DEPUTY COMMISSIONER OF INCOME TAX, NEW DELHI vs. KUNDAN RICE MILLS LIMITED, HARYANA

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

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2013-14 Dcit, Vs. Kundan Rice Mills Ltd., Central Circle 14, E-4, Industrial Area, New Delhi Panipat, Haryana Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent) Assessment Year: 2013-14 Kundan Rice Mills Ltd., Vs. Dcit, E-4, Industrial Area, Central Circle 14, Panipat, Haryana New Delhi Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent) Assessment Year: 2014-15 Dcit, Vs. Kundan Rice Mills Ltd., Central Circle 14, E-4, Industrial Area, New Delhi Panipat, Haryana Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent)

reassessment proceeding and issuing notice u/s 148 of the Act. 2 That the order dated 08.02.2024 passed-u/s 250 of the Act by the Commissioner of Income Tax (Appeals)-26, New Delhi is against law and facts on the file in as much as he was not justified to partly uphold the action of the Ld Assessing Officer

DEPUTY COMMISSIONER OF INCOME TAX, NEW DELHI vs. KUNDAN RICE MILLS LIMITED, HARYANA

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

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2013-14 Dcit, Vs. Kundan Rice Mills Ltd., Central Circle 14, E-4, Industrial Area, New Delhi Panipat, Haryana Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent) Assessment Year: 2013-14 Kundan Rice Mills Ltd., Vs. Dcit, E-4, Industrial Area, Central Circle 14, Panipat, Haryana New Delhi Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent) Assessment Year: 2014-15 Dcit, Vs. Kundan Rice Mills Ltd., Central Circle 14, E-4, Industrial Area, New Delhi Panipat, Haryana Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent)

reassessment proceeding and issuing notice u/s 148 of the Act. 2 That the order dated 08.02.2024 passed-u/s 250 of the Act by the Commissioner of Income Tax (Appeals)-26, New Delhi is against law and facts on the file in as much as he was not justified to partly uphold the action of the Ld Assessing Officer

KUNDAN RICE MILLS LIMITED,NEW DELHI vs. DEPUTY COMMISIONER OF INCOME TAX, CENTRAL CIRCLE-14, NEW DELHI

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

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2013-14 Dcit, Vs. Kundan Rice Mills Ltd., Central Circle 14, E-4, Industrial Area, New Delhi Panipat, Haryana Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent) Assessment Year: 2013-14 Kundan Rice Mills Ltd., Vs. Dcit, E-4, Industrial Area, Central Circle 14, Panipat, Haryana New Delhi Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent) Assessment Year: 2014-15 Dcit, Vs. Kundan Rice Mills Ltd., Central Circle 14, E-4, Industrial Area, New Delhi Panipat, Haryana Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent)

reassessment proceeding and issuing notice u/s 148 of the Act. 2 That the order dated 08.02.2024 passed-u/s 250 of the Act by the Commissioner of Income Tax (Appeals)-26, New Delhi is against law and facts on the file in as much as he was not justified to partly uphold the action of the Ld Assessing Officer

KAJAL BATRA,DELHI vs. ACIT,CIRCLE-52(1), DELHI

In the result, the appeal of the assessee stands dismissed as above

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Avdhesh Kumar Mishra

147 of the Act. There is no approval u/s 151 by the competent authority nor such approval was made available to the assessee. Even if there is one, it 1 Kajal Batra appears to be granted mechanically without application of mind and after the reasons were recorded. 3. The CIT(A) has erred in not appreciating that the final order

ARVIND KUMAR PROP. M/S SHREE BALAJI TRADING CO.,PANIPAT vs. ADDL/JT/ASST COMMISSIONER OF INCOME TAX/INCOME TAX OFFICER, NFAC, DELHI, DELHI

In the result, the appeal of the assessee is partly allowed for statistical\npurposes as indicated above

147 to 151 as envisaged under the\nIncome Tax Act, 1961 and without obtaining valid approval/\nsanction u/s 151 as per law.\n\n2. That in any case and in any view of the matter, action of Ld.\nCIT (A) in not quashing the impugned reassessment order passed\nby Ld. AO u/s 147/144B, is bad in law and against

NEHA JEWELLERS PVT. LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-6, NEW DELHI

In the result, the appeal of the assessee is allowed and the appeal of the Revenue is dismissed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

