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

DHARAMVIR KHOSLA ,. vs. DCIT CC-5, NEW DELHI , .

The appeals are allowed for statistical purposes and ld

251/- and Shipra Estate\nLimited and Jaikishan Estate Developers have not deposited Rs.8,21,530/-. Thus,\nPage | 9\nITA Nos. 3976 & 3977/Del/2025\nDharamvirKhosla (AY: 2019-20 & 2020-21)\ntotaling Rs.17,03,974/- was though deducted but not deposited. Due to which\ncredit was not allowed while computing the tax.”\n8.\nThe ld. DR has primarily relied the decision of Bangalore

M/S GINNI GOLDLIMITED,NEW DELHI vs. ACIT, NEW DELHI

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

Bench: Shri R.K. Panda & Ms. Suchitra Kambleassessment Year : 2009-10

147 of the act have been taxed remained untaxed, and there is an escapement of income, as a result of the assessee's failure to disclose fully and truly all material facts necessary for computation of income 17. In the same decision honourable Delhi High court after considering the provision of section 251(1) (a) of the act further held

EBRO INDIA PVT.LTD. ,DELHI vs. ACIT CIRCLE-7(1), DELHI

In the result, the ground no 4 raised by the assessee is allowed

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

251 ITR 263 upheld the decision of the Delhi High Court, stating that there can be no addition in the hands of a company for moneys received towards share capital. The Court held that, if necessary, the Revenue may reopen the assessment of the shareholders to bring to tax the alleged undisclosed amount.  CIT v. ARL Infratech

HURON BUILDERS PVT LTD,NEW DELHI vs. ITO WARD - 6(1), NEW DELHI

In the result the appeal is allowed on this preliminary

Bench: Shri Amit Shukla & Shri Anadee Nath Misshra

reassessment proceedings for the assessment year 2013-14. (PB page 55 to 66) (vii) 13.12.2017 Petition under section 144A filed before Jt.CIT/Addl.CIT for seeking direction on validity of initiation of proceedings under section 147 for the assessment year 2013-14 (year under appeal). (PB page 67 to 70) 6 I.T.A. No.6251/DEL/2019 (viii) 19.12.2017 Rejoinder submitted on this date, before

PR. COMMISSIONER OF INCOME TAX-19 vs. SHRI ANKUR AGGARWAL

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE NAJMI WAZIRI

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

PR. COMMISSIONER OF INCOME TAX-19 vs. SHRI ANKUR AGGARWAL

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE NAJMI WAZIRI

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

PR. COMMISSIONER OF INCOME TAX-19 vs. SHRI NEERAJ JINDAL

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE NAJMI WAZIRI

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

DHARAMVIR KHOSLA,. vs. DCIT CC-5, NEW DELHI , .

The appeals are allowed for statistical purposes and ld

251/- and Shipra Estate\nLimited and Jaikishan Estate Developers have not deposited Rs.8,21,530/-. Thus,\nPage | 10\nITA Nos. 3976 & 3977/Del/2025\nDharamvirKhosla (AY: 2019-20 & 2020-21)\ntotaling Rs.17,03,974/- was though deducted but not deposited. Due to which\ncredit was not allowed while computing the tax.”\n8.\nThe ld. DR has primarily relied the decision of Bangalore

ANIL KUMAR JAIN,NEW DELHI vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-26, JHANDEWALAN, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

reassessment u/s 148 qua genuineness of unsecured loan as well as purchases disclosed, considered and accepted during the original assessment under Section 143(3) of the Income Tax Act, 1961 for AY 2013-14 2. On the facts and circumstances of the case, the impugned order dated 10th December 2024 passed by the CIT(A) as well as order dated

