COMPAREX INDIA P.LTD,NEW DELHI vs. ITO, CIRCLE-4(2), NEW DELHI

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

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

270A of the Act in the final assessment order passed for relevant AY.” 5. Further, assessee filed following additional grounds of appeal with the application under Rule 11 of the ITAT Rules, 1962:- “Pertaining to Transfer Pricing matters 16. On facts and circumstances of the case and in law, the Ld. AO erred by not passing the final assessment order

AEP INVESTMENTS (MAURITIUS) LIMITED,MAURITIUS vs. ACIT CIRCLE INTL. TAXATION 1(1)(1), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Kul Bharat & Dr. B. R. R. Kumar

270A of the Act. 10. That on the facts and in the circumstances of the case, the assessing officer has erred in initiating penalty proceedings under section 271F of the Act. 3 AEP Investments (Mauritius) Ltd. 3. M/s AEP Investments(Mauritius) Limited. (AIML) is a company incorporated in Mauritius on 15.07.2008. The Company is set-up under the laws

BOOKING.COM B.V.,THE NETHERLANDS vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE 1(1)(2), INTERNATIONAL TAXATION, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri M Balaganesh & Shri Vimal Kumarbooking.Com B.V. Vs. Acit, Circle -1(1)(2) Oosterdokskade 163, International Taxation, 1011 Dl, Amsterdam, The Civic Centre, Minto Road, Netherlands, New Delhi – 110002 Haryana 122002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aagcb2395A Appellant .. Respondent

U/s 148A/148/147 have been wrongly initiated. 4. On considering the replies ld. AO passed draft assessment order dated 29.03.2024. The assessee filed objections to the draft assessment order on 26.04.2024 before ld. DRP under Section 144C(5) of the Act. Through, order dated 31.12.2024 DRP-1, New Delhi, rejected objections of the assessee and P a g e | 6 Booking.com

ACIT, NEW DELHI vs. FILATAX INIDA LIMITED, DELHI

section 148A. The\n\nrelevant observations of the hon'ble high court as contained in para 29\nto 32 of the order reads as under:\n\n29. In our considered opinion, and bearing in mind the import of Explanation 3\nas well as the language in which Section 147 of the Act stands couched,\nwe find no justification to differ

DEEP MALIK,NEW DELHI vs. ACIT, CIRCLE 2(2)(1), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Saktijit Dey, Hon’Ble & Dr. B. R. R. Kumar

section 144C(15) was prospective and not retrospective 2. That on facts and circumstances of the case and in law, the issuance of notice u/s 148 dated 28.03.2021 and reopening proceedings u/s 147 only for verification is illegal, invalid and void ab initio and merits quashing 2 Deep Malik 3. That the AO grossly erred in law by not providing

COMPUTER MODELLING GROUP LIMITED,CANADA vs. ACIT INTERNATIONAL TAXATION CIRCLE 1(2)(1), NEW DELHI

In the result, all the four appeals of the assessee for AY 2012-13,

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

147 of the Act. The Ld. CIT (A) also held reassessment proceedings under sections 147/148 of the Act as valid. 5.2 On the issue of addition, the Ld. CIT (A) concurred with the directions dated 19.04.2023 of the Ld. DRP in respect of similar addition made in AY 2019-20 and 2020-21 wherein the decision of Hon'ble Supreme

COMPUTER MODELLING GROUP LIMITED,CANADA vs. ACIT, CIRCLE-1(2)(1), INT. TAXATION, NEW DELHI

In the result, all the four appeals of the assessee for AY 2012-13,

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

147 of the Act. The Ld. CIT (A) also held reassessment proceedings under sections 147/148 of the Act as valid. 5.2 On the issue of addition, the Ld. CIT (A) concurred with the directions dated 19.04.2023 of the Ld. DRP in respect of similar addition made in AY 2019-20 and 2020-21 wherein the decision of Hon'ble Supreme

COMPUTER MODELLING GROUP LIMITED,CANADA vs. DCIT CIRCLE INTERNATIONAL TAXATION 1(2)(1), NEW DELHI

In the result, all the four appeals of the assessee for AY 2012-13,

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

147 of the Act. The Ld. CIT (A) also held reassessment proceedings under sections 147/148 of the Act as valid. 5.2 On the issue of addition, the Ld. CIT (A) concurred with the directions dated 19.04.2023 of the Ld. DRP in respect of similar addition made in AY 2019-20 and 2020-21 wherein the decision of Hon'ble Supreme

ATAAT RAHAT KHAN,GURGAON vs. DCIT/ACIT-INT-TAX GURGAON, GURGAON

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh[Assessment Year: 2017-18]

u/s 147 r.w.s 144 of the Income Tax Act, 1961 (hereinafter ‘the Act’). 2. Grounds of appeal raised by the assessee are as under:- 1. That on the facts and circumstances of the case and in law, the notice under Section 148 of the Income-tax Act, 1961 ("the Act") is illegal, bad in law and without jurisdiction. 2. That

HARISH BANGA,HISAR vs. ASSESSMENT UNIT, NEW DELHI

In the result, both the substantial ground of appeal is allowed

Bench: Shri Pawan Singhassessment Year: 2018-19 (Physical Hearing) Harish Banga, Assessment Unit, 264, Bank Colony, Hisar, Vs. Faceless Assessment Unit Haryana – 125001. Income Tax Department, Pan – Abqpb 8845 F New Delhi-110001. (Appellant) (Respondent) Present For: Assessee By : Shri H.K. Batra, Ca & Shri Naman Chawla, Ca Revenue By : Shri Virender Kumar Singh, Sr. D.R. Date Of Hearing : 04.12.2025 Date Of Pronouncement : 19.12 .2025 O R D E R Per : Pawan Singh: This Appeal By The Assessee Is Directed Against The Order Of Cit (A) Dated 08.07.2025 Vide Assessment Year 2018-19. The Assessee Has Raised Following Grounds Of Appeal:-