147 of the Act, bad in law and are contrary to the facts. 4. On the facts and circumstances of the case, learned CIT(A) has erred both on facts and in law in confirming the reopening ignoring the fact that there is no live nexus between the reasons recorded and the belief formed by the assessing officer

NEHA JEWELLERS PVT. LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-6, NEW DELHI

In the result, the appeal of the assessee is allowed and the appeal of the Revenue is dismissed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

147 of the Act, bad in law and are contrary to the facts. 4. On the facts and circumstances of the case, learned CIT(A) has erred both on facts and in law in confirming the reopening ignoring the fact that there is no live nexus between the reasons recorded and the belief formed by the assessing officer

ACIT CENTRAL CIRCLE-14, NEW DELHI vs. NEHA JEWELLERS PVT. LTD., NEW DELHI

In the result, the appeal of the assessee is allowed and the appeal of the Revenue is dismissed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

147 of the Act, bad in law and are contrary to the facts. 4. On the facts and circumstances of the case, learned CIT(A) has erred both on facts and in law in confirming the reopening ignoring the fact that there is no live nexus between the reasons recorded and the belief formed by the assessing officer

ACIT CENTRAL CIRCLE-14, NEW DELHI vs. NEHA JEWELLERS PVT. LTD., NEW DELHI

In the result, the appeal of the assessee is allowed and the appeal of the Revenue is dismissed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

147 of the Act, bad in law and are contrary to the facts. 4. On the facts and circumstances of the case, learned CIT(A) has erred both on facts and in law in confirming the reopening ignoring the fact that there is no live nexus between the reasons recorded and the belief formed by the assessing officer

ACIT, CENTRAL CIRCLE-14, NEW DELHI vs. NEHA JEWELLERS PVT. LTD., DELHI

In the result, the appeal of the assessee is allowed and the appeal of the Revenue is dismissed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

147 of the Act, bad in law and are contrary to the facts. 4. On the facts and circumstances of the case, learned CIT(A) has erred both on facts and in law in confirming the reopening ignoring the fact that there is no live nexus between the reasons recorded and the belief formed by the assessing officer

NEHA JEWELLERS PVT. LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-6, NEW DELHI

In the result, the appeal of the assessee is allowed and the appeal of the Revenue is dismissed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

147 of the Act, bad in law and are contrary to the facts. 4. On the facts and circumstances of the case, learned CIT(A) has erred both on facts and in law in confirming the reopening ignoring the fact that there is no live nexus between the reasons recorded and the belief formed by the assessing officer

NEHA JEWELLERS PVT. LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-6, NEW DELHI

In the result, the appeal of the assessee is allowed and the appeal of the Revenue is dismissed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

147 of the Act, bad in law and are contrary to the facts. 4. On the facts and circumstances of the case, learned CIT(A) has erred both on facts and in law in confirming the reopening ignoring the fact that there is no live nexus between the reasons recorded and the belief formed by the assessing officer

NEHA JEWELLERS PVT. LTD.,NEW DELHI vs. ACIT, CC-14, NEW DELHI

In the result, the appeal of the assessee is allowed and the appeal of the Revenue is dismissed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

147 of the Act, bad in law and are contrary to the facts. 4. On the facts and circumstances of the case, learned CIT(A) has erred both on facts and in law in confirming the reopening ignoring the fact that there is no live nexus between the reasons recorded and the belief formed by the assessing officer

DCIT CENTRAL CIRCLE 29, NEW DELHI vs. B.R. GOEL & SONS, NEW DELHI

In the result, both the appeals of the revenue are dismissed and both the Cross Objections of the assessee are dismissed as infructuous

Bench: Shri C. N. Prasad & Shri M. Balaganesh

reassessment proceedings clarified to AO that torn currency notes were deposited with normal currency notes while providing date wise details of cash withdrawn and cash deposited in the bank account. The learned counsel further submitted that the assessee used to withdraw cash out of its bank account and used to deposit the cash in its bank accounts from time

DCIT,CENTRAL CIRCLE-29, NEW DELHI vs. B.R. GOEL & SONS, DELHI

In the result, both the appeals of the revenue are dismissed and both the Cross Objections of the assessee are dismissed as infructuous

