DONALDSON INDIA FILTERS SYSTEMS PVT. LTD vs. DCIT, CIRCLE 10(1)

reassessed. To confer jurisdiction under section 147(a) two conditions were required to be satisfied : firstly the Assessing Officer must have been reason to believe that income, profits or gains chargeable to income tax have escaped assessment, and secondly he must also have reason to believe that such escapement has occurred by reason of either omission or failure

BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE-18, DELHI

In the result, the appeals of the revenue in ITA No

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

147, for the very same year is nothing but rowing and fishing enquiries, which is impermissible. 7. That on the facts & circumstances of the case and in law, the CIT(A) did not appreciate that the information based on which order u/s. 153A/143(3) of the Act was concluded, was already available with the Income-tax Department. Inter-alia, Assessing

BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-18, NEW DELHI

In the result, the appeals of the revenue in ITA No

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

147, for the very same year is nothing but rowing and fishing enquiries, which is impermissible. 7. That on the facts & circumstances of the case and in law, the CIT(A) did not appreciate that the information based on which order u/s. 153A/143(3) of the Act was concluded, was already available with the Income-tax Department. Inter-alia, Assessing

ACIT, NEW DELHI vs. SH. EMPIRE CASTING PVT. LTD., NEW DELHI

In the result, the appeal of the revenue and C

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

147, section 148, section 149, section 151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003, the Assessing Officer shall— (a) issue notice to such person requiring him to furnish within

JINDAL STEEL & POWER LTD.,NEW DELHI vs. PRCIT, GURUGRAM

In the result appeal of the assessee is allowed on the issue of the impugned order passed beyond the prescribed time, other issues are left open

147 and issued notice dated 21.03.2014 under Section 148 alleging that in assessment year in question there is an escaped assessment on account of failure to disallow expenditure on purchases from overseas in terms of Section 40(a)(i) of Act, 1961 for non deduction of tax at source from such payment. Reassessment order was passed on 26.03.2015 after making

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:

u/s 40A(2)(b) including purchases made from Kanidi Cosmeceuticals and 1,otus Herbals Color Cosmetics. -Vide reply dated 19.11.2015[(@pages 136 to 200 of the paper book, the assessee furnished the following details:  Vide Sr. No.1, the detail of various Marketing expenses recorded under different accounting heads for AY 2010-11 το ۸۷ 2013-14 Detailed comparative Table

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:

u/s 40A(2)(b) including purchases made from Kanidi Cosmeceuticals and 1,otus Herbals Color Cosmetics. -Vide reply dated 19.11.2015[(@pages 136 to 200 of the paper book, the assessee furnished the following details:  Vide Sr. No.1, the detail of various Marketing expenses recorded under different accounting heads for AY 2010-11 το ۸۷ 2013-14 Detailed comparative Table

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:

u/s 40A(2)(b) including purchases made from Kanidi Cosmeceuticals and 1,otus Herbals Color Cosmetics. -Vide reply dated 19.11.2015[(@pages 136 to 200 of the paper book, the assessee furnished the following details:  Vide Sr. No.1, the detail of various Marketing expenses recorded under different accounting heads for AY 2010-11 το ۸۷ 2013-14 Detailed comparative Table

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:

u/s 40A(2)(b) including purchases made from Kanidi Cosmeceuticals and 1,otus Herbals Color Cosmetics. -Vide reply dated 19.11.2015[(@pages 136 to 200 of the paper book, the assessee furnished the following details:  Vide Sr. No.1, the detail of various Marketing expenses recorded under different accounting heads for AY 2010-11 το ۸۷ 2013-14 Detailed comparative Table

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:

u/s 40A(2)(b) including purchases made from Kanidi Cosmeceuticals and 1,otus Herbals Color Cosmetics. -Vide reply dated 19.11.2015[(@pages 136 to 200 of the paper book, the assessee furnished the following details:  Vide Sr. No.1, the detail of various Marketing expenses recorded under different accounting heads for AY 2010-11 το ۸۷ 2013-14 Detailed comparative Table

COSMIC INFORMATICS PVT. LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE - 2, NEW 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:

u/s 40A(2)(b) including purchases made from Kanidi Cosmeceuticals and 1,otus Herbals Color Cosmetics. -Vide reply dated 19.11.2015[(@pages 136 to 200 of the paper book, the assessee furnished the following details:  Vide Sr. No.1, the detail of various Marketing expenses recorded under different accounting heads for AY 2010-11 το ۸۷ 2013-14 Detailed comparative Table

