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

148A(d), notice issued under section 148 and consequent reassessment order passed by AO under Section 147 r.w.s. 144 of the Act are illegal and void-ab-initio as the same have been issued and passed without following the statutory conditions and procedures prescribed under the Act. 9. On the facts and circumstances of the case, the learned

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

148A(d), notice issued under section 148 and consequent reassessment order passed by AO under Section 147 r.w.s. 144 of the Act are illegal and void-ab-initio as the same have been issued and passed without following the statutory conditions and procedures prescribed under the Act. 9. On the facts and circumstances of the case, the learned

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

147 regarding assessment or reassessment of escaped income, he would keep on making roving inquiry and thereby including different items of income not connected or related with the reasons to believe, on the basis of which he assumed jurisdiction. For every new issue coming before AO during the course of proceedings of assessment or reassessment of escaped income, and which

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

147 regarding assessment or reassessment of escaped income, he would keep on making roving inquiry and thereby including different items of income not connected or related with the reasons to believe, on the basis of which he assumed jurisdiction. For every new issue coming before AO during the course of proceedings of assessment or reassessment of escaped income, and which

COLVIN CARE PVT LTD,GURGAON vs. DCIT, CIRCLE- 4(2), DELHI

In the result, appeal of the assessee is partly allowed

Bench: Shri Challa Nagendra Prasad & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2016-17] Colvin Care Pvt. Ltd. Dcit, Circle-4(2), C-531, 2Nd Floor, Sushant Lok-1, C.R. Building, I.P. Estate, Gurgaon, Haryana-1220002 Vs Delhi-110002 Pan-Aajcc0406C Appellant Respondent Appellant/Assessee By Shri Mukesh Jain, Ca & Shri Samyak Jain, Adv. Respondent/Revenue By Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 01.04.2026 Date Of Pronouncement 08.04.2026

reassessment or recomputation under section 147, and subject to the provisions of section 148A. the Assessing Officer shall serve on the assessee a notice, along with a copy of the order passed, if required, under clause (d) of section 148A, requiring him to furnish within such period, as may be specified in such notice, a return of his income

INTERNATIONAL HOSPITAL LIMITED vs. DCIT CIRCLE 12 (2)

Bench: HON'BLE MR. JUSTICE RAVINDER DUDEJA,HON'BLE MR. JUSTICE YASHWANT VARMA

147 read with Section 144 W.P.(C) 13991/2022 21 June 2021 23 May 2022 25 July 2022 Notice under Section 148 Order under Section 148A(b) Order under Section 148A(d) and Notice under Section 148 W.P.(C) 14034/2022 27 May 2022 28 July 2022 Order under Section 148A(b) Order under Section 148A(d) and Notice under Section

INCOME TAX OFFICER, WARD-20(3), DELHI, NEW DELHI vs. RMP HOLDINGS PVT LTD, NEW DELHI

In the result the appeal of the Revenue is dismissed

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2017-18 Ito, Vs. Rmp Holdings Pvt. Ltd. New Delhi 138-C, Block -B Group -4 Dilshad Garden New Delhi Pan No.Aaacr5533N (Appellant) (Respondent)

147 of the Act becomes void-ab-initio and therefore, assessment in this case is hereby annulled as notice u/s 148 and order u/s 148A(d) of the Act are invalid in the eyes of law as AO lacks jurisdiction to issue notice u/s 148 without the approval of specified authority. Thus, Ground No. 3 of the appeal is allowed

THE HISAR LEADING BANK CO-OP NON-AGRI THRIFT & CREDIT SOCIETY,HISAR vs. INCOME-TAX OFFICER, WARD-1, HISAR, HISAR

In the result, Appeal of the Assessee is allowed

reassessment proceedings, which began on 01.06.2021, to\nissue a notice under Section 148 of the Act. The said notice was\nrequired to be accompanied by an order under Section 148A(d)of\nthe Act. Thus, the AO was required to pass an order\nunder Section 148A(d) of the Act within the said twenty-nine\ndays notwithstanding the time stipulated

