DCIT, HISAR vs. TAYAL SONS PVT. LTD., HISAR

The Appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalita No. 3323/Del/2025 (A.Y. 2019-20) Tayal Sons Private Vs Dcit Limited Income Tax Office, Sesctor14, 653A, Kath Mandi Road, Hisar, Hisar, Haryana Pan: Aabct6693E Appellant Respondent Ita No. 3467/Del/2025 (A.Y. 2019-20) Dcit Vs Tayal Sons Private Limited Income Tax Office, 653A, Kath Mandi Road, Hisar, Sesctor14, Hisar, Haryana. Pan: Aabct6693E Appellant Respondent Assessee By Sh. Sh. Salil Kapoor, Adv, Ms. Ananya Kapoor, Adv, Ms. Ishitafarsiya, Adv, Ms. Soumya Singh, Adv& Ms. Sakshirustagi. Revenue By Ms. Amisha S. Gupt, Cit (Dr) Date Of Hearing 27/11/2025 Date Of Pronouncement 28/11/2025 Order Per Yogesh Kumar, U.S. Jm: The Captioned Two Appeals Are Filed By The Assessee & Two

147 of the Act, (b) issuance of notice under section 148 of the Act, shall be through automated allocation, in accordance with risk management strategy formulated by the Board as referred to in section 148 of the Act for issuance of notice, and in a faceless manner, to the extent provided in section 144B of the Act with reference

DY. COMMISSIONER OF INCOME TAX, HISAR vs. M/S. TAYAL SONS PVT. LTD., HISAR

The Appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalita No. 3323/Del/2025 (A.Y. 2019-20) Tayal Sons Private Vs Dcit Limited Income Tax Office, Sesctor14, 653A, Kath Mandi Road, Hisar, Hisar, Haryana Pan: Aabct6693E Appellant Respondent Ita No. 3467/Del/2025 (A.Y. 2019-20) Dcit Vs Tayal Sons Private Limited Income Tax Office, 653A, Kath Mandi Road, Hisar, Sesctor14, Hisar, Haryana. Pan: Aabct6693E Appellant Respondent Assessee By Sh. Sh. Salil Kapoor, Adv, Ms. Ananya Kapoor, Adv, Ms. Ishitafarsiya, Adv, Ms. Soumya Singh, Adv& Ms. Sakshirustagi. Revenue By Ms. Amisha S. Gupt, Cit (Dr) Date Of Hearing 27/11/2025 Date Of Pronouncement 28/11/2025 Order Per Yogesh Kumar, U.S. Jm: The Captioned Two Appeals Are Filed By The Assessee & Two

147 of the Act, (b) issuance of notice under section 148 of the Act, shall be through automated allocation, in accordance with risk management strategy formulated by the Board as referred to in section 148 of the Act for issuance of notice, and in a faceless manner, to the extent provided in section 144B of the Act with reference

TAYAL SONS PRIVATE LIMITED,HISAR vs. DCIT, HISAR

The Appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalita No. 3323/Del/2025 (A.Y. 2019-20) Tayal Sons Private Vs Dcit Limited Income Tax Office, Sesctor14, 653A, Kath Mandi Road, Hisar, Hisar, Haryana Pan: Aabct6693E Appellant Respondent Ita No. 3467/Del/2025 (A.Y. 2019-20) Dcit Vs Tayal Sons Private Limited Income Tax Office, 653A, Kath Mandi Road, Hisar, Sesctor14, Hisar, Haryana. Pan: Aabct6693E Appellant Respondent Assessee By Sh. Sh. Salil Kapoor, Adv, Ms. Ananya Kapoor, Adv, Ms. Ishitafarsiya, Adv, Ms. Soumya Singh, Adv& Ms. Sakshirustagi. Revenue By Ms. Amisha S. Gupt, Cit (Dr) Date Of Hearing 27/11/2025 Date Of Pronouncement 28/11/2025 Order Per Yogesh Kumar, U.S. Jm: The Captioned Two Appeals Are Filed By The Assessee & Two

