ACIT, NEW DELHI vs. SH. VALMIK THAPAR, NEW DELHI

Appeals are disposed of by this common order as indicated above

Bench: Hon’Ble Justice P.P. Bhatt & Shri Prashant Maharishi(Through Video Conferencing) Shri Valmik Thapar, Vs. Acit, 19, Kautilya Marg, Circle-53(1), New Delhi New Delhi (Appellant) (Respondent) Shri Valmik Thapar, Vs. Dcit, M/S. R. N. Khanna & Company, Ca, Circle-32(1), 14-15F, Shivam House, Connaught New Delhi Place, New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Acit, Vs. Shri Valmik Thapar, Circle-53(1), 19, Kautilya Marg, New Delhi New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Assessee By : Shri Salil Agarwal, Senior Advocate Along With Shri Shailesh Gupta, Shri Mahur Agarwal, Advocates Revenue By: Shri H. K. Choudhary, Cit Dr Date Of Hearing 11/06/2021 (Last Hearing) Date Of Pronouncement 11/06/2021. O R D E R Per Prashant Maharishi, A. M. 1. These Are Three Appeals For Two Assessment Years Pertaining To One Assessee, Mr. Valmik Thapar, A Resident, Individual [Assessee]. Assessee Filed Ita Number

35. Learned authorised representative reiterated the original submission made by him with respect to the availability of deduction u/s 54EC of the act and for the purpose of deduction Under Section 54 of the income tax act, he relied on the decision of the honourable madras High Court. Queries by the Bench 36. Coordinate bench then raised the query

SHRI VALMIK THAPAR,NEW DELHI vs. DCIT, NEW DELHI

Appeals are disposed of by this common order as indicated above

Bench: Hon’Ble Justice P.P. Bhatt & Shri Prashant Maharishi(Through Video Conferencing) Shri Valmik Thapar, Vs. Acit, 19, Kautilya Marg, Circle-53(1), New Delhi New Delhi (Appellant) (Respondent) Shri Valmik Thapar, Vs. Dcit, M/S. R. N. Khanna & Company, Ca, Circle-32(1), 14-15F, Shivam House, Connaught New Delhi Place, New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Acit, Vs. Shri Valmik Thapar, Circle-53(1), 19, Kautilya Marg, New Delhi New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Assessee By : Shri Salil Agarwal, Senior Advocate Along With Shri Shailesh Gupta, Shri Mahur Agarwal, Advocates Revenue By: Shri H. K. Choudhary, Cit Dr Date Of Hearing 11/06/2021 (Last Hearing) Date Of Pronouncement 11/06/2021. O R D E R Per Prashant Maharishi, A. M. 1. These Are Three Appeals For Two Assessment Years Pertaining To One Assessee, Mr. Valmik Thapar, A Resident, Individual [Assessee]. Assessee Filed Ita Number

35. Learned authorised representative reiterated the original submission made by him with respect to the availability of deduction u/s 54EC of the act and for the purpose of deduction Under Section 54 of the income tax act, he relied on the decision of the honourable madras High Court. Queries by the Bench 36. Coordinate bench then raised the query

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

35-40), and the provisions of Section 150 of the Act. The assessee, while supporting the ultimate relief granted, is aggrieved by the directions given by the 14 CIT(A) in his order suggesting the AO initiate proceedings under Section 147/148 of the Act. The assessee therefore before us by preferring the present Cross-Objection to challenge the dis that

BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE-18, DELHI

In the result, the appeals of the revenue in ITA No

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

35-40), and the provisions of Section 150 of the Act. The assessee, while supporting the ultimate relief granted, is aggrieved by the directions given by the 14 CIT(A) in his order suggesting the AO initiate proceedings under Section 147/148 of the Act. The assessee therefore before us by preferring the present Cross-Objection to challenge the dis that

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

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

In the result, all the appeals for Assessment Years 2013-14 to 2022-23 in ITA

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 4153 & 4008/Del/2025 (Assessment Year: 2012-13 & 2018-19) Dcit, Proform Interiors Pvt. Ltd., Central Circle-20, Ground Floor, Jmd Regent Room No. 269A, 2Nd Floor, Vs. Plaza, Mg Road, Gurgaon, Ara Centre, Jhandewalan Haryana-122001. Extn., Delhi-110055. Pan-Aahcs5999J

1). It empowers the AO to scrutinize that return if he considers that income has been understated or tax was underpaid. However, when a search u/s 132 takes place and materials are found indicating possible escapement of income, the statute envisages a different route for carrying out assessment or reassessment u/s 147 r.w.s. 148 which is special mechanism for bringing

MAHESH KUMAR,DELHI vs. ITO,WARD-68(6), DELHI

In the result, Ground no. 3 as raised by the assessee deserves to be allowed and the impugned addition cannot be sustained

Bench: Justice (Retd.) C.V. Bhadang(), Shri Mahavir Singh & Shri Brajesh Kumar Singh[Assessment Year: 2012-13] Mahesh Kumar, Vs Ito, 6/305/1A, Doonger Ward-68(6), Mohalla, Delhi-110032. Delhi. Pan-Aoopk6335A Appellant Respondent Appellant By Shri Neeraj Mangla, Ca Respondent By Shri Krishna K. Ramawat, Sr. Dr Date Of Hearing 06.08.2025 Date Of Pronouncement 06.08.2025

1) Limited reported 331 ITR 236 (Bom) and Ranbaxy Laboratories Ltd. reported in 336 ITR 136 (Del) on facts in the instant case? 5.1. As discussed earlier in para no.3.6 of this order, the Kolkata Tribunal had granted relief to the assessee by quashing the reassessment proceedings u/s 147/148 of the Act on the ground that the issue on which

