VRC TOWNSHIP P LTD.,DELHI vs. ITO, NEW DELHI

In the result, appeal of the Assessee allowed

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

reassessment order invalid”. 3.4. In the case of Sarthak Securities Co. (P) Ltd., 329 ITR 110 (Del.), the Hon’ble Delhi High Court held as under : “No independent application of mind by the Assessing officer but acting under information from Inv. Wing - Notice U/s. 147 to be quashed”. 3.5. The assessee also submitted that assessment is barred by time

M/S. MOONSTAR SECURITIES TRADING & FINANCE CO. PVT. LTD.,,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal filed by the assessee is allowed

reassess under section 147 or pass an order enhancing the assessment or reducing the refund already made or otherwise increasing the liability of the assessee under section 154." 16. Equally illuminating are the following observations in Godrej and Boyce Mfg. Co. Ltd. (supra) (page 117 of 328 ITR) : "However, if the assessee does not maintain separate accounts, it would

SHARK PACKAGING (INDIA) PRIVATE LIMITED,DELHI vs. ITO,WARD-23(1), NEW DELHI

In the result, the appeal of the assessee for AY 2012-13 is partly allowed only on ground no

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

reassessment order u/s. 147 r.w.s. 143(3) of the Act, and ld. representatives both the sides have not placed any arguments on the other grounds of assessee on merits, therefore, we don’t deem it proper to adjudicate those grounds in absence of any arguments. 24.1 In the result, the appeal of assessee for AY 2011-12 is allowed

SHARK PACKAGING (INDIA) PVT LTD,NEW DELHI vs. ITO WARD - 23(1), NEW DELHI

In the result, the appeal of the assessee for AY 2012-13 is partly allowed only on ground no

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

reassessment order u/s. 147 r.w.s. 143(3) of the Act, and ld. representatives both the sides have not placed any arguments on the other grounds of assessee on merits, therefore, we don’t deem it proper to adjudicate those grounds in absence of any arguments. 24.1 In the result, the appeal of assessee for AY 2011-12 is allowed

SHARK PACKAGING (INDIA) PVT LTD,NEW DELHI vs. ITO WARD - 23(1), NEW DELHI

In the result, the appeal of the assessee for AY 2012-13 is partly allowed only on ground no

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

reassessment order u/s. 147 r.w.s. 143(3) of the Act, and ld. representatives both the sides have not placed any arguments on the other grounds of assessee on merits, therefore, we don’t deem it proper to adjudicate those grounds in absence of any arguments. 24.1 In the result, the appeal of assessee for AY 2011-12 is allowed

MADHU APARTMENT PVT. LTD.,DELHI vs. ITO, WARD- 16(1), NEW DELHI

In the result, appeal of the Assessee allowed

Bench: Shri Bhavnesh Saini & Shri B.R.R. Kumar

reassessment order invalid”. 3.4. In the case of Sarthak Securities Co. (P) Ltd., 329 ITR 110 (Del.), the Hon’ble Delhi High Court held as under : “No independent application of mind by the Assessing officer but acting under information from Inv. Wing - Notice U/s. 147 to be quashed”. 3.5. The assessee also submitted that assessment is barred by time

MADHU APARTMENT PVT. LTD.,DELHI vs. ITO, WARD- 16(1), NEW DELHI

In the result, appeal of the Assessee allowed

Bench: Shri Bhavnesh Saini & Shri B.R.R. Kumar

reassessment order invalid”. 3.4. In the case of Sarthak Securities Co. (P) Ltd., 329 ITR 110 (Del.), the Hon’ble Delhi High Court held as under : “No independent application of mind by the Assessing officer but acting under information from Inv. Wing - Notice U/s. 147 to be quashed”. 3.5. The assessee also submitted that assessment is barred by time

BTL HOLDING CO. LTD,FARIDABAD vs. DCIT CENTRAL CIRCLE-II, FARIDABAD

In the result, ITA No.7429/Del/2019 for A

Bench: Shri Vikas Awasthy & Shri Amitabh Shukla

147 / 148 themselves are not supported by valid legal authority, consequent reassessment order arising there from would be a case of nullity and an order being void ab initio. Accordingly, we are of the view that the proceedings u/s 148 are bad in law and deserves to be quashed. We therefore quash the proceedings u/s 148 as being

BTL HOLDING CO. LTD,FARIDABAD vs. DCIT CENTRAL CIRCLE-II, FARIDABAD

In the result, ITA No.7429/Del/2019 for A

Bench: Shri Vikas Awasthy & Shri Amitabh Shukla

147 / 148 themselves are not supported by valid legal authority, consequent reassessment order arising there from would be a case of nullity and an order being void ab initio. Accordingly, we are of the view that the proceedings u/s 148 are bad in law and deserves to be quashed. We therefore quash the proceedings u/s 148 as being