147 of the Act, (b) issuance of notice under section 148 of the Act, shall be through automated allocation, in accordance with risk management strategy formulated by the Board as referred to in section 148 of the Act for issuance of notice, and in a faceless manner, to the extent provided in section 144B of the Act with reference

TAYAL SONS PRIVATE LIMITED,HISAR vs. DCIT, HISAR

The Appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalita No. 3323/Del/2025 (A.Y. 2019-20) Tayal Sons Private Vs Dcit Limited Income Tax Office, Sesctor14, 653A, Kath Mandi Road, Hisar, Hisar, Haryana Pan: Aabct6693E Appellant Respondent Ita No. 3467/Del/2025 (A.Y. 2019-20) Dcit Vs Tayal Sons Private Limited Income Tax Office, 653A, Kath Mandi Road, Hisar, Sesctor14, Hisar, Haryana. Pan: Aabct6693E Appellant Respondent Assessee By Sh. Sh. Salil Kapoor, Adv, Ms. Ananya Kapoor, Adv, Ms. Ishitafarsiya, Adv, Ms. Soumya Singh, Adv& Ms. Sakshirustagi. Revenue By Ms. Amisha S. Gupt, Cit (Dr) Date Of Hearing 27/11/2025 Date Of Pronouncement 28/11/2025 Order Per Yogesh Kumar, U.S. Jm: The Captioned Two Appeals Are Filed By The Assessee & Two

147 of the Act, (b) issuance of notice under section 148 of the Act, shall be through automated allocation, in accordance with risk management strategy formulated by the Board as referred to in section 148 of the Act for issuance of notice, and in a faceless manner, to the extent provided in section 144B of the Act with reference

SEEMA GOEL,DELHI vs. CIT A, DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

147 r.w.s. 144B of the Act wherein addition of Rs.59,18,00,000/- was made in the hands of the assessee by treating the long terms capital gains as unexplained money u/s 69A on protective basis and further addition of Rs. 1,54,00,000/- is made by holding the same as short terms capital gains from sale of properties

SEEMA GOEL,DELHI vs. CIT A, DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

147 r.w.s. 144B of the Act wherein addition of Rs.59,18,00,000/- was made in the hands of the assessee by treating the long terms capital gains as unexplained money u/s 69A on protective basis and further addition of Rs. 1,54,00,000/- is made by holding the same as short terms capital gains from sale of properties

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

147 r.w.s. 144B of the Act wherein addition of Rs.59,18,00,000/- was made in the hands of the assessee by treating the long terms capital gains as unexplained money u/s 69A on protective basis and further addition of Rs. 1,54,00,000/- is made by holding the same as short terms capital gains from sale of properties

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

147 r.w.s. 144B of the Act wherein addition of Rs.59,18,00,000/- was made in the hands of the assessee by treating the long terms capital gains as unexplained money u/s 69A on protective basis and further addition of Rs. 1,54,00,000/- is made by holding the same as short terms capital gains from sale of properties

EBRO INDIA PVT.LTD. ,DELHI vs. ACIT CIRCLE-7(1), DELHI

In the result, the ground no 4 raised by the assessee is allowed

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

section 1448 of IT Act, the case was duly transferred to the jurisdiction AO, who has no previous idea about the assessment proceedings in the case. However it is pointed out, that, even during the DRP stage and even after providing opportunity by AO, the assessee could not submit any evidence with respect to bank statement of assessee and also

CHAMPION BUILDER PVT. LTD.,KOLKATA vs. ITO,WARD-1(3), GURGAON

In the result, both the appeals of the assessee are partly

Bench: Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A Nos.462 & 463/Del/2024 िनधा"रणवष"/Assessment Years: 2015-16 & 2016-17

reassessment made u/s 144B read with section 147 of the Act for the AY 2015-16 on the basis of such

