doonger Ward-68(6), Mohalla, Delhi-110032. Delhi. Pan-Aoopk6335A Appellant Respondent Appellant By Shri Neeraj Mangla, Ca Respondent By Shri Krishna K. Ramawat, Sr. Dr Date Of Hearing 06.08.2025 Date Of Pronouncement 06.08.2025

Section 80 HH and 80-I as well. 21. In view of our above discussions, the Tribunal was right in holding that the Assessing Officer had the jurisdiction to reassess

INCOME TAX OFFICER, WARD 3(1), DELHI, DELHI vs. ARTISTIC FINANCE PRIVATE LIMITED, DELHI

In the result, Ground no. 3 as raised by the assessee deserves to be allowed and the impugned addition cannot be sustained

Bench: Justice (Retd.) C.V. Bhadang(), Shri Mahavir Singh & Shri Brajesh Kumar Singh[Assessment Year: 2012-13] Mahesh Kumar, Vs Ito, 6/305/1A, Doonger Ward-68(6), Mohalla, Delhi-110032. Delhi. Pan-Aoopk6335A Appellant Respondent Appellant By Shri Neeraj Mangla, Ca Respondent By Shri Krishna K. Ramawat, Sr. Dr Date Of Hearing 06.08.2025 Date Of Pronouncement 06.08.2025

Section 80 HH and 80-I as well. 21. In view of our above discussions, the Tribunal was right in holding that the Assessing Officer had the jurisdiction to reassess

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 total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

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 total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

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 total income of 6 assessment years immediately preceding the assessment year relating to the previous year that search was conducted/requisition made. 77. The ingredients of Section 153 C are: (i) Satisfaction of the Assessing Officer who is Assessing Officer of the section 153A noticee that money/bullion/jewellery/other valuable article or thing/books of account or documents (incriminating materials) seized/requisitioned belongs to/pertain

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

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

80. Notice under Section 153C would have to be issued only upon confront satisfaction of both conditions as aforesaid. To this extent, there is, in my Section 153A and 153C. The contention of the revenue that a mandate is cast upon the Assessing Officer of the third party to issue notice under Section 153C for all the years comprising

SAKSHI AGARWAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28, NEW DELHI

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

80. Notice under Section 153C would have to be issued only upon confront satisfaction of both conditions as aforesaid. To this extent, there is, in my Section 153A and 153C. The contention of the revenue that a mandate is cast upon the Assessing Officer of the third party to issue notice under Section 153C for all the years comprising

SAKSHI AGARWAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28, DELHI

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

80. Notice under Section 153C would have to be issued only upon confront satisfaction of both conditions as aforesaid. To this extent, there is, in my Section 153A and 153C. The contention of the revenue that a mandate is cast upon the Assessing Officer of the third party to issue notice under Section 153C for all the years comprising

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

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

80. Notice under Section 153C would have to be issued only upon confront satisfaction of both conditions as aforesaid. To this extent, there is, in my Section 153A and 153C. The contention of the revenue that a mandate is cast upon the Assessing Officer of the third party to issue notice under Section 153C for all the years comprising

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

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

80. Notice under Section 153C would have to be issued only upon confront satisfaction of both conditions as aforesaid. To this extent, there is, in my Section 153A and 153C. The contention of the revenue that a mandate is cast upon the Assessing Officer of the third party to issue notice under Section 153C for all the years comprising

SAKSHI AGARWAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE- 28, NEW DELHI

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

80. Notice under Section 153C would have to be issued only upon confront satisfaction of both conditions as aforesaid. To this extent, there is, in my Section 153A and 153C. The contention of the revenue that a mandate is cast upon the Assessing Officer of the third party to issue notice under Section 153C for all the years comprising