SMT. RAJ BALA,DELHI vs. ITO, NEW DELHI

In the result, all the four appeals filed by the respective assessees are allowed

Bench: Shri R.K. Panda & Shri Amit Shukla

section 139(4) of the Income Tax Act, the assessee was required to furnish the return upto 31.03.2012 alongwith penalty u/s 271F & other consequential actions. However, since the assessee failed to stick any of the above mandatory schedule of filing of her Income Tax return the above mentioned return was treated as invalid being time-barred. Penalty Notice u/s 271F

SIMRANPAL SINGH SURI,NEW DELHI vs. ITO WARD 45(5), NEW DELHI

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

Bench: Shri R.K. Pandaassessment Year: 2010-11 Simranpal Singh Suri, Vs Ito, Jg-1/77, Vikaspuri, Ward 45(5), New Delhi. New Delhi. Pan: Akzps3760Q (Appellant) (Respondent) Assessee By : Shri V.K. Sabharwal, Advocate Revenue By : Shri Farath Khan, Sr. Dr Date Of Hearing : 15.03.2021 Date Of Pronouncement : 12.05.2021 Order

section 147 of the Income Tax Act, 1961. It is pertinent to mention that in the case of Raymond Woollen Mills Ltd. 236 ITR 34 (SC), the Hon’ble Apex court has held that in determining whether commencement of reassessment proceedings was valid it has only to be seen whether there was prima facie some material on the basis

DEEPAK KUMAR GUPTA,KANPUR vs. ITO WARD 2(1), MORADABAD, MORADABAD

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

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2014-15 Deepak Kumar Gupta, Vs. Income Tax Officer, 7/115, Flat No. B-1, Sai Niwas, Ward 2(1), Arya Nagar, Kanpur - 208020 Moradabad ( U.P) Uttar Pradesh. Pin: 244 001 Pan :Acmpg1836E (Appellant) (Respondent)

Section 271(1)(c) and 271F of the Act were initiated. 3. Against order dated 29.03.2022 of Ld. AO, the appellant/assessee preferred appeal before the Ld. CIT(A) which was partly allowed vide order dated 20.08.2024. 4. Being aggrieved, the appellant/assessee preferred present appeal with following Grounds of Appeal: “1. That the Ld. CIT(A) NFAC has grossly erred both

TRANS WORLD INTERNATIONAL LLC,WILMINGTON, DELAWARE, USA vs. DEPUTY COMMISSIONER OF INCOME TA, CIRCLE 3(1)(1), INTERNATIONAL TAXATION, CIVIC CENTRE, NEAR MINTO ROAD, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

reassessment order passed by the Ld. Deputy Commissioner of Income-tax, Circle 3()O), International Taxation, New Delhi (Ld. AO') under section 147 read with section 144C(13) of the Income Tax Act, 1961 (the Act), in pursuance to the directions of the Learned Dispute Resolution Panel - 2, New Delhi (Ld. DRP'), assessing the income of the Appellant

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

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 of Mauritius as an investment holding company for making investments and holding them on a long- term basis. The Assessee is a tax resident of Mauritius

NAMITA TIWARI,MUMBAI vs. ITO, WARD 2(1), FARIDABAD

In the result, appeal of the assessee is allowed

Bench: Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.2980/Del/2023 िनधा"रणवष"/Assessment Year: 2012-13

section 271F particularly when, the quantum appeal of the appellant is pending with CIT(A). I.T.A.No.2980/Del/2023 2. On the facts and circumstances of the case the learned CIT(A) has also erred in confirming penalty of Rs. 5,000/- particularly when, the appellant has proved that investment in flat was made by her husband by producing his bank statements

DEEP KOTHARI,USA vs. ASSSISTANT COMMISSIONER OF INCOME TAX, CIVIC CENTRE NEW DELHI

Appeal is partly allowed

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

u/s 147 r.w.s. 144C(13) of the Income Tax Act, 1961 (in short “the Act”). 2. Heard both the parties at length. Case file perused. 3. The assessee pleads the following substantive grounds in the instant appeal: 2 Deep Kothari “1. That on facts and circumstances of the case and in law the impugned order dated 13.03.2024 passed under section

TRANS WORLD INTERNATIONAL LLC,WILMINGTON, DELAWARE, USA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(1)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, the appeal of the assessee is allowed

reassessment order passed by the Ld. Deputy\nCommissioner of Income-tax, Circle 3()O), International Taxation,\nNew Delhi (Ld. AO') under section 147 read with section\n144C(13) of the Income Tax Act, 1961 (the Act), in pursuance to\nthe directions of the Learned Dispute Resolution Panel - 2, New\nDelhi (Ld. DRP'), assessing the income of the Appellant