INCOME TAX OFFICER, ROHTAK vs. PANKAJ JAIN, ROHTAK

In the result, the appeal filed by the Revenue is dismissed

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmaincome Tax Officer, Vs. Pankaj Jain, Rohtak. 123/34, Vishwakarma Kathmandi, Rohtak – 124 001 (Haryana). (Pan : Azupj6345A) (Appellant) (Respondent) Assessee By : Shri Shri Naveen Gupta, Advocate Shri Nakul Gupta, Advocate Revenue By : Shri Ajay Kumar Arora,Sr. Dr Date Of Hearing : 06.11.2025 Date Of Order : 30.12.2025 Order Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Cit(A)”, For Short] Dated 04.02.2025 For The Assessment Year 2018-19 Raising Following Grounds Of Appeal :- “1. The Learned Cit(A) Has Erred In Law & On Facts In Not Upholding The Validity Of The Notice Issued Under Section 148 Of The Income Tax Act, 1961 (The Act) Without The Proper & Mandatory Compliance With The Provisions Of Section 148A(B). 2. The Learned Cit(A) Has Further Erred In Law & On Facts By Failing To Consider That The Then Ao Has Given Notice U/S 148A(B) To Assessee On 31.03.2022

147 r.w.s 144B of the Act on 25.03.2024 by assessing the total income at Rs.5,41,69,809/-. 4. Aggrieved with the above order, assessee preferred an appeal before the NFAC, Delhi and filed grounds of appeal and detailed submissions. Before the ld. CIT (A), assessee has raised the legal issues vide Ground Nos.1 to 7 regarding challenging the legal

CHIRAG KIRPAL,DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, GURGAON

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh & Shri Vimal Kumarchirag Kirpal, Vs. Acit, C/O. Anuj Bhatia, C-3, Bali International Taxation, Nagar, New Raja Garden, Gurgaon New Delhi (Appellant) (Respondent) Pan: Bwxpk8788D Assessee By : Shri. S. K. Gupta, Ca Revenue By: Shri M. S. Nethrapal, Cit Dr Date Of Hearing 17/09/2025 Date Of Pronouncement 30/09/2025

148A of the Income Tax Act, 1961 (for short ‗the Act‘) inconsonance with the order passed by the Dispute Resolution Panel (DRP-1) dated 04.12.2024 u/s 144C(5). 2. The preliminary issue to be decided in this appeal is as to whether the assumption of jurisdiction by the Learned AO could be construed as valid when the notice under section

ANURAG PANDEY,DELHI vs. ITO, WARD 29(1), CIVIC CENTRE

In the result, appeal of the assessee is allowed

reassessment or\nrecomputation under section 147, and subject to the provisions\nof section 148A. the Assessing Officer shall serve on the\nassessee a notice, along with a copy of the order passed, if\nrequired, under clause (d) of section 148A, requiring him to\nfurnish within such period, as may be specified in such notice, a\nreturn of his income

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

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

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)

u/s 147/148-Held, Section 151 stipulates that CIT (A), who was competent authority to authorize reassessment notice, had to apply his mind and form opinion-Mere appending of expression 'approved' says nothing-It was not as if CIT (A) had to record elaborate reasons for agreeing with noting put up-At same time, satisfaction had to be recorded of given case

BHUSHAN GUPTA,DELHI vs. ITO, WARD 47(1), DELHI, NEW DELHI

In the result appeal of the assessee in ITA number 1112 for AY 2016-17 &

Bench: Madhumita Roy & Shri Amitabh Shukla

reassessment or recomputation under section 147, and subject to the provisions of section 148A. the Assessing Officer shall serve on the assessee a notice, along with a copy of the order passed, if required, under clause (d) of section 148A, requiring him to furnish within such period, as may be specified in such notice, a return of his income

BHUSHAN GUPTA,DELHI vs. ITO, WARD 47(1), DELHI, NEW DELHI

In the result appeal of the assessee in ITA number 1112 for AY 2016-17 &

Bench: Madhumita Roy & Shri Amitabh Shukla

reassessment or recomputation under section 147, and subject to the provisions of section 148A. the Assessing Officer shall serve on the assessee a notice, along with a copy of the order passed, if required, under clause (d) of section 148A, requiring him to furnish within such period, as may be specified in such notice, a return of his income