M/S SURAJ PULSES PVT.LTD.,,DELHI vs. PR. CIT-8, NEW DELHI

In the result, the appeals of the Assessees are allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi

reassessment or assessment order can be challenged in the revisionary proceeding under section 263; and secondly, if any material has been found pertaining to the assessee in the case of person searched or covered u/s 153A, then only recourse was to initiate proceedings under section 153C and not under section 147

M/S SURAJ PULSES PROCESSORS PVT.LTD.,,DELHI vs. PR. CIT-8, NEW DELHI

In the result, the appeals of the Assessees are allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi

reassessment or assessment order can be challenged in the revisionary proceeding under section 263; and secondly, if any material has been found pertaining to the assessee in the case of person searched or covered u/s 153A, then only recourse was to initiate proceedings under section 153C and not under section 147

M/S SURAJ PULSES PVT.LTD.,,DELHI vs. PR. CIT-8, NEW DELHI

In the result, the appeals of the Assessees are allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi

reassessment or assessment order can be challenged in the revisionary proceeding under section 263; and secondly, if any material has been found pertaining to the assessee in the case of person searched or covered u/s 153A, then only recourse was to initiate proceedings under section 153C and not under section 147

M/S. SRI BALAJI FORGINGS (P) LTD.,NEW DELHI vs. PR. CIT- 8, NEW DELHI

In the result, appeal of Assessee is allowed

Bench: Shri Bhavnesh Saini, J.M. & Shri Prashant Maharishi, A.M.

147 of the Income Tax Act, 1961. Therefore, a notice u/s. 148 of the Income Tax Act, 1961 is required to be issued to the assessee company to assess the income escaped as stated hereinabove. As the period to reopen the case exceeds four years and as per records no scrutiny assessment has been done in this case

M/S. SNB ENTERPRISES PVT. LTD.,NEW DELHI vs. PR. CIT- 8, NEW DELHI

In the result ITA No. 2841/Del/2017 is dismissed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishishri Sai City Promoters & Developers Vs. Pr. Cit,8 Pvt Ltd, New Delhi H. No. 25 Block & Pockets C-3, Sector- 11, Rohini, Delhi Pan: Aajcs1878A (Appellant) (Respondent)

reassessment or assessment order can be challenged in the revisionary proceeding under section 263; and secondly, if any material has been found pertaining to the assessee in the case of person searched or covered u/s 153A of the Act, then only recourse was to initiate proceedings under section 153C of the Act and not under section 147

SSE COMMODITIES PVT. LTD.,NEW DELHI vs. PR. CIT- 8, NEW DELHI

In the result ITA No. 2841/Del/2017 is dismissed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishishri Sai City Promoters & Developers Vs. Pr. Cit,8 Pvt Ltd, New Delhi H. No. 25 Block & Pockets C-3, Sector- 11, Rohini, Delhi Pan: Aajcs1878A (Appellant) (Respondent)

reassessment or assessment order can be challenged in the revisionary proceeding under section 263; and secondly, if any material has been found pertaining to the assessee in the case of person searched or covered u/s 153A of the Act, then only recourse was to initiate proceedings under section 153C of the Act and not under section 147

SHREE SAI CITY PROMOTERS AND DEVELOPERS PVT. LTD.,DELHI vs. PR.CIT- 8, NEW DELHI

In the result ITA No. 2841/Del/2017 is dismissed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishishri Sai City Promoters & Developers Vs. Pr. Cit,8 Pvt Ltd, New Delhi H. No. 25 Block & Pockets C-3, Sector- 11, Rohini, Delhi Pan: Aajcs1878A (Appellant) (Respondent)

reassessment or assessment order can be challenged in the revisionary proceeding under section 263; and secondly, if any material has been found pertaining to the assessee in the case of person searched or covered u/s 153A of the Act, then only recourse was to initiate proceedings under section 153C of the Act and not under section 147

SURYA IRRIGATION PVT. LTD.,NEW DELHI vs. PR. CIT- 8, NEW DELHI

In the result ITA No. 2841/Del/2017 is dismissed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishishri Sai City Promoters & Developers Vs. Pr. Cit,8 Pvt Ltd, New Delhi H. No. 25 Block & Pockets C-3, Sector- 11, Rohini, Delhi Pan: Aajcs1878A (Appellant) (Respondent)

reassessment or assessment order can be challenged in the revisionary proceeding under section 263; and secondly, if any material has been found pertaining to the assessee in the case of person searched or covered u/s 153A of the Act, then only recourse was to initiate proceedings under section 153C of the Act and not under section 147

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

263 of the Act on 30.03.2019 and the impugned order which was revised was passed u/s 147 of the act on 30.12.2016. He submitted that reassessment proceedings were initiated for separate reasons. He referred to the reasons recorded under Section

