SONEA DHIR,DELHI vs. ACIT CIRCLE-32 (1), NEW DELHI

In the result, appeal of the assessee is allowed

reassessment proceedings u/s 147/148 merely because\nhe felt that he failed to do what he has ought to have done i.e. to\nissue of notice u/s 143(2) for normal scrutiny assessment.\n3. On the facts and in the circumstances of the case, CIT (A) erred in\nupholding the impugned order passed by the respondent in framing\nimpugned assessment order

QUETZAL BUILDTECH PRIVATE LIMITED,HARYANA vs. INCOME TAX OFFICER, HARYANA

In the result, the appeal filed by the assessee is partly\nallowed as indicated above

reassessment observing\nas under :-\n1.\nWe have heard the rival submissions and\nperused the material available on record. The assessee\nis an individual. The return of income for AY 2009-10\nwas originally filed u/s 139 of the Act by the assessee\non 22.09.2010 declaring taxable income of Rs.\n3,90,294/- offering business income from the business\nof trading

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

reassessment proceedings u/s 147 is bad in law and void inter alia as: 3 ITAs No.5512, 5513, 5546 & 5574/DEL/2011 (a) there was no legitimate material to form a reason to believe that income liable to tax has escaped assessment. (b) the assumption of jurisdiction is bad in law, mechanical and without due consideration. (c) the observations of CIT (A) vide

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

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

reassessment proceedings u/s 147 is bad in law and void inter alia as: 3 ITAs No.5512, 5513, 5546 & 5574/DEL/2011 (a) there was no legitimate material to form a reason to believe that income liable to tax has escaped assessment. (b) the assumption of jurisdiction is bad in law, mechanical and without due consideration. (c) the observations of CIT (A) vide

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

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

reassessment proceedings u/s 147 is bad in law and void inter alia as: 3 ITAs No.5512, 5513, 5546 & 5574/DEL/2011 (a) there was no legitimate material to form a reason to believe that income liable to tax has escaped assessment. (b) the assumption of jurisdiction is bad in law, mechanical and without due consideration. (c) the observations of CIT (A) vide

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

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

reassessment proceedings u/s 147 is bad in law and void inter alia as: 3 ITAs No.5512, 5513, 5546 & 5574/DEL/2011 (a) there was no legitimate material to form a reason to believe that income liable to tax has escaped assessment. (b) the assumption of jurisdiction is bad in law, mechanical and without due consideration. (c) the observations of CIT (A) vide

ANUJ CHAUDHARY,GHAZIABAD vs. ITO, WARD- 1(1), GHAZIABAD

In the result, the appeal of the assessee is allowed

u/s 147 of the Act in the\ninstant case is based on incorrect facts recorded thereon. Accordingly, ground\nNos. 1 and 2 raised by the assessee on the legal issue are allowed. Since, relief\nis granted on the legal issues by quashing the reassessment, adjudication of\nother grounds raised by the assessee on merits would become academic in\nnature

ACIT, NEW DELHI vs. M/S. K.S. CHAWLA & SONGS (HUF), NEW DELHI

Appeal of the Revenue is dismissed

Bench: Shri N. K. Billaiya & Ms. Suchitra Kamble(Through Video Conferencing)

50C of the Act as against Rs. 77,50,000 declared by the appellant HUF and further erred in sustaining the above difference of Rs. 8,02,993 as alleged on- money for the purpose of computing capital gains in the hands of the appellant HUF which is highly arbitrary, uncalled for, unjustified

DELIGHT PROPCON PRIVATE LIMITED,DELHI vs. ACIT, CENTRAL CIRCLE-2, FARIDABAD

In the result, Appeal of the Assessee is partly allowed

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.M/S Delight Propcon Private Vs Assistant Commissioner Of Limited Shop No. 68, Building Income Tax, No. 38, Surya House, Near Central Circle-Ii, New Cgo Pnb Devil Road, Khanpur, Complex, N. H. Iv, Nit New Delhi Faridabad, Haryana-121001 Pan: Aadcd6203E Appellant Respondent Assessee By Sh. S. S. Nagar, Ca Revenue By Sh. Suman Malik, Cit(Dr) Date Of Hearing 08/09/2025 Date Of Pronouncement 26/11/2025 Order

reassessment proceedings u/s 147 of the Act was based on borrowed satisfaction and without application of mind. 6.2 That on the facts and in the circumstances of the case, the Ld. CIT-(A) has erred in upholding the order of Ld. AO without considering the fact that the reasons u/s 148 were recorded merely on the basis of suspicion

