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

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 Page 1 of 53 5767/Del/2015 for assessment year 2007 – 08 and ITA number 6346/Del/2014 for A Y 2010-11. Ld AO filed ITA number 6726/Del/2014

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

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 Page 1 of 53 5767/Del/2015 for assessment year 2007 – 08 and ITA number 6346/Del/2014 for A Y 2010-11. Ld AO filed ITA number 6726/Del/2014

SEEMA GOEL,DELHI vs. CIT A, DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

1)(c) be quashed.  Any other relief deemed fit by the Hon’ble Tribunal be granted. 15. Thereafter, the assessee has also taken additional grounds of appeal, wherein assessee has challenged the reassessment proceedings initiated by 11 IT Nos.2005 & 2006/Del/2025 Seema Goel vs. CIT(A) issue of notice u/s 148 passed order u/s 148A(d) of the Act without following

SEEMA GOEL,DELHI vs. CIT A, DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

1)(c) be quashed.  Any other relief deemed fit by the Hon’ble Tribunal be granted. 15. Thereafter, the assessee has also taken additional grounds of appeal, wherein assessee has challenged the reassessment proceedings initiated by 11 IT Nos.2005 & 2006/Del/2025 Seema Goel vs. CIT(A) issue of notice u/s 148 passed order u/s 148A(d) of the Act without following

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

1)(c) be quashed.  Any other relief deemed fit by the Hon’ble Tribunal be granted. 15. Thereafter, the assessee has also taken additional grounds of appeal, wherein assessee has challenged the reassessment proceedings initiated by 11 IT Nos.2005 & 2006/Del/2025 Seema Goel vs. CIT(A) issue of notice u/s 148 passed order u/s 148A(d) of the Act without following

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

1)(c) be quashed.  Any other relief deemed fit by the Hon’ble Tribunal be granted. 15. Thereafter, the assessee has also taken additional grounds of appeal, wherein assessee has challenged the reassessment proceedings initiated by 11 IT Nos.2005 & 2006/Del/2025 Seema Goel vs. CIT(A) issue of notice u/s 148 passed order u/s 148A(d) of the Act without following

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

In the result, all the appeals for Assessment Years 2013-14 to 2022-23 in ITA

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 4153 & 4008/Del/2025 (Assessment Year: 2012-13 & 2018-19) Dcit, Proform Interiors Pvt. Ltd., Central Circle-20, Ground Floor, Jmd Regent Room No. 269A, 2Nd Floor, Vs. Plaza, Mg Road, Gurgaon, Ara Centre, Jhandewalan Haryana-122001. Extn., Delhi-110055. Pan-Aahcs5999J

D E R PER MANISH AGARWAL, AM: The captioned appeals are filed by Assessee and Revenue against the separate orders, all are dated 28.02.2025 passed by Ld. Commissioner of Income Tax (Appeals)-30, New Delhi [‘Ld. CIT(A)’ in short] u/s 250 of the Income Tax Act, ITA Nos.4153,4008, 2708 to 2717/Del/2025 1961 [‘the Act’] arising out of Assessment

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

11 let 1961 from the concerned person, hence remains unexplained and added back to the income of the assessee u/s 68 of the IT Act 1901. Penalty proceedings u/s 271(1)(e) are being initiated separately for furnishing inaccurate particulars and thereby concealment of income. 12. Further detailed analysis of evidences available on record i.e. bank statements and statement

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

11 let 1961 from the concerned person, hence remains unexplained and added back to the income of the assessee u/s 68 of the IT Act 1901. Penalty proceedings u/s 271(1)(e) are being initiated separately for furnishing inaccurate particulars and thereby concealment of income. 12. Further detailed analysis of evidences available on record i.e. bank statements and statement

SMT. CHAYA SINHA,NEW DELHI vs. ACIT, FARIDABAD

In the result the appeal of the assessee is allowed

Bench: Shria.T.Varkey & Shri Prashant Maharishi

D E R PER PRASHANT MAHARISHI, A. M. 1. This appeal is preferred by the assessee for the Assessment Year 2006-07 against the order of learned Commissioner of Income- tax (Appeals)-18.03.2013 for the Assessment Year 2006-07, wherein there are six effective grounds of appeal have been raised as under:- “1. That having regard to the facts

COMMISSIONER OF INCOME TAX, DELHI VIII vs. INDIAN FARMERS FERTILIZERS CO-OP. LTD.

The appeal stands disposed of accordingly

reassessment proceeding initiated by the Assessing Officer u/s 147 R/W Section 148 of the Act was without jurisdiction?” 3. In order to appreciate the legal and factual points at issue in the present appeal, the facts attending this matter need to be marshalled at the outset. The respondent is a cooperative society manufacturing fertilizers. During the assessment year

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

147 read with section 148 of the Act, which was\napplicable to searches conducted after 01.04.2021. In view of the same, a notice\nunder section 148 for the year under consideration was issued on 20.01.2023 for\n assessment year 2012-13. The AO computed limitation for issuing notices under\nsection 148 for the aforesaid assessment year

THE COMMISSIONER OF INCOME TAX-V vs. ORIENT CRAFT LTD

u/s 80HHC of the Income Tax Act, 1961. In 2012:DHC:7425-DB ITA No.555/2012 Page 5 of 14 view of these facts there is reason of believe that the income chargeable to tax has escaped assessment.” We think that the point taken on behalf of the assessee that even an assessment made under Section 143(1

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

147 and for the remaining two\nyears i.e., Assessment Years 2021-22 and 2022-23 assessment orders were passed\nu/s 143(3) of the Act. By Finance Act 2021, section 148 has been amended and as\nper the new section limitation were provided in section 149 where section 149(1) (b)\nfirst proviso provided as under:\n“Provided that

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

u/s 270A dated 16.06.2023 imposing penalty of Rs.19,21,517/-. 5. We have heard rival submissions in the light of material available on records. At this stage, we deem it necessary to reproduce the statutory provisions of section 270A of the Act “270A. (1) The Assessing Officer or 94[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the Principal

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

147 and for the remaining two\nyears i.e., Assessment Years 2021-22 and 2022-23 assessment orders were passed\nu/s 143(3) of the Act. By Finance Act 2021, section 148 has been amended and as\nper the new section limitation were provided in section 149 where section 149(1) (b)\nfirst proviso provided as under:\n“Provided that

DCIT, NEW DELHI vs. M/S. DHARAMPAL SATYAPAL LTD., DELHI

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

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

D E R PER A.T. VARKEY, JUDICIAL MEMBER : These are cross appeals filed by the revenue and the assessee against the order of the Commissioner of Income-tax (Appeals)-XXXIII, New Delhi dated 24.06.2013 for the assessment year 2004-05. 2. From the assessment order, we find that the assessee company had filed return declaring NIL income

M/S. DHARAMPAL SATYAPAL LTD.,NEW DELHI vs. DCIT, NEW DELHI

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

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

D E R PER A.T. VARKEY, JUDICIAL MEMBER : These are cross appeals filed by the revenue and the assessee against the order of the Commissioner of Income-tax (Appeals)-XXXIII, New Delhi dated 24.06.2013 for the assessment year 2004-05. 2. From the assessment order, we find that the assessee company had filed return declaring NIL income

ACIT, CC-30, NEW DELHI vs. AMARJYOTI VANIJYA PVT. LTD., NEW DELHI

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

1) of section 153A shall be construed as reference to the date of receiving the books of account or documents or assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person: 32 I.T.As. No. 4046, 4047 & 4048/DEL/2017 8. By virtue of second proviso to Section 153A, the assessment/reassessment pending on the date of initiation of search