Bench: Shri C. N. Prasad & Shri M. Balaganesh

reassessment proceedings clarified to AO that torn currency notes were deposited with normal currency notes while providing date wise details of cash withdrawn and cash deposited in the bank account. The learned counsel further submitted that the assessee used to withdraw cash out of its bank account and used to deposit the cash in its bank accounts from time

DCIT, CIRCLE- 19(1), DELHI vs. R. GOPAL IMPEX PVT.LTD., DELHI

In the result, the appeal of the Assessee as well as the Revenue

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

147 of the Income Tax Act, 1961 ('Act' for short) alleging that assessee has deposited cash of Rs. 1,34,88,000/- in his bank account during the demonetization period. During the course of reassessment proceedings, assessee submitted the details explaining the source of cash in Specified Bank Notes (SBN) deposits. The NFAC also asked the assessee to explain

R. GOPAL IMPEX PVT LTD,DELHI vs. ACIT CIRCLE - 19(1), DELHI

In the result, the appeal of the Assessee as well as the Revenue

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

147 of the Income Tax Act, 1961 ('Act' for short) alleging that assessee has deposited cash of Rs. 1,34,88,000/- in his bank account during the demonetization period. During the course of reassessment proceedings, assessee submitted the details explaining the source of cash in Specified Bank Notes (SBN) deposits. The NFAC also asked the assessee to explain

ACIT, CC-29, NEW DELHI vs. SUBHASH CHNAD GUPTA, DELHI

Accordingly, the grounds raised by the Revenue are dismissed

Bench: Shri M. Balaganesh & Shri Sudhir Kumarsubhash Chand Gupta Vs. Acit, B-41, Kailash Colony, Central Circle – 29, New Delhi – 110 054 New Delhi Pan: Aaapg 2554 K (Appellant) (Respondent) & Acit, Vs. Subhash Chand Gupta Central Circle – 29, 43/1M Rajpur Road, New Delhi Civil Lines, North Delhi, New Delhi – 110 054 Pan: Aaapg 2554 K (Appellant) (Respondent) Assessee By : Shri Sankalp Malik, Adv. Revenue By: Shri V. K. Dubey, Sr. D.R. Date Of Hearing 14/10/2024 Date Of Pronouncement 18/10/2024 O R D E R Per M. Balaganesh, A. M.: The Appeals In Ita Nos. 2529/Del/2022 & Ita 1. No.1557/Del/2021 For Ays 2015-16 & 2017-18, Arises Out Of The Order Of The Commissioner Of Income Tax (Appeals)-30, New

u/s 147/148 of the Income Tax Act, 1961. In response to which assessee has failed to furnish satisfactory reply. 3. Therefore, on the facts and case as stated above, I have reason to believe that income of Rs.35,01,600/- has escaped assessment. Therefore, I propose to reasons the aforesaid income chargeable to tax which has escaped assessment. (Vijay Singh

SUBHASH CHAND GUPTA,NEW DELHI vs. ACIT, CENTRAL CIRCLE-29, NEW DELHI

Accordingly, the grounds raised by the Revenue are dismissed

Bench: Shri M. Balaganesh & Shri Sudhir Kumarsubhash Chand Gupta Vs. Acit, B-41, Kailash Colony, Central Circle – 29, New Delhi – 110 054 New Delhi Pan: Aaapg 2554 K (Appellant) (Respondent) & Acit, Vs. Subhash Chand Gupta Central Circle – 29, 43/1M Rajpur Road, New Delhi Civil Lines, North Delhi, New Delhi – 110 054 Pan: Aaapg 2554 K (Appellant) (Respondent) Assessee By : Shri Sankalp Malik, Adv. Revenue By: Shri V. K. Dubey, Sr. D.R. Date Of Hearing 14/10/2024 Date Of Pronouncement 18/10/2024 O R D E R Per M. Balaganesh, A. M.: The Appeals In Ita Nos. 2529/Del/2022 & Ita 1. No.1557/Del/2021 For Ays 2015-16 & 2017-18, Arises Out Of The Order Of The Commissioner Of Income Tax (Appeals)-30, New

u/s 147/148 of the Income Tax Act, 1961. In response to which assessee has failed to furnish satisfactory reply. 3. Therefore, on the facts and case as stated above, I have reason to believe that income of Rs.35,01,600/- has escaped assessment. Therefore, I propose to reasons the aforesaid income chargeable to tax which has escaped assessment. (Vijay Singh