MR. ABHISAR SHARMA,NOIDA vs. DCIT, NEW DELHI

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

Bench: Shri R.K. Panda & Ms Suchitra Kambleassessment Year: 2005-06 Mr. Abhisar Sharma, Vs Dcit, B-602, Plot No.F-2, Circle-64(1), The Crescent, B-Block, Room No.314, Sector-50, Pratyakshkar Bhawan, Noida. Civic Centre, New Delhi. Pan: Aigps3840N (Appellant) (Respondent) Assessee By : Shri Gautam Jain, Advocate & Shri Lalit Mohan, Ca Revenue By : Shri J.K. Mishra, Cit-Dr. Date Of Hearing : 12.01.2021 Date Of Pronouncement : 27.01.2021 Order Per R.K. Panda, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30Th March, 2015 Passed U/S 263 Of The It Act By The Pcit-22, Delhi, Relating To Assessment Year 2005-06. 2. Facts Of The Case, In Brief, Are That The Assessee Is An Individual & Filed His Return Of Income On 22Nd July, 2005 Declaring Income Of Rs.9,00,355/-. The Assessee In The Return Of Income Had Declared Income From Salary At Rs.9,81,964/- & Loss From House Property At Rs.81,609/-. The Return Was Processed U/S 143(1) Of The Act On 4Th July, 2006 At The Same Income. Subsequently, The Case Of The Assessee Was Reopened By Issue Of Notice U/S 148 Of The Act Dated 27Th March, 2012 After Obtaining Prior Approval Of The Addl. Cit, Range-7, New Delhi, Vide His Letter No.526 Dated 27Th March, 2012. The Ao Completed The Assessment U/S 147/143(3) On 28Th March, 2013, Determining The Income Of The Assessee At Rs.11,03,270/- As Against The Returned Income Of Rs.9,00,355/- Wherein He Made The Following Additions:-

147 was initiated against the assessee and his spouse for F.Y.s 2004-05 to 2007-08 relevant to A.Y. 2005-06 to 2008-09 and the status of the aforesaid action is as under:- 8. Referring to the decision of the Tribunal in the case of the wife of the assessee, vide ITA No.3281 to 3284/Del/2015, order dated 11.10.2019, copy

SUNITA SAINI,HARYANA vs. INCOME TAX OFFICER, WARD 1(4), FARIDABAD, HARYANA

In the result, appeal of the Assessee is allowed

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A No.1877/Del/2024 िनधा"रणवष"/Assessment Year:2016-17 बनाम Sunita Saini, Income Tax Officer, House No.743P, Sector-38, Vs. Ward 1(4), Gurugram, Haryana. Faridabad. Pan No.Awmps2317Q अपीलाथ" Appellant ""यथ"/Respondent

section 147 of the Income Tax Act, 1961. In order to assess the above income or any other income which comes to my notice subsequently in the course of assessment proceedings u/s 147, I proceed to initiate proceedings u/s 147 of the I.T. Act, 1961 in the case for A.Y. 2016- 17.” 9. While completing the assessment addition of Rs.2

CHARBUJA MARMO (INDIA) PVT. LTD.,DELHI vs. PR.CIT- 2 , NEW DELHI

In the result, appeal of Assessee allowed

Bench: Shri Bhavnesh Saini & Shri B.R.R. Kumar

147 of the Act, without complying with the statutory conditions and the procedure prescribed under the law, is bad and liable to be quashed, and thus, the same could not have been revised under Section 263 of the Act. 7.(c) On the facts and circumstances of the case, the learned Pr. CIT has erred both on facts

MRS. SHUMANA SEN,NOIDA vs. DCIT, NEW DELHI

In the result, all the four appeals of the assessee in ITA Nos

Bench: Shri N.K. Billaiya & Shri Kuldip Singh

263 as per the findings given in paras-(14)(A) to (14)(J) above, are properly examined vis -a-vis the evidences collected and required to be collected, the claims made by the assessee regarding such evidences and the position of law, so as to ensure that the errors pointed out in this order and the prejudices erased to revenue

MRS. SHUMANA SEN,NOIDA vs. DCIT, NEW DELHI

In the result, all the four appeals of the assessee in ITA Nos

Bench: Shri N.K. Billaiya & Shri Kuldip Singh

263 as per the findings given in paras-(14)(A) to (14)(J) above, are properly examined vis -a-vis the evidences collected and required to be collected, the claims made by the assessee regarding such evidences and the position of law, so as to ensure that the errors pointed out in this order and the prejudices erased to revenue

MRS. SHUMANA SEN,NOIDA vs. DCIT, NEW DELHI

In the result, all the four appeals of the assessee in ITA Nos

Bench: Shri N.K. Billaiya & Shri Kuldip Singh

263 as per the findings given in paras-(14)(A) to (14)(J) above, are properly examined vis -a-vis the evidences collected and required to be collected, the claims made by the assessee regarding such evidences and the position of law, so as to ensure that the errors pointed out in this order and the prejudices erased to revenue

MRS. SHUMANA SEN,NOIDA vs. DCIT, NEW DELHI

In the result, all the four appeals of the assessee in ITA Nos

Bench: Shri N.K. Billaiya & Shri Kuldip Singh

263 as per the findings given in paras-(14)(A) to (14)(J) above, are properly examined vis -a-vis the evidences collected and required to be collected, the claims made by the assessee regarding such evidences and the position of law, so as to ensure that the errors pointed out in this order and the prejudices erased to revenue

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

reassessment or assessment order can be challenged in the revisionary proceeding under section 263; and secondly, if any material has been found pertaining to the assessee in the case of person searched or covered u/s 153A, then only recourse was to initiate proceedings under section 153C and not under section 147

MIKADO REALTORS (P) LTD,NEW DELHI vs. PR. CIT (CENTRAL), GURUGRAM

In the result, the appeal of the assessee is allowed

Bench: Shri Amit Shukla & Shri O.P. Kant

147, that was the subject matter of revision under section 263 itself is an invalid order. We do not think that the Tribunal has any such power to consider the validity of any such order, while considering the appeal filed against the order issued by the Commissioner under section 263. The assessee having not challenged the revised assessment, cannot also