TRANS WORLD INTERNATIONAL LLC,DELAWARE, USA vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE (INTERNATIONAL TAXATION) - 3(1)(1), NEW DELHI

In the result, the appeal of the assessee is allowed

reassessment order passed by the Ld. Deputy\nCommissioner of Income-tax, Circle 3()O), International Taxation,\nNew Delhi (Ld. AO') under section 147 read with section\n144C(13) of the Income Tax Act, 1961 (the Act), in pursuance to\nthe directions of the Learned Dispute Resolution Panel - 2, New\nDelhi (Ld. DRP'), assessing the income of the Appellant

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

DCIT CENTRAL CIRCLE-32, DELHI vs. RNB INTERNATIONAL PVT. LTD., DELHI

26. In view of the above discussion and findings, appeal- ITA No

Bench: Shri Shamim Yahya & Shri Narinder Kumarm/S Rnb International Private Vs. Dcit, Central Circle-32, Delhi Limited, Rnb House, 1, Shivaji Enclave, Main Road, Near Raja Garden, Opp. Mother Dairy, Delhi- 110027 Pan :..Aaccr7687L (Appellant) (Respondent) & Ita/845/Del/2022 Deputy Commissioner Of Income Vs. M/S. Rnb International Pvt. Limited, Tax, Rnb House, 142A/2, Noida, Sez, Central Circle-32, New Delhi Noida- Dadri Road, U.P. 201305 (Appellant) (Respondent)

271F of the Act. Thereupon, vide letter dated 20.12.2019, AR of the assessee submitted certain details before the Assessing Officer. Ultimately the Assessing Officer proceeded to finalize the assessment on merits. 10. It may be mentioned here that vide notice u/s 142(1) of the Act and the detailed questionnaire dated 23.10.2019, the Assessing Officer had asked the assessee

RNB INTERNATIONAL PVT. LTD.,DELHI vs. DCIT CENTRAL CIRCLE-32, DELHI

26. In view of the above discussion and findings, appeal- ITA No

Bench: Shri Shamim Yahya & Shri Narinder Kumarm/S Rnb International Private Vs. Dcit, Central Circle-32, Delhi Limited, Rnb House, 1, Shivaji Enclave, Main Road, Near Raja Garden, Opp. Mother Dairy, Delhi- 110027 Pan :..Aaccr7687L (Appellant) (Respondent) & Ita/845/Del/2022 Deputy Commissioner Of Income Vs. M/S. Rnb International Pvt. Limited, Tax, Rnb House, 142A/2, Noida, Sez, Central Circle-32, New Delhi Noida- Dadri Road, U.P. 201305 (Appellant) (Respondent)

271F of the Act. Thereupon, vide letter dated 20.12.2019, AR of the assessee submitted certain details before the Assessing Officer. Ultimately the Assessing Officer proceeded to finalize the assessment on merits. 10. It may be mentioned here that vide notice u/s 142(1) of the Act and the detailed questionnaire dated 23.10.2019, the Assessing Officer had asked the assessee

FR. SAUTER AG,NEW DELHI vs. ITO WARD INTERNATIONAL TAX 1(3)(2), NEW DELHI

In the result, the Appeal in ITA No

Bench: Shri Shamim Yahya & Shri Kul Bharat[Assessment Year : 2012-13]

Reassessment proceedings are bad-in- law 1.1. On the facts and in the circumstances of the case and in law, the Ld. AO has erred in initiating the re-assessment proceedings under the Act in respect of AY 2012-13, in the absence of any income escaping assessment. 1.2. On the facts and circumstances of the case

BHAGIRATHI KRISHNAN,NEW DELHI vs. ITO WARD 35(5), NEW DELHI

Bench: Shri Pawan Singh(Physical Hearing) Bhagirathi Krishnan, Income Tax Officer, Ward-35(5), C/O-Anil Jain Dd & Co. 611, 6Th Floor, Vs Civic Centre, Surya Kiran Building, 19- K.G. Marg, New Delhi-110002 New Delhi-110001 Pan:Aqzpk1479J Appellant / Assessee Respondent / Revenue

147 is illegal, bad in law, without jurisdiction and time barred and thus assessment order passed requires to be quashed. 2. That on the facts and circumstances of the case and the provision of law, the notice issued under section 148A(b), the order passed under section 148A(d), and the consequential notice issued under section 148 of the Income