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

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

In the result, all the appeals for

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

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

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

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

In the result, all the appeals for

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

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

reassessment\ncommenced pursuant to a search, based upon it being found that the proceedings\nwould have sustained bearing in mind the timelines prescribed in Sections 149,\n153A and 1536, as they existed prior to the commencement of Finance Act, 2021.\nThis necessarily requires us to advert to the timeframes comprised in both Section\n149(1)(b) as well as Section

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

In the result, all the appeals for

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

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

In the result, all the appeals for

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

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

147", "Section 148", "Section 149", "Section 153A", "Section 153C", "Section 148B", "Section 153D" ], "issues": "Whether the reassessment proceedings for AY 2012-13 were barred by limitation? Whether the approval granted u/s

ACE MEGA STRUCTURES PRIVATE LIMITED,UTTAR PRADESH vs. DCIT/ACIT CEN CIR, NOIDA, NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

u/s 143(2), dated 17th of June 2022 and the Assessing Officer ITA Nos.4115 & 4067/Del/2025 was well aware of the information and material including, the material found and seized from the third parties namely Sh. Ajay Prabhakar and Sh. Ravi Kapoor and further to that, we have carefully gone through explanation -2 to section 147 as amended by Finance

DY. COMMISSIONER OF INCOME TAX, NOIDA vs. M/S ACE MEGA STRUCTURE PRIVATE LIMITED, NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

u/s 143(2), dated 17th of June 2022 and the Assessing Officer ITA Nos.4115 & 4067/Del/2025 was well aware of the information and material including, the material found and seized from the third parties namely Sh. Ajay Prabhakar and Sh. Ravi Kapoor and further to that, we have carefully gone through explanation -2 to section 147 as amended by Finance

MONTAGE ENTERPRISES PRIVATE LIMITED,MAYUR VIHAR PHASE-I, EAST DELHI vs. DCIT/ACIT CEN CIR-II, NOIDA, CENTRAL CIRCLE-II, NOIDA

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2022-23 Montage Enterprises Pvt. Vs. Dcit/Acit, Ltd., Central Circle-Ii, 205, 2Nd Floor, V-4, Mayur Noida Plaza -2, Local Shopping Centre, Mayur Vihar, Phase-1, East Delhi, Delhi Pan :Aaccm8173H (Appellant) (Respondent) With Assessment Year: 2022-23 Dcit/Acit, Vs. Montage Enterprises Pvt. Ltd., Central Circle-Ii, 205, 2Nd Floor, V-4, Mayur Noida Plaza -2, Local Shopping Centre, Mayur Vihar, Phase-1, East Delhi, Delhi Pan: Aaccm8173H (Appellant) (Respondent) Assessee By Sh. Rohit Kapoor, Adv. Sh. Veersen Aggarwal, Itp Department By Sh. Siddharth Bhim Singh Meena, Cit(Dr) Date Of Hearing 08.12.2025 Date Of Pronouncement 29.12.2025

u/s 148B before passing assessment order. 13.2 As the Assessing Officer completed the assessment under section 143(3) of the Act without issuing the notice under section 148 of the Act. Therefore, the question before us is whether the assessment proceedings initiated under section 143(3) of the Act can be validly continued and completed after a search under section

DCIT, CENTRAL CIRCLE - 2, NOIDA, NOIDA vs. M/S MONTAGE ENTERPRISES PVT. LTD., NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2022-23 Montage Enterprises Pvt. Vs. Dcit/Acit, Ltd., Central Circle-Ii, 205, 2Nd Floor, V-4, Mayur Noida Plaza -2, Local Shopping Centre, Mayur Vihar, Phase-1, East Delhi, Delhi Pan :Aaccm8173H (Appellant) (Respondent) With Assessment Year: 2022-23 Dcit/Acit, Vs. Montage Enterprises Pvt. Ltd., Central Circle-Ii, 205, 2Nd Floor, V-4, Mayur Noida Plaza -2, Local Shopping Centre, Mayur Vihar, Phase-1, East Delhi, Delhi Pan: Aaccm8173H (Appellant) (Respondent) Assessee By Sh. Rohit Kapoor, Adv. Sh. Veersen Aggarwal, Itp Department By Sh. Siddharth Bhim Singh Meena, Cit(Dr) Date Of Hearing 08.12.2025 Date Of Pronouncement 29.12.2025

u/s 148B before passing assessment order. 13.2 As the Assessing Officer completed the assessment under section 143(3) of the Act without issuing the notice under section 148 of the Act. Therefore, the question before us is whether the assessment proceedings initiated under section 143(3) of the Act can be validly continued and completed after a search under section

DEEPAK KUMAR GUPTA,KANPUR vs. ITO WARD 2(1), MORADABAD, MORADABAD

In the result, appeal of the Assessee is partly allowed as indicated above

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2014-15 Deepak Kumar Gupta, Vs. Income Tax Officer, 7/115, Flat No. B-1, Sai Niwas, Ward 2(1), Arya Nagar, Kanpur - 208020 Moradabad ( U.P) Uttar Pradesh. Pin: 244 001 Pan :Acmpg1836E (Appellant) (Respondent)

147 r.w.s. 148B of the Act for assessment year 2014-15. 2. Brief facts of the case are that assessee filed his return of income declaring income of Rs.6,46,010/-. The case was reopened on information that the assessee had purchased immovable property for a consideration of Rs.40,23,000/-. During verification, assessee failed to provide the source

INDUS VALLEY PROMOTERS LTD,NEW DELHI vs. DCIT CIRCLE-10(1), DELHI, DELHI

In the result the appeal of the assessee is allowed

Bench: Sh. Sudhir Kumar & Sh. Manish Agarwalassessment Year- 2018-19 M/S. Indus Vally Promoters Vs. Dcit Ltd., F-6, Ground Floor Circle – 10 (1) (Right), Lajpat Nagar –Iii Delhi New Delhi-110024 Pan No. Aaaci2241L (Appellant) (Respondent)

147 of the Act were initiated and order u/s 148(d) of the Act was passed on 31-03-2022. In the compliance of the notice dated 31-03-2022 under section 148 of the Act the assessee furnished the ITR declaring total income of Rs. 4,92,88,570/- on 25-04-2022. After considering the submission submitted

ITO, NEW DELHI vs. MR. DINESH BANSAL, DELHI

In the result, revenue’s appeal as well as assessee’s cross objection stand dismissed

Bench: Shri S.V. Mehrotra : & Ms. Suchitra Kamble :Asstt. Yr: 2005-06 Income Tax Officer, Vs. Mr. Dinesh Bansal, Ward 25(1), New Delhi. C/0 Krishan Lal Dinesh Kumar, 148B, G&Ju-Block, Pitampura, Delhi-110034. Pan: Agepb 8000 H & C.O. No. 108/Del/2014 ( In Ita No. 5744/Del/2013) Asstt. Yr: 2005-06 Mr. Dinesh Bansal, Vs. Income Tax Officer, C/0 Krishan Lal Dinesh Kumar, Ward 25(1), New Delhi. 148B, G&Ju-Block, Pitampura, Delhi-110034. ( Appellant ) (Respondent)

148B, G&JU-Block, Pitampura, Delhi-110034. ( Appellant ) (Respondent) Revenue by : Shri Neehar Ranjan Pandey Sr. DR Assessee by : Shri Neeraj Jain CA & Shri P.K. Misra CA . Date of hearing : 17/12/2015. Date of order : 03/02/2016. O R D E R PER S.V. MEHROTRA, A.M: The captioned appeal by the revenue and the cross-objection by the assessee are directed against