INCOME TAX OFFICER, WARD 3(1), DELHI, DELHI vs. ARTISTIC FINANCE PRIVATE LIMITED, DELHI

In the result, Ground no. 3 as raised by the assessee deserves to be allowed and the impugned addition cannot be sustained

Bench: Justice (Retd.) C.V. Bhadang(), Shri Mahavir Singh & Shri Brajesh Kumar Singh[Assessment Year: 2012-13] Mahesh Kumar, Vs Ito, 6/305/1A, Doonger Ward-68(6), Mohalla, Delhi-110032. Delhi. Pan-Aoopk6335A Appellant Respondent Appellant By Shri Neeraj Mangla, Ca Respondent By Shri Krishna K. Ramawat, Sr. Dr Date Of Hearing 06.08.2025 Date Of Pronouncement 06.08.2025

1) Limited reported 331 ITR 236 (Bom) and Ranbaxy Laboratories Ltd. reported in 336 ITR 136 (Del) on facts in the instant case? 5.1. As discussed earlier in para no.3.6 of this order, the Kolkata Tribunal had granted relief to the assessee by quashing the reassessment proceedings u/s 147/148 of the Act on the ground that the issue on which

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

The appeals are allowed for statistical purposes and ld

35,500/-. In this\nconnection, your kind attention is invited to the decisions of Delhi High court\nin the case of Chintan Bindra versus DCIT 158 taxmann.com 27 (Delhi) and\nBDR Finvest Pvt. Ltd. versus DCIT 161 taxmann.com 583 (Delhi). In these\ncases, Hon'ble High Court has held that if deductor had failed to deposit tax\nPage | 6\nITA

THE COMMISSIONER OF INCOME TAX-V vs. ORIENT CRAFT LTD

35,65,316/- under Section 10B. The assessee was a 100% export-oriented undertaking and was entitled to substantial amounts as duty drawback, 2012:DHC:7425-DB ITA No.555/2012 Page 2 of 14 DEPB, premium on DEPB and on sale of quota etc. These were all declared in the profit and loss account and the computation of income

ACIT, CIRCLE-26(2), NEW DELHI vs. VIKRAM ELECTRIC EQUIPMENT P.LTD, NEW DELHI

The appeal of the Revenue is dismissed as\ninfructuous

147, 148 and 149 in\nthe 45 1961 Act. A clear distinction has been made out\nbetween 'issue of notice' and 'service of notice' under the\n1961 Act. Section 149 prescribe the period of limitation. It\ncategorically prescribes that no notice under section 149\nshall be issued after the prescribed limitation\nhas lapsed.Section 148(1) provides for service of notice

SHYAM PRODUCTS P.LTD,NEW DELHI vs. ITO, WARD-23(3), NEW DELHI

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

Bench: Shri Challa Nagendra Prasad, S.M.C.

1), the authorities are bereft of the powers under other sections of the Act including sec 147/148 of the Act. Recently, on the exactly identical facts where reassessment proceedings, based on the seized material from Sh S.K. Jain Group initiated u/s 147/148 of IT Act, were quashed in view of Section 153C being independent code in the decisions

OPTIMIST ELECTRONICS P.LTD,NEW DELHI vs. ITO, WARD-19(2), NEW DELHI

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

Bench: Shri Challa Nagendra Prasad, S.M.C.

1), the authorities are bereft of the powers under other sections of the Act including sec 147/148 of the Act. Recently, on the exactly identical facts where reassessment proceedings, based on the seized material from Sh S.K. Jain Group initiated u/s 147/148 of IT Act, were quashed in view of Section 153C being independent code in the decisions

DCIT, NEW DELHI vs. M/S. DHARAMPAL SATYAPAL LTD., DELHI

In the result, the appeal of the assessee is allowed and the appeal of the revenue is dismissed

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

1. PB 59-62 at 59-60 is questionnaire dated 13.01.2006 from Learned Assessing Officer issued in original assessment u/s 143(3) asking about procurement of raw material from different units/divisions and about deduction u/s 80IC, excise duty. 2. PB 63-85 is assessee's letter dated 02/02/2006 giving details of inter unit transfers and that Delhi office

M/S. DHARAMPAL SATYAPAL LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee is allowed and the appeal of the revenue is dismissed

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

1. PB 59-62 at 59-60 is questionnaire dated 13.01.2006 from Learned Assessing Officer issued in original assessment u/s 143(3) asking about procurement of raw material from different units/divisions and about deduction u/s 80IC, excise duty. 2. PB 63-85 is assessee's letter dated 02/02/2006 giving details of inter unit transfers and that Delhi office

M/S. CHITRAKOOT MERCHANDISE PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, both the Appeals filed by the Assessee stand allowed

Bench: Shri H.S. Sidhu & Shri O.P. Kant

147, section section 149, section 151 and 148, section 149, section 151 section 153, where the and section 153, where the Assessing Officer is satisfied Assessing Officer is satisfied that any money, bullion, that any money, bullion, jewellery or other valuable jewellery or other valuable article or thing or books of article or thing or books of account or documents

M/S. CHITRAKOOT MERCHANDISE PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, both the Appeals filed by the Assessee stand allowed

Bench: Shri H.S. Sidhu & Shri O.P. Kant

147, section section 149, section 151 and 148, section 149, section 151 section 153, where the and section 153, where the Assessing Officer is satisfied Assessing Officer is satisfied that any money, bullion, that any money, bullion, jewellery or other valuable jewellery or other valuable article or thing or books of article or thing or books of account or documents