MR. RANJEET SINGH,GURGAON vs. DCIT, NEW DELHI

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year 2005-06

14 ITAs No.5512, 5513, 5546 & 5574/DEL/2011 appellant in terms of section 17(2)(iii) read with section 2(24)(iv). The appellant as a director of the company has been transferred shares at Rs.10/- per share, which is the face value and not the market value. Since M/s Eltek SGS Pvt. Ltd. was a profit making and dividend paying company

MR. J.S. GUJRAL,GURGAON vs. DCIT, NEW DELHI

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year 2005-06

14 ITAs No.5512, 5513, 5546 & 5574/DEL/2011 appellant in terms of section 17(2)(iii) read with section 2(24)(iv). The appellant as a director of the company has been transferred shares at Rs.10/- per share, which is the face value and not the market value. Since M/s Eltek SGS Pvt. Ltd. was a profit making and dividend paying company

MR. SANJIV NARAYAN,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year 2005-06

14 ITAs No.5512, 5513, 5546 & 5574/DEL/2011 appellant in terms of section 17(2)(iii) read with section 2(24)(iv). The appellant as a director of the company has been transferred shares at Rs.10/- per share, which is the face value and not the market value. Since M/s Eltek SGS Pvt. Ltd. was a profit making and dividend paying company

BALLU SINGH,GURGAON vs. ITO WARD -65(5), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Kul Bharat

section 147 of the IT Act, 1961. Moreover, it is quite possible that any other income may also have escaped assessment and hence issue of notice u/s 148 becomes inevitable to bring the income that has escaped assessment under the ambit of assessment.” 2.2 Plain reading of the reasons as recorded by the Ld. Assessing Officer suggest us as follows

BALLU SINGH,GURGAON vs. ITO WARD -65(5), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Kul Bharat

section 147 of the IT Act, 1961. Moreover, it is quite possible that any other income may also have escaped assessment and hence issue of notice u/s 148 becomes inevitable to bring the income that has escaped assessment under the ambit of assessment.” 2.2 Plain reading of the reasons as recorded by the Ld. Assessing Officer suggest us as follows

ACIT, CENTRAL CIRCLE-II, GURGAON vs. ANOOP THATAI, NEW DELHI

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

2(22)(e) 13 made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A of the Income

DCIT, CENTRAL CIRCLE-II, GURGAON vs. SUDHIR DHINGRA, NEW DELHI

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

2(22)(e) 13 made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A of the Income

SUDHIR DHINGRA,NEW DELHI vs. DCIT, CENTRAL CIRCLE-II, GURGAON

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

2(22)(e) 13 made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A of the Income

DCIT, CENTRAL CIRCLE-II, GURGAON vs. SUDHIR DHINGRA, NEW DELHI

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

2(22)(e) 13 made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A of the Income

ANOOP THATAI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-II, GURGAON

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

2(22)(e) 13 made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A of the Income

DCIT, CENTRAL CIRCLE-II, GURGAON vs. SUDHIR DHINGRA, NEW DELHI

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

2(22)(e) 13 made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A of the Income

DCIT, CENTRAL CIRCLE-II, GURGAON vs. SUDHIR DHINGRA, NEW DELHI

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

2(22)(e) 13 made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A of the Income

DCIT, CENTRAL CIRCLE-II, GURGAON vs. SUDHIR DHINGRA, NEW DELHI

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

2(22)(e) 13 made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A of the Income

DCIT, CENTRAL CIRCLE-II, GURGAON vs. SUDHIR DHINGRA, NEW DELHI

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

2(22)(e) 13 made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A of the Income

SUDHIR DHINGRA,NEW DELHI vs. DCIT, CENTRAL CIRCLE-II, GURGAON

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

2(22)(e) 13 made by the AO in a block assessment u/s 158BC, the provisions of which are restrictive than those of section 153A. (iii) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was right in concluding that there was a difference in scope of proceedings under section 153A of the Income

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

reassessment order passed u/s 147 of the Act is further not tenable under the law because the additions made on the basis of reasons recorded for reopening were deleted by Ld. CIT(A) and thus, no additions on the basis of reasons recorded for reopening survives in case of assessee.” 2. The assessee was a government employee during the year

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

reassessment order passed u/s 147 of the Act is further not tenable under the law because the additions made on the basis of reasons recorded for reopening were deleted by Ld. CIT(A) and thus, no additions on the basis of reasons recorded for reopening survives in case of assessee.” 2. The assessee was a government employee during the year

M/S. DHARAMPAL SATYAPAL LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee is allowed and the appeal of the revenue is dismissed

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

iii) In case reopening is sought to be done by the AO after expiry of four years from the end of the relevant assessment year and the original assessment was framed u/s 143(3) then reasons can be recorded only if there was failure on the part of the assessee in disclosure of material of facts, as has been envisaged

DCIT, NEW DELHI vs. M/S. DHARAMPAL SATYAPAL LTD., DELHI

In the result, the appeal of the assessee is allowed and the appeal of the revenue is dismissed

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

iii) In case reopening is sought to be done by the AO after expiry of four years from the end of the relevant assessment year and the original assessment was framed u/s 143(3) then reasons can be recorded only if there was failure on the part of the assessee in disclosure of material of facts, as has been envisaged