COSMIC INFORMATICS PVT. LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE - 2, NEW 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:

u/s 40A(2)(b) including purchases made from Kanidi Cosmeceuticals and 1,otus Herbals Color Cosmetics. -Vide reply dated 19.11.2015[(@pages 136 to 200 of the paper book, the assessee furnished the following details:  Vide Sr. No.1, the detail of various Marketing expenses recorded under different accounting heads for AY 2010-11 το ۸۷ 2013-14 Detailed comparative Table

GE NUOVO PIGNONE SPA,GURGAON vs. DCIT (INTERNATIONAL TAXATION), CIRCLE-1(3)(1), NEW DELHI

In the result, appeal filed by assessee stands partly allowed

Bench: Shri Nk Saini & Smt. Beena A Pillaiay: 2009-10 Ge Nuovo Pignone Spa Vs. Dcit, International Taxation C/O 6Th Floor, Building No.7 A Circle 1(3)(1) Standard Chartered Building New Delhi Dlf Cyber City, Phase Iii Gurgaon 122 002 Haryana

u/s 5(2) of the Act, and (b) Income of the Assessee could not be deemed to have accrued or arisen in India under section 9 of the Act read with Explanation thereto. 3.3. The Ld AO erred on the facts and in the circumstances of the case and in law in concluding the assessment proceedings for the impugned year

DCIT, NEW DELHI vs. M/S. DSL SOFTWARE LTD., NEW DELHI

In the result, all the three appeals of the Revenue and cross objection of the assessee are dismissed

Bench: : Shri Amit Shukla & Shri L.P. Sahu

234 ITR 170 (Del), CIT vs. Mittal Casting Ltd. : 124 Taxman 11 (Del) and Anant Raj Industries Ltd. [ITA No. 342/2009 (Del)] ITA Nos. 3722, 3723/Del/2014, 2310/Del/12 & CO. No.258/Del/2012 15 In the facts of the ease of the appellant the claim of deduction under section 80HHE and section 10A of the Act in respect of various undertakings was evident

ACIT, NEW DELHI vs. M/S. DSL SOFTWARE LTD., NEW DELHI

In the result, all the three appeals of the Revenue and cross objection of the assessee are dismissed

Bench: : Shri Amit Shukla & Shri L.P. Sahu

234 ITR 170 (Del), CIT vs. Mittal Casting Ltd. : 124 Taxman 11 (Del) and Anant Raj Industries Ltd. [ITA No. 342/2009 (Del)] ITA Nos. 3722, 3723/Del/2014, 2310/Del/12 & CO. No.258/Del/2012 15 In the facts of the ease of the appellant the claim of deduction under section 80HHE and section 10A of the Act in respect of various undertakings was evident

DCIT, NEW DELHI vs. M/S. DSL SOFTWARE LTD., NEW DELHI

In the result, all the three appeals of the Revenue and cross objection of the assessee are dismissed

Bench: : Shri Amit Shukla & Shri L.P. Sahu

234 ITR 170 (Del), CIT vs. Mittal Casting Ltd. : 124 Taxman 11 (Del) and Anant Raj Industries Ltd. [ITA No. 342/2009 (Del)] ITA Nos. 3722, 3723/Del/2014, 2310/Del/12 & CO. No.258/Del/2012 15 In the facts of the ease of the appellant the claim of deduction under section 80HHE and section 10A of the Act in respect of various undertakings was evident

SUNIL AGARWAL,HARIDWAR vs. ITO, WARD- 1(3)(3), HARIDWAR

In the result, the Appeal filed by the Assessee stands allowed

Bench: Shri H.S. Sidhu & Shri N.K. Billaiyaassessment Year : 2008-09 Sunil Agarwal, Vs. Ito, Ward 1(3)(3), Haridwar Laxmi Niwas, Near Post Office, Kankhal, Haridwar Uttarakhand (Pan: Aanpa0687L) (Appellant) (Respondent)

234 B of the Act which is not leviable on the facts and circumstances of the case of the appellant. It is therefore, prayed that it be held that assessment made by the learned Assessing Officer and sustained by the learned Commissioner of Income Tax (Appeals) deserves to be quashed as such. It be further held addition made and upheld

MAHARASHTRA FEEDS P. LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE, FARIDABAD

In the result, the appeals of the assessee are allowed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

u/s 234A & 234B is hereby rejected. The assessee application on the issue of quantum of interest under section 234C is acceptable as interest under section 234C is levied on return of income filed Maharashtra Feeds P Ltd. under section 245C (1) of the Income Tax Act, 1961. Therefore, the same is rectified.” 4. Aggrieved, the assesee filed appeal before