SURYA JYOTI SOFTWARE PVT. LTD.,NEW DELHI vs. PR. CIT, NEW DELHI

In the result, appeal of the assessee is dismissed

Bench: Shri G. D. Agrawal & Shri Amit Shukla

245 Taxman 127 (SC) 5. Shree Maniunathesware Packing Products & Camphor Works Vs CIT [1998] 96 231 ITR 53 (SC). 16. Regarding challenging the validity of reopening under section 147 by the assessee, on the ground that the proceedings should have been initiated under section 153C, he submitted that the Pr. CIT has dealt with this issue at page

SUNITA BHARDWAJ,NEW DELHI vs. ACIT CIRCLE 63(1), NEW DELHI

u/s 147/148-Held, Section 151 stipulates that CIT (A), who was competent authority to authorize reassessment notice, had to apply his mind and form opinion-Mere appending of expression 'approved' says nothing-It was not as if CIT (A) had to record elaborate reasons for agreeing with noting put up-At same time, satisfaction had to be recorded of given case

SGDC INDIA P. LTD.,NEW DELHI vs. DCIT, CIRCLE- 24(2), DELHI

In the result, all the three appeals filed by the assessee are allowed

Bench: Shri R.K. Panda & Ms Suchitra Kamble

147 and failure to take steps under section 143(3) will not render the Assessing Officer powerless to initiate reassessment proceedings, even when intimation under section 143(1) has been issued. 15. Referring to the decision in the case Yuvraj v. Union of India, 315 ITR 84 he submitted that the Hon’ble Supreme Court in the said decision

SGDC INDIA P. LTD.,NEW DELHI vs. DCIT, CIRCLE- 24(2), DELHI

In the result, all the three appeals filed by the assessee are allowed

Bench: Shri R.K. Panda & Ms Suchitra Kamble

147 and failure to take steps under section 143(3) will not render the Assessing Officer powerless to initiate reassessment proceedings, even when intimation under section 143(1) has been issued. 15. Referring to the decision in the case Yuvraj v. Union of India, 315 ITR 84 he submitted that the Hon’ble Supreme Court in the said decision

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents or assets

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents or assets

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents or assets

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents or assets

SUNITA BHARDWAJ,NEW DELHI vs. ITO WARD 61(1), NEW DELHI

u/s 147/148-Held,\nSection 151 stipulates that CIT (A), who was competent authority to\nauthorize reassessment notice, had to apply his mind and form\nopinion-Mere appending of expression 'approved' says nothing-It was\nnot as if CIT (A) had to record elaborate reasons for agreeing with\nnoting put up-At same time, satisfaction had to be recorded of given\ncase

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

u/s 147/148-Held, Section 151 stipulates that CIT (A), who was competent authority to authorize reassessment notice, had to apply his mind and form opinion-Mere appending of expression 'approved' says nothing-It was not as if CIT (A) had to record elaborate reasons for agreeing with noting put up-At same time, satisfaction had to be recorded of given case

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

u/s 147/148-Held, Section 151 stipulates that CIT (A), who was competent authority to authorize reassessment notice, had to apply his mind and form opinion-Mere appending of expression 'approved' says nothing-It was not as if CIT (A) had to record elaborate reasons for agreeing with noting put up-At same time, satisfaction had to be recorded of given case

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

u/s 147/148-Held, Section 151 stipulates that CIT (A), who was competent authority to authorize reassessment notice, had to apply his mind and form opinion-Mere appending of expression 'approved' says nothing-It was not as if CIT (A) had to record elaborate reasons for agreeing with noting put up-At same time, satisfaction had to be recorded of given case

SANTOSH RANI LEGAL HEIR OF LATE SH PARVEEN KALYAN,KURUKSHETRA vs. INCOME TAX OFFICER, WARD 1, KARNAL, KARNAL

In the result, appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2011-12] Santosh Rani Vs Ito, Legal Heir Of Late Shri Parveen Ward-1, Karnal, Kalyan, Krishna Nagar, Gamri, Haryana-132001. Thanesar, Distt.-Kurukshetra, Haryana-136118. Pan-Awhpr4944D Appellant Respondent Appellant By Shri Suresh K.Gupta, Ca Respondent By Shri Dheeraj Kumar Jaiswal, Sr.Dr Date Of Hearing 01.07.2025 Date Of Pronouncement 19.09.2025 Order

u/s 147/148-Held, Section 151 stipulates that CIT (A), who was competent authority to authorize reassessment notice, had to apply his mind and form opinion-Mere appending of expression 'approved' says nothing-It was not as if CIT (A) had to record elaborate reasons for agreeing with noting put up-At same time, satisfaction had to be recorded of given case

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

reassessment, tax shall be calculated on the aggregate of the total income as assessed in the earlier proceeding for assessment under section 143 or section 144 or section 147 and the income disclosed in the application as if such aggregate were the total income. FORM NO. 34B [See rules 44C and 44CA] Form of application for settlement of case under

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

reassessment, tax shall be calculated on the aggregate of the total income as assessed in the earlier proceeding for assessment under section 143 or section 144 or section 147 and the income disclosed in the application as if such aggregate were the total income. FORM NO. 34B [See rules 44C and 44CA] Form of application for settlement of case under

ACIT, CENTRAL CIRCLE-19, NEW DELHI vs. M/S K.R. PULP & PAPERS LTD,, NEW DELHI

In the result, the appeal of the Revenue is

Bench: Shri R.K. Panda & Shri N.K. Choudhry

245 CTR 623 P & H 16. Nova Promoters &Finiease (P) Ltd 342 ITR 169 (Del.) 17. AZEEM INVESTMENT PVT LTD 252 CTR 0217 Del.) 18. MAJOR METALS LTD 359 ITR 0450 (Bom) 19. INDEPENDENT MEDIA PVT. LTD. 25 taxmann.com 276 (Delhi) 20. NEELKANTHISPAT UDHYOG PVT LTD 81 DTR 0214 21. Frostair P. Ltd 92 DTR 393 (Del). 22. Rajani Hotels

THE KADIYAN COOP. L&C SOCIETY LTD.,PANIPAT vs. ACIT, CIRCLE PANIPAT, PANIPAT

In the result appeal of the assessee is allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishithe Kadiyan Coop L&C Society Vs. Acit, Ltd, Circle Panipat V&Po Sewah, Panipat, Haryana Pan: Aaalt0541R (Appellant) (Respondent)

u/s 80P(2) VI of the Income Tax Act, 1961 to invoke for mutual interest of employment.” 3. The appellant assessee is a cooperative society, which is primarily having object of promoting the economic interest of manual labourers by providing suitable and profitable employment to them by obtaining contract work from government or private. The assessee filed its return

ACIT, CENTRAL CIRCLE- 30, NEW DELHI vs. PARKASH INDUSTRIES LTD, HISAR

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

reassessment under section 147 shall abate.Assessments under section 153A i.e, “Assessment in case of search or requisition” shall not abate by operation of section 153A itself. In the year of search, no notice has to be issued under section 153A consequent to a search. However in the 6 preceding years, notice under 153A has to be mandatorily issued