BALLU SINGH,GURGAON vs. ITO WARD -65(5), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Kul Bharat

5), New Delhi. 1.2 Section 148 mandates issue of notice before assessment, reassessment or computation of income u/s 147. As per section 148, it is mandatory that the Assessing Officer shall serve on the assessee a notice required him to furnish a return. The expression “Assessing Officer” used in the section 148 means ‘the Assessing Officer vested with the jurisdiction

MR. KRISHNA KUMAR PANT,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year 2005-06

section 2(24)(iv) of the Income Tax Act, 1961.” 5. Appellant vide letter dated 6th September, 2010 objected to the action of initiation of proceedings u/s 147. The objection raised was disposed off by the Ld. AO by passing an order dated 20th September, 2010 and thereafter he continued the proceedings for reassessment

MR. SANJIV NARAYAN,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year 2005-06

section 2(24)(iv) of the Income Tax Act, 1961.” 5. Appellant vide letter dated 6th September, 2010 objected to the action of initiation of proceedings u/s 147. The objection raised was disposed off by the Ld. AO by passing an order dated 20th September, 2010 and thereafter he continued the proceedings for reassessment

MR. J.S. GUJRAL,GURGAON vs. DCIT, NEW DELHI

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year 2005-06

section 2(24)(iv) of the Income Tax Act, 1961.” 5. Appellant vide letter dated 6th September, 2010 objected to the action of initiation of proceedings u/s 147. The objection raised was disposed off by the Ld. AO by passing an order dated 20th September, 2010 and thereafter he continued the proceedings for reassessment

MR. RANJEET SINGH,GURGAON vs. DCIT, NEW DELHI

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year 2005-06

section 2(24)(iv) of the Income Tax Act, 1961.” 5. Appellant vide letter dated 6th September, 2010 objected to the action of initiation of proceedings u/s 147. The objection raised was disposed off by the Ld. AO by passing an order dated 20th September, 2010 and thereafter he continued the proceedings for reassessment

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

section 147 to 151 are not satisfied. 2. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in reopening the impugned assessment U/S 147, more so when the appellant was searched u/s 132 of Income Tax Act, 1961. 3. That

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

section 147 to 151 are not satisfied. 2. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in reopening the impugned assessment U/S 147, more so when the appellant was searched u/s 132 of Income Tax Act, 1961. 3. That

SUDHIR DHINGRA,NEW DELHI vs. DCIT, CENTRAL CIRCLE-II, GURGAON

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

5,13,00,000/- on account of deemed dividend u/s 2(22)(e) of the Act in an assessment order framed u/s 153A can be made by the Assessing Officer on the basis in the documents found and seized during search u/s 132, information of fund flow collected during the enquiries conducted by the Investigation Wing/Assessing Officer and statements

DCIT, CENTRAL CIRCLE-II, GURGAON vs. SUDHIR DHINGRA, NEW DELHI

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

5,13,00,000/- on account of deemed dividend u/s 2(22)(e) of the Act in an assessment order framed u/s 153A can be made by the Assessing Officer on the basis in the documents found and seized during search u/s 132, information of fund flow collected during the enquiries conducted by the Investigation Wing/Assessing Officer and statements

DCIT, CENTRAL CIRCLE-II, GURGAON vs. SUDHIR DHINGRA, NEW DELHI

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

5,13,00,000/- on account of deemed dividend u/s 2(22)(e) of the Act in an assessment order framed u/s 153A can be made by the Assessing Officer on the basis in the documents found and seized during search u/s 132, information of fund flow collected during the enquiries conducted by the Investigation Wing/Assessing Officer and statements

DCIT, CENTRAL CIRCLE-II, GURGAON vs. SUDHIR DHINGRA, NEW DELHI

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

5,13,00,000/- on account of deemed dividend u/s 2(22)(e) of the Act in an assessment order framed u/s 153A can be made by the Assessing Officer on the basis in the documents found and seized during search u/s 132, information of fund flow collected during the enquiries conducted by the Investigation Wing/Assessing Officer and statements

ACIT, CENTRAL CIRCLE-II, GURGAON vs. ANOOP THATAI, NEW DELHI

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

5,13,00,000/- on account of deemed dividend u/s 2(22)(e) of the Act in an assessment order framed u/s 153A can be made by the Assessing Officer on the basis in the documents found and seized during search u/s 132, information of fund flow collected during the enquiries conducted by the Investigation Wing/Assessing Officer and statements

ANOOP THATAI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-II, GURGAON

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

5,13,00,000/- on account of deemed dividend u/s 2(22)(e) of the Act in an assessment order framed u/s 153A can be made by the Assessing Officer on the basis in the documents found and seized during search u/s 132, information of fund flow collected during the enquiries conducted by the Investigation Wing/Assessing Officer and statements

DCIT, CENTRAL CIRCLE-II, GURGAON vs. SUDHIR DHINGRA, NEW DELHI

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

5,13,00,000/- on account of deemed dividend u/s 2(22)(e) of the Act in an assessment order framed u/s 153A can be made by the Assessing Officer on the basis in the documents found and seized during search u/s 132, information of fund flow collected during the enquiries conducted by the Investigation Wing/Assessing Officer and statements

SUDHIR DHINGRA,NEW DELHI vs. DCIT, CENTRAL CIRCLE-II, GURGAON

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

5,13,00,000/- on account of deemed dividend u/s 2(22)(e) of the Act in an assessment order framed u/s 153A can be made by the Assessing Officer on the basis in the documents found and seized during search u/s 132, information of fund flow collected during the enquiries conducted by the Investigation Wing/Assessing Officer and statements

DCIT, CENTRAL CIRCLE-II, GURGAON vs. SUDHIR DHINGRA, NEW DELHI

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

5,13,00,000/- on account of deemed dividend u/s 2(22)(e) of the Act in an assessment order framed u/s 153A can be made by the Assessing Officer on the basis in the documents found and seized during search u/s 132, information of fund flow collected during the enquiries conducted by the Investigation Wing/Assessing Officer and statements

DCIT, CENTRAL CIRCLE-II, GURGAON vs. SUDHIR DHINGRA, NEW DELHI

In the result, appeal of the revenue is dismissed

Bench: Sh. Amit Shukla, Judicialmember & Sh.B. R. R. Kumar

5,13,00,000/- on account of deemed dividend u/s 2(22)(e) of the Act in an assessment order framed u/s 153A can be made by the Assessing Officer on the basis in the documents found and seized during search u/s 132, information of fund flow collected during the enquiries conducted by the Investigation Wing/Assessing Officer and statements

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

2) of Section 148 mandates reasons for issuance of notice by the Assessing Officer and sub-section (1) thereof mandates service of notice to the assessee before the Assessing Officer proceeds to assess, reassess or recompute escaped income. Section 147 mandates recording of reasons to believe by the Assessing Officer that the income chargeable to tax has escaped assessment