SUNITA SAINI,HARYANA vs. INCOME TAX OFFICER, WARD 1(4), FARIDABAD, HARYANA

In the result, appeal of the Assessee is allowed

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A No.1877/Del/2024 िनधा"रणवष"/Assessment Year:2016-17 बनाम Sunita Saini, Income Tax Officer, House No.743P, Sector-38, Vs. Ward 1(4), Gurugram, Haryana. Faridabad. Pan No.Awmps2317Q अपीलाथ" Appellant ""यथ"/Respondent

section 147 of the Income Tax Act, 1961. In order to assess the above income or any other income which comes to my notice subsequently in the course of assessment proceedings u/s 147, I proceed to initiate proceedings u/s 147 of the I.T. Act, 1961 in the case for A.Y. 2016- 17.” 9. While completing the assessment addition of Rs.2

HARISH KUMAR,DELHI vs. NFAC, DELHI

In the result, the Assessee’s appeal is partly allowed

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manish Agarwal, Hon’Bleasstt. Year : 2015-16 Harish Kumar Vs. Nfac, Delhi 5/21, Shanti Niketan, Chankaya Puri, South West Delhi, New Delhi – 21 (Pan: Aaipk9783G) (Appellant) (Respondent) & Asstt. Year : 2015-16 Acit, Vs. Harish Kumar, Room No. 1505, 15Th Floor, E-2 1/7, West Patel Nagar Tower, Dr. Sp Mukherjee New Delhi – 8 Civic Centre, New Delhi – 2 (Pan: Aaipk9783G) (Appellant) (Respondent) Appellant By : Shri Sanjay Agarwal, Ca & Sh. Sumaksh Mahajan, Ca Respondent By : Shri Surender Pal, Cit(Dr) Date Of Hearing 20.03.2025 Date Of Pronouncement 18.06.2025 Order Per Mahavir Singh, Vp : These Are Cross Appeals Filed By The Assessee As Well As Revenue Against The Order Dated 06.8.2024 Passed By The Ld. Cit(A)/Nfac, Delhi

reassessment proceedings based on the information received under Risk Management Strategy as formulated by the CBDT. Notice u/s. 148 dated 23.06.2021 was issued after obtaining the prior approval of the PCIT, Delhi-4. The AO vide order u/s. 147 r.w.s. 144B of the Act dated 29.05.2023 completed the assessment at income of Rs. 36,24,74,243/- by disallowing

ASSISTANT COMMISSIONER OF INCOME TAX, CIVIC CENTRE, NEW DELHI vs. HARISH KUMAR, DELHI

In the result, the Assessee’s appeal is partly allowed

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manish Agarwal, Hon’Bleasstt. Year : 2015-16 Harish Kumar Vs. Nfac, Delhi 5/21, Shanti Niketan, Chankaya Puri, South West Delhi, New Delhi – 21 (Pan: Aaipk9783G) (Appellant) (Respondent) & Asstt. Year : 2015-16 Acit, Vs. Harish Kumar, Room No. 1505, 15Th Floor, E-2 1/7, West Patel Nagar Tower, Dr. Sp Mukherjee New Delhi – 8 Civic Centre, New Delhi – 2 (Pan: Aaipk9783G) (Appellant) (Respondent) Appellant By : Shri Sanjay Agarwal, Ca & Sh. Sumaksh Mahajan, Ca Respondent By : Shri Surender Pal, Cit(Dr) Date Of Hearing 20.03.2025 Date Of Pronouncement 18.06.2025 Order Per Mahavir Singh, Vp : These Are Cross Appeals Filed By The Assessee As Well As Revenue Against The Order Dated 06.8.2024 Passed By The Ld. Cit(A)/Nfac, Delhi

reassessment proceedings based on the information received under Risk Management Strategy as formulated by the CBDT. Notice u/s. 148 dated 23.06.2021 was issued after obtaining the prior approval of the PCIT, Delhi-4. The AO vide order u/s. 147 r.w.s. 144B of the Act dated 29.05.2023 completed the assessment at income of Rs. 36,24,74,243/- by disallowing