SMT. RANJANA GARG,NEW DELHI vs. DCIT, NEW DELHI

In the result, the CO of the assessee is allowed and

Bench: Shri G.D. Agrawal & Shri Sudhanshu Srivastavaranjana Garg, Vs Dcit 141, Sunder Nagar, Central Circle 12, New Delhi. Jhandewalan Aanpg3625Q Extn., New Delhi. Ranjana Garg, Vs Dcit 141, Sunder Nagar, Central Circle 12, New Delhi. Jhandewalan Aanpg3625Q Extn., New Delhi. Acit Vs Amita Garg, Central Circle 12, G-15, Maharani Bagh, New Delhi. New Delhi. Aadpg0990L Acit Vs Amita Garg, Central Circle 12, G-15, Maharani Bagh, New Delhi. New Delhi. Aadpg0990L

reassessment can be made. The word ‘assess’ in Section 153A is relatable to abated proceedings (i.e. those pending on the date of search) and the word ‘reassessee’ to completed assessment proceedings. vi. Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment u/s 153A merges into one. Only one assessment shall be made separately

SANDEEP KUMAR,UTTAR PRADESH vs. ITO, GHAZIABAD

In the result, the appeal of the assessee is allowed

Bench: Shri H.S. Sidhu & Shri B.P. Jain[Assessment Year: 2012-13] Shri Sandeep Kumar Vs. The Income-Tax Officer S/O Late Yogendar Singh Ward – 1(3) L/H Late Smt. Javitri Devi Ghaziabad R/O Village Noor Nagar Ghaziabad, U.P. Pan : Cfipd 6068 N [Appellant] [Respondent] Date Of Hearing : 12.12.2017 Date Of Pronouncement : 14.12.2017 Assessee By : Shri Hiren Mehta, Ca Shri Mukesh Kumar Bansal, Ca Shri M.K. Madan, Ca Revenue By : Shri S.S. Rana, Cit - Dr

147 of the Act. Issue notice u/s 148 of the Act.” 4. It was further brought to our notice at page 9 of the Sale Deed where circle rate is mentioned at front page of sale deed at Rs. 8,73,80,000/- and at Paper Book page 49 it is mentioned as 13,60,00,000/- whereas the sale

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

50C of the Act and cost of land parcels/loss 7 claimed by the assessee of Rs. 37,27,570/- as land cost covered by panchayat written off, hence the assessment order passed by the AO is erroneous in so far as it is prejudicial to the interest of revenue in view of provision of section 263 read with Explanation

ASSISSTANT COMMISSIONER OF INCOME TAX, JHANDEWALAN EXTN. vs. OM PRAKASH ARORA, CONNAUGHT PLACE

In the result, appeal of the Revenue vide ITA No

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2015-16] Assistant Commissioner Of Om Prakash Arora, Income Tax, Central Circle-01, M-3, Flat No.103, Avg Bhawan E-2, Jhandewalan Extn. Vs The Variety Books Depot. New Delhi-110055 Connaught Place, New Delhi-110001 Pan-Accpa9774F Assessee Revenue Cross Objection No.42/Del/2025 (Arising Out Of Ita No.5031/Del/2024) [Assessment Year: 2015-16] Om Prakash Arora, Assistant Commissioner Of Income M-3, Flat No.103, Avg Tax, Central Circle-01, Bhawan The Variety Books Vs E-2, Jhandewalan Extn. Depot. Connaught Place, New Delhi-110055 New Delhi-110001 Pan-Accpa9774F Assessee Revenue [Assessment Year: 2016-17] Assistant Commissioner Of Om Prakash Arora, Income Tax, Central Circle-01, M-3, Flat No.103, Avg Bhawan E-2, Jhandewalan Extn. Vs The Variety Books Depot. New Delhi-110055 Connaught Place, New Delhi-110001 Pan-Accpa9774F Assessee Revenue

reassessment proceedings on the premise that the Joint Commissioner or Additional Commissioner could not be the Assessing Officer under section 2(7A) of the Act unless specifically directed under section 120(4)(b) of the Act to perform the functions of an AO and in the case of the Appellant, no such directions had been issued and the case