147 read with section 148A of the Act, which was invalid and without jurisdiction. 1.2 The Ld. CIT(A) failed to appreciate that the Assessing Officer (AO) did not have tangible material or credible information to form a reasonable belief that income chargeable to tax had escaped assessment. The reliance on "flagged information" from the Insight Portal under the head

ITO, WARD-1(1), FARIDABAD, FARIDABAD vs. CHAMAN, FARIDABAD

In the result, appeal of the assessee is allowed

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2017-18 Vs. Chaman, Income Tax Officer, Ward-1(1), H. No. 437, Sector-9, Faridabad Faridabad Pan: Bfapd6698P (Appellant) (Respondent) With C.O. No.103/Del/2024 [Arising Out Of Ita No.2774/Del/2024] Assessment Year: 2017-18 Vs. Income Tax Officer, Chaman, H. No. 437, Sector-9, Ward-1(1), Faridabad, Haryana Faridabad Pan: Bfapd6698P (Appellant) (Respondent) Assessee By Sh. Gaurav, Adv. Department By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 25.06.2025 Date Of Pronouncement 25.06.2025 Order Per Satbeer Singh Godara, Jm This Revenue’S Appeal Ita No. 2774/Del/2024 & Assessee’S Cross Objection C.O. No. 103/Del/2024 For Assessment Year 2017- 18, Arises Against The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre [In Short, The

147 r.w.s. 144 of the Income- tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case files perused. 2. This Revenue’s appeal ITA No.2774/Del/2024 raises the following substantive grounds: 1. "Whether, on the facts and circumstances of the case and law, the Ld.CIT (A) erred in deleting the addition

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)

270A of the Act.” 11. On the other hand, ld. DR for the Revenue argued the matter and filed the written submissions which are reproduced below :- “After the introduction of faceless assessment scheme, lot of legislative changes were also made in the Income Tax Act, for example till 31.03.2022 the NeAC was mandated to pass all the assessment orders. From

A K ENTERPRISES ,DELHI vs. ITO WARD 35(5), DELHI

In the result, appeal of the assessee is dismissed

Bench: Sh. Sudhir Kumar & Sh. Manish Agarwalassessment Year: 2019-20

147 r.w.s. 144 & 144B on 02-02-2024 further becomes non-est, because of the non-receipt /service of any notice u/s 148 along with the other statutory notices claimed to be issued u/s 142(1) of the Income Tax Act 1961 prior to pass the ex-parte assessment order on 02- 02-2024, because of sending the same

SMS GROUP GMBH,DELHI vs. ACIT.CIRCLE-3(1)(2), NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri M. Balaganesh & Shri Vimal Kumar

147 of the Act. 10.2 I have also gone through copies of invoices pertaining to receipts from Jindal Steel and Power Ltd. and it is seen that receipt of 949,600 Euro (Rs. 5,27,63,546) pertains to supply of equipment for an Electric Arc Furnace. The other two receipts of 235,000 and 30,600 Euros amounting

SMS GROUP GMBH,NEW DELHI vs. ACIT, CIRCLE-3(1)(2), INT. TAXATION, NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri M. Balaganesh & Shri Vimal Kumar

147 of the Act. 10.2 I have also gone through copies of invoices pertaining to receipts from Jindal Steel and Power Ltd. and it is seen that receipt of 949,600 Euro (Rs. 5,27,63,546) pertains to supply of equipment for an Electric Arc Furnace. The other two receipts of 235,000 and 30,600 Euros amounting

SMS GROUP GMBH,NEW DELHI vs. ACIT, CIRCLE-3(1)(2) INT. TAXATION, NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri M. Balaganesh & Shri Vimal Kumar

147 of the Act. 10.2 I have also gone through copies of invoices pertaining to receipts from Jindal Steel and Power Ltd. and it is seen that receipt of 949,600 Euro (Rs. 5,27,63,546) pertains to supply of equipment for an Electric Arc Furnace. The other two receipts of 235,000 and 30,600 Euros amounting

SMS GROUP GMBH,NEW DELHI vs. ACIT CIRCLE - 3(1)(2) INTL. TAXATION, NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri M. Balaganesh & Shri Vimal Kumar

147 of the Act. 10.2 I have also gone through copies of invoices pertaining to receipts from Jindal Steel and Power Ltd. and it is seen that receipt of 949,600 Euro (Rs. 5,27,63,546) pertains to supply of equipment for an Electric Arc Furnace. The other two receipts of 235,000 and 30,600 Euros amounting

SMS GROUP GMBH,NEW DELHI vs. ACIT, CIRCLE 3(1)(2), INTERNATIONAL TXATION, NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri M. Balaganesh & Shri Vimal Kumar

147 of the Act. 10.2 I have also gone through copies of invoices pertaining to receipts from Jindal Steel and Power Ltd. and it is seen that receipt of 949,600 Euro (Rs. 5,27,63,546) pertains to supply of equipment for an Electric Arc Furnace. The other two receipts of 235,000 and 30,600 Euros amounting