SUNITA BHARDWAJ,NEW DELHI vs. ITO WARD 61(1), NEW DELHI

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2012-13] Sunita Bhardwaj, Vs Acit, 1/2, Taj Apartments, Circle-63(1), R.K.Puram, Sector-12, Delhi Delhi-110022. Pan-Ahfpb1928E Appellant Respondent

section 1 28.12.2019 CIT(A), NFAC, 144 r.w.s. 147 of the [Assessment Year 2012-13] Delhi order dated Income Tax Act, 30.01.2024 1961. 2. 30.03.2022 CIT(A), NFAC, 147 r.w.s. 144B of [Assessment Year 2013-14] Delhi order dated the Income Tax Act, 30.01.2024 1961. 3. 30.03.2022 CIT(A), NFAC, 147 r.w.s. 144B of [Assessment Year 2014-15] Delhi order

SUNITA BHARDWAJ,NEW DELHI vs. ITO WARD 61(1), NEW DELHI

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2012-13] Sunita Bhardwaj, Vs Acit, 1/2, Taj Apartments, Circle-63(1), R.K.Puram, Sector-12, Delhi Delhi-110022. Pan-Ahfpb1928E Appellant Respondent

section 1 28.12.2019 CIT(A), NFAC, 144 r.w.s. 147 of the [Assessment Year 2012-13] Delhi order dated Income Tax Act, 30.01.2024 1961. 2. 30.03.2022 CIT(A), NFAC, 147 r.w.s. 144B of [Assessment Year 2013-14] Delhi order dated the Income Tax Act, 30.01.2024 1961. 3. 30.03.2022 CIT(A), NFAC, 147 r.w.s. 144B of [Assessment Year 2014-15] Delhi order

SUMAN KISHORE,NEW DELHI vs. ITO, NEW DELHI

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2012-13] Sunita Bhardwaj, Vs Acit, 1/2, Taj Apartments, Circle-63(1), R.K.Puram, Sector-12, Delhi Delhi-110022. Pan-Ahfpb1928E Appellant Respondent

section 1 28.12.2019 CIT(A), NFAC, 144 r.w.s. 147 of the [Assessment Year 2012-13] Delhi order dated Income Tax Act, 30.01.2024 1961. 2. 30.03.2022 CIT(A), NFAC, 147 r.w.s. 144B of [Assessment Year 2013-14] Delhi order dated the Income Tax Act, 30.01.2024 1961. 3. 30.03.2022 CIT(A), NFAC, 147 r.w.s. 144B of [Assessment Year 2014-15] Delhi order

SUNITA BHARDWAJ,NEW DELHI vs. ITO WARD 61(1), NEW DELHI

u/s 147 r.w.s.\n143(3) for all the three assessment years i.e. for AY 2013-14, AY\n2014-15 and AY 2015-16 are hereby, quashed. The grounds of\nappeals Nos.1 & 2 for all these three years are thus allowed.\n\n23. Since we have allowed the legal grounds raised by the assessee,\nother grounds of appeal become academic

ACIT CIRCLE-28(1), NEW DELHI, NEW DELHI vs. KULDEEP KAUR, NEW DELHI

Accordingly, the cross objections filed by the assessee for AY 2016-17 is allowed

Bench: Shris.Rifaur Rahman & Shri Vimal Kumaracit, Circle 28 (1), Vs. Kuldeep Kaur, New Delhi. S – 493, Greater Kailash Part Ii, New Delhi – 110 048. (Pan : Aigps1433B) Co No.95/Del/2025 (In Ita No.5978/Del/2024) (Assessment Years : 2016-17) Kuldeep Kaur, Vs. Acit, Circle 28 (1), S – 493, Greater Kailash Part Ii, New Delhi. New Delhi – 110 048. (Pan : Aigps1433B) (Appellant) (Respondent) Assessee By : Shri V.K. Sabharwal, Advocate Shri Rajiv Kumar, Advocate Shri S.S. Agarwal, Ca Revenue By : Shri Om Prakash, Sr. Dr Date Of Hearing : 06.11.2025 Date Of Order : 26.11.2025 O R D E R Per S.Rifaur Rahman: 1. The Revenue Has Filed Appeal Against The Order Of Ld. Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi

section 144B of the Income Tax Act, 1961 further becomes non- est under the law & to the facts of the case because of the taking & granting of approval by the JCIT u/s 151 of the act was mechanical without any application of her mind. 3 CO No.95/Del/2025 4. That the reassessment order passed on 30.03.2022 u/s 147

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

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