BSES YAMUNA POWER LTD.,NEW DELHI vs. DCIT, CIRCLE- 5(1), NEW DELHI

The appeal of the assessee is allowed on legal issues

Bench: Shri Anubhav Sharma & Shri Manish Agarwalbses Rajdhani Power Ltd., Dy. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd., Asst. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Yamuna Power Dy. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd. & Ors Vs. Acit Bses Yamuna Power Asst. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv., Sh. Deepesh Jain, Adv. & Sh. Shivam Gupta, Ca Department By Mr. Javed Akhtar, Cit-Dr Date Of Hearing 20/02/2025 Date Of Pronouncement 16/04/2025 O R D E R

u/s 148 which are as under: GOA No. 3 to 3.4-Validity of re-assessment proceedings 24. In the present case, reassessment proceedings under section 147/148 of the Act were initiated by the assessing officer vide notice dated 31.03.2014, ie, much beyond the period of 4 years and almost at the fag-end of the overall limitation period

BSES YAMUNA POWER LTD,DELHI vs. ACIT, CIRCLE-5(1), NEW DEL;HI

The appeal of the assessee is allowed on legal issues

Bench: Shri Anubhav Sharma & Shri Manish Agarwalbses Rajdhani Power Ltd., Dy. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd., Asst. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Yamuna Power Dy. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd. & Ors Vs. Acit Bses Yamuna Power Asst. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv., Sh. Deepesh Jain, Adv. & Sh. Shivam Gupta, Ca Department By Mr. Javed Akhtar, Cit-Dr Date Of Hearing 20/02/2025 Date Of Pronouncement 16/04/2025 O R D E R

u/s 148 which are as under: GOA No. 3 to 3.4-Validity of re-assessment proceedings 24. In the present case, reassessment proceedings under section 147/148 of the Act were initiated by the assessing officer vide notice dated 31.03.2014, ie, much beyond the period of 4 years and almost at the fag-end of the overall limitation period

ADDL. CIT, NEW DELHI vs. M/S. IRCON INTERNATIONAL LTD., NEW DELHI

In the result, the appeal of the Revenue is accordingly dismissed

Bench: Shri Amit Shukla & Shri O.P. Kant[Through Video Conferencing]

1) of section 142 or section 148 or to disclose truly and fully all material facts necessary for his assessment for that assessment year. It is also noted that the scope of newly substituted (w.e.f. 01/04/1989) section 147 has been elaborated in department circular number 549 dated 31st October, 1989, meaning thereby, on or after 01/04/ 1989, initiation of reassessment

PASSION REALTECH PVT LTD,GURGAON vs. ;ACIT, CENTRAL CIRCLE-2, FARIDABAD

In the result, Appeals in ITA

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

251 (Guj) and CIT Vs. Mahavir Crimpers, 95 Taxman.com 323 (Guj) have held that when the Department has accepted the factum of repayment, the additions under Section 68 is not sustainable in law. Similar view has been expressed in CIT Vs. Karaj Singh (2011) 15 Taxmann.com 70 (P&H) &Panna Devi Chowdhary

PASSION REALTECH PVT LTD,GURGAON vs. ACIT, CENTRAL CIRCLE-2, FARIDABAD

In the result, Appeals in ITA

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

251 (Guj) and CIT Vs. Mahavir Crimpers, 95 Taxman.com 323 (Guj) have held that when the Department has accepted the factum of repayment, the additions under Section 68 is not sustainable in law. Similar view has been expressed in CIT Vs. Karaj Singh (2011) 15 Taxmann.com 70 (P&H) &Panna Devi Chowdhary

LENIENT CONSULTANTS PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-2, NOIDA

In the result, the appeal of the Assessee is partly allowed\nas indicated above

251)\n4.\nHon'ble Apex Court in case of PCIT vs. Anuj Bansal approving\nabove Hon'ble Delhi High Court order reported at 466 ITR 254\n5.\nHon'ble Delhi High Court in case of PCIT vs. MDLR Hotels Pvt. Ltd.\nITA 593/2023 (30.07.2024) approving ITAT impugned order on sec.\n153D.\n6.\nHon'ble Delhi High Court in case

SURESH CHAND BANSAL,HARYANA vs. ACIT, CENTRAL CIRCLE-16 , DELHI

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

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

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

AMIT BANSAL,HARYANA vs. ACIT, CENTRAL CIRCLE-16, DELHI

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

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

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

AMIT BANSAL,HARYANA vs. ACIT CENTRAL CIRCLE-16, DELHI

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

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

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