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

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

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

SEEMA GOEL,DELHI vs. CIT A, DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

1) On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in confirming the action of the AO despite the fact that the order under Section 148A(d) of the Act, notice under section 148 of the Act and the consequent reassessment order under section 147 r.w.s

SEEMA GOEL,DELHI vs. CIT A, DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

1) On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in confirming the action of the AO despite the fact that the order under Section 148A(d) of the Act, notice under section 148 of the Act and the consequent reassessment order under section 147 r.w.s

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) On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in confirming the action of the AO despite the fact that the order under Section 148A(d) of the Act, notice under section 148 of the Act and the consequent reassessment order under section 147 r.w.s

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) On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in confirming the action of the AO despite the fact that the order under Section 148A(d) of the Act, notice under section 148 of the Act and the consequent reassessment order under section 147 r.w.s

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

HCL SINGAPORE PTE. LTD (SUCCESSOR TO AXON SOLUTIONS SINGAPORE PTE LIMITED),DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, similar grounds of appeal, in all the captioned

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

u/s 147 r.w.s 144C(13) of the Income- tax Act, 1961 [the Act, for short] pertaining to different Assessment Years. 2. Since the underlying facts are common in the appeals of the assessee, they were heard together and are disposed of by this common order for the sake of convenience and brevity. 3. The grounds of appeal taken

HCL AUSTRALIA SERVICES PTY LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, similar grounds of appeal, in all the captioned

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

u/s 147 r.w.s 144C(13) of the Income- tax Act, 1961 [the Act, for short] pertaining to different Assessment Years. 2. Since the underlying facts are common in the appeals of the assessee, they were heard together and are disposed of by this common order for the sake of convenience and brevity. 3. The grounds of appeal taken

HCL TECHNOLOGIES NORWAY AS ,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, similar grounds of appeal, in all the captioned

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

u/s 147 r.w.s 144C(13) of the Income- tax Act, 1961 [the Act, for short] pertaining to different Assessment Years. 2. Since the underlying facts are common in the appeals of the assessee, they were heard together and are disposed of by this common order for the sake of convenience and brevity. 3. The grounds of appeal taken

INCOME TAX OFFICER, WARD 46(1), NEW DELHI, NEW DELHI vs. MAM RAJ CHUNNI LAL EXIM, NEW DELHI

In the result the appeal of the Revenue is dismissed and the cross objection of the assessee is partly allowed

Bench: Sh. Sudhir Kumar & Sh. Manish Agarwalassessment Year: 2016-17 Income Tax Officer, Vs Mam Raj Chunni Lal Exim Ward- 46 (1) Shop No. 5183, Ground New Delhi Floor, Lahori Gate, Naya Bazar, Delhi -110006 Pan No.Aaxfm0533B (Appellant) (Respondent)

151A, the CBDT has the power to notify a scheme for the purpose of 1. the purpose of assessment, reassessment or re-computation under Section 147; or 2. issuance of notice under Section 148; or 3. conducting of inquiry or issuance of show cause notice or passing of order under Section 148A; or 4. sanction for issuance of notice under

SUSHIL KUMAR,DELHI vs. ACIT - CIRCLE -22(2), DELHI

In the result, Appeal of the Assessee is allowed

Bench: Shri M. Balaganesh & Sh. Yogesh Kumar U.S.Sushil Kumar Vs. Acit Shreeram Overseas Circle-22(2) 5520, Basti Harpull C. R. Building, Singh, Sadar Bazar, Delhi Delhi Pan: Aalpk5068M Appellant Respondent

147 to section 151A of Income Tax Act, 1961 and therefore, the reassessment proceeding initiated along with assessment order passed are liable to be quashed and CIT(A) erred in not holding so. 3. On the facts and circumstances of the case and in law, the order passed by the learned assessing officer and the addition made therein

SH. RAJ KUMAR CHAUDHARY,DELHI vs. ITO WARD-34(5), DELHI

In the result, both the appeals of the assessee are allowed for statistical purposes only

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh[Assessment Year: 2018-19] Shri Raj Kumar Chaudhary, Income Tax Officer, C-243, Sector-3, Dsidc Ward-34(5), Indl. Area Bawana, Vs Delhi. New Delhi-11003. Pan- Aewpk1980K Assessee Revenue [Assessment Year: 2018-19] Shri Raj Kumar Chaudhary, Income Tax Officer, C-243, Sector-3, Dsidc Ward-34(5), Indl. Area Bawana, Vs Delhi. New Delhi-11003. Pan- Aewpk1980K Assessee Revenue

151A of the Act; and therefore the assumption of jurisdiction was not in accordance with law. 4That the learned Commissioner of Income Tax (Appeals) has further erred both in law and on facts in upholding an addition of Rs. 3,60,51,890/- representing alleged unexplained money and brought to tax u/s 69A of the Act read with section 115BBE

SH. RAJ KUMAR CHAUDHARY,DELHI vs. ITO WARD-34(5), DELHI

In the result, both the appeals of the assessee are allowed for statistical purposes only

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh[Assessment Year: 2018-19] Shri Raj Kumar Chaudhary, Income Tax Officer, C-243, Sector-3, Dsidc Ward-34(5), Indl. Area Bawana, Vs Delhi. New Delhi-11003. Pan- Aewpk1980K Assessee Revenue [Assessment Year: 2018-19] Shri Raj Kumar Chaudhary, Income Tax Officer, C-243, Sector-3, Dsidc Ward-34(5), Indl. Area Bawana, Vs Delhi. New Delhi-11003. Pan- Aewpk1980K Assessee Revenue

151A of the Act; and therefore the assumption of jurisdiction was not in accordance with law. 4That the learned Commissioner of Income Tax (Appeals) has further erred both in law and on facts in upholding an addition of Rs. 3,60,51,890/- representing alleged unexplained money and brought to tax u/s 69A of the Act read with section 115BBE

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

1) of theAct. 9. That on facts and circumstances of the case, the issuance of notice by Jurisdictional Assessing Officer (JAO) is completely violation of provision of section 151A of the Income Tax Act, 1961. Thus, the initiation of proceeding u/s 148 of the Act is void ab-initio in toto and consequential Assessment Order is liable to be quashed