BTL HOLDING CO. LTD,FARIDABAD vs. DCIT CENTRAL CIRCLE-II, FARIDABAD

In the result, ITA No.7429/Del/2019 for A

Bench: Shri Vikas Awasthy & Shri Amitabh Shukla

147 / 148 themselves are not supported by valid legal authority, consequent reassessment order arising there from would be a case of nullity and an order being void ab initio. Accordingly, we are of the view that the proceedings u/s 148 are bad in law and deserves to be quashed. We therefore quash the proceedings u/s 148 as being

COMMISSIONER OF INCOME TAX-VI vs. TAIKISHA ENGINEERING INDIA LTD

u/s 14A would arise only if some expenditure is said to have been incurred in relation to investment in such securities. In this regard, it is observed that the assessee made total investment of [Rs.] 6.33 crore in shares or securities resulting into exempt income. As against that share holder funds stood at [Rs.] 53.79 crore

M/S. MOONSTAR SECURITIES TRADING & FINANCE CO. PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result appeal filed by the assessee is allowed

Bench: : Shri Bhavnesh Saini & Shri L.P. Sahu

reassess under section 147 or pass an order enhancing the assessment or reducing the refund already made or otherwise increasing the liability of the assessee under section 154." 16. Equally illuminating are the following observations in Godrej and Boyce Mfg. Co. Ltd. (supra) (page 117 of 328 ITR) : "However, if the assessee does not maintain separate accounts, it would

ACIT, NEW DELHI vs. M/S. MOONSTAR SECURITIES TRADING & FINANCE CO. PVT. LTD., NEW DELHI

In the result appeal filed by the assessee is allowed

Bench: : Shri Bhavnesh Saini & Shri L.P. Sahu

reassess under section 147 or pass an order enhancing the assessment or reducing the refund already made or otherwise increasing the liability of the assessee under section 154." 16. Equally illuminating are the following observations in Godrej and Boyce Mfg. Co. Ltd. (supra) (page 117 of 328 ITR) : "However, if the assessee does not maintain separate accounts, it would

DCIT, NEW DELHI vs. M/S. GALILEO INDIA PVT. LTD., NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: : Shri H.S. Sidhu & Shri L.P. Sahu

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001. 8. A plain reading of the provisions of section 14A(2)/ (3)suggests that the disallowance under this

BEHAT HOLDINGS LTD.,NEW DELHI vs. ITO WARD-4(3), NEW DELHI

In the result, appeal of Assessee allowed

Bench: Shri Bhavnesh Saini & Shri N.K. Billaiya

reassessment order invalid”. 3.4. In the case of Sarthak Securities Co. (P) Ltd., 329 ITR 110 (Del.), the Hon’ble Delhi High Court held as under : “No independent application of mind by the Assessing officer but acting under information from Inv. Wing - Notice U/s. 147 to be quashed”. 3.5. The assessee also submitted that assessment is barred by time

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

147 r.w.s. 143(3) dated 31.03.2022 wherein the total income of the assessee was assessed by making additions of Rs.10,96,92,546/- after disallowing various expenses claimed. 9. Against the said order, the assessee has preferred the appeal before the Ld. CIT(A) who after considering the merits of the submissions made, had deleted the DCIT vs. Lotus Hearbals

DCIT, CENTRAL CIRCLE-20, DELHI vs. LOTUS HERBALS PVT. LTD, DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

147 r.w.s. 143(3) dated 31.03.2022 wherein the total income of the assessee was assessed by making additions of Rs.10,96,92,546/- after disallowing various expenses claimed. 9. Against the said order, the assessee has preferred the appeal before the Ld. CIT(A) who after considering the merits of the submissions made, had deleted the DCIT vs. Lotus Hearbals

DCIT, CENTRAL CIRCLE-20, NEW DELHI vs. LOTUS HERBALS P.LTD, DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

147 r.w.s. 143(3) dated 31.03.2022 wherein the total income of the assessee was assessed by making additions of Rs.10,96,92,546/- after disallowing various expenses claimed. 9. Against the said order, the assessee has preferred the appeal before the Ld. CIT(A) who after considering the merits of the submissions made, had deleted the DCIT vs. Lotus Hearbals

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

147 r.w.s. 143(3) dated 31.03.2022 wherein the total income of the assessee was assessed by making additions of Rs.10,96,92,546/- after disallowing various expenses claimed. 9. Against the said order, the assessee has preferred the appeal before the Ld. CIT(A) who after considering the merits of the submissions made, had deleted the DCIT vs. Lotus Hearbals