ASSISSTANT COMMISSIONER OF INCOME TAX, JHANDEWALAN EXTN. vs. OM PRAKASH ARORA, CONNAUGHT PLACE

In the result, appeal of the Revenue vide ITA No

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2015-16] Assistant Commissioner Of Om Prakash Arora, Income Tax, Central Circle-01, M-3, Flat No.103, Avg Bhawan E-2, Jhandewalan Extn. Vs The Variety Books Depot. New Delhi-110055 Connaught Place, New Delhi-110001 Pan-Accpa9774F Assessee Revenue Cross Objection No.42/Del/2025 (Arising Out Of Ita No.5031/Del/2024) [Assessment Year: 2015-16] Om Prakash Arora, Assistant Commissioner Of Income M-3, Flat No.103, Avg Tax, Central Circle-01, Bhawan The Variety Books Vs E-2, Jhandewalan Extn. Depot. Connaught Place, New Delhi-110055 New Delhi-110001 Pan-Accpa9774F Assessee Revenue [Assessment Year: 2016-17] Assistant Commissioner Of Om Prakash Arora, Income Tax, Central Circle-01, M-3, Flat No.103, Avg Bhawan E-2, Jhandewalan Extn. Vs The Variety Books Depot. New Delhi-110055 Connaught Place, New Delhi-110001 Pan-Accpa9774F Assessee Revenue

reassessment proceedings on the premise that the Joint Commissioner or Additional Commissioner could not be the Assessing Officer under section 2(7A) of the Act unless specifically directed under section 120(4)(b) of the Act to perform the functions of an AO and in the case of the Appellant, no such directions had been issued and the case

SATISH KUMAR TANDON,NEW DELHI vs. ITO, WARD- 34(3), NEW DELHI

In the result, the appeal filed by the assessee stands allowed for statistical purposes

Bench: Shri H. S. Sidhu

u/s. 50C(1) of the Act and held that the value adopted for stamp duty purposes shall be deemed to be the full value of the consideration received as a result of such transfer. Hence, the AO assessed full value of the consideration as per the circle rates and added Rs. 16,69,167/- to the total income

KUNWAR PAL SINGH,GHAZIABAD vs. ITO WARD - 1(3), GHAZIABAD

In the result, the impugned notice is quashed

Bench: learned first appellate authority, inter alia, challenging the reopening of the assessment under section 147 of the Act.

147 are applicable to facts of this case and the assessment year under consideration is deemed to be a case where income chargeable to tax has escaped assessment". 5. The fact is the return of income for A.Y. 2012-13 filed by petitioner on 24th September, 2012 has been assessed under Section 143(3) of the Act and the Assessment

NARENDRA KUMAR GILL,MUZAFFARNAGAR vs. ITO, MUZAFFARNAGAR

In the result, the appeal of the assessee on the grounds of

Bench: Sh. Kuldip Singhdr. B. R. R. Kumar(Through Video Conferencing) Ita No. 1532/Del/2017 : Asstt. Year : 2009-10 Narendra Kumar Gill, Vs Income Tax Officer, C/O Shri N.K. Arora, Adv., Ward-2(1), 219, Civil Line South, Muzaffarnagar Muzaffarnagar (Appellant) (Respondent) Pan No. Acvpg8013G Assessee By : Sh. Prem Lata Bansal, Sr. Adv. Revenue By : Ms. Rakhi Vimal, Sr. Dr Date Of Hearing: 23.11.2020 Date Of Pronouncement: 22.12.2020

50C r.w.s. 48 of the Income Tax Act, 1961. 4. Owing to the reason to believe, that the income of the assessee escaped assessment with regard to the capital gains arising out of the sale of immovable property namely “Modern Service Station” situated at Rampuri, Muzaffarnagar. The 5 Narendra Kumar Gill Assessing Officer, ITO Ward-1(2), Muzaffarnagar issued notice

SHRI INAMUL HAQ,SAHARANPUR vs. ITO, SAHARANPUR

In the result, the appeal of the assessee is allowed

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2009-10 Shri Inamul Haq S/O Sh. Mohd. Vs. Income Tax Officer, Yamin, Vill.Megh Chhappar, Ward-2. Ambalaa Road, Saharanpur (U.P) Saharanpur Pan: Aaiph2840K (Appellant) (Respondent)

147 read with section 148. 4. That no proper statutory approval has been taken by the Assessing officer U/s 151 of the I.T. Act, 1961, as required. If any approval is taken then the approval is in very mechanical manner without application of mind by the statutory authority hence the proceedings initiated U/s 147/148 is illegal

JAGDISH PARSHAD JAIN,PANIPAT vs. DCIT CENTRAL CIRCLE KARNAL, KARNAL

In the result, the appeal of the assessee is allowed

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2009-10 Shri Inamul Haq S/O Sh. Mohd. Vs. Income Tax Officer, Yamin, Vill.Megh Chhappar, Ward-2. Ambalaa Road, Saharanpur (U.P) Saharanpur Pan: Aaiph2840K (Appellant) (Respondent)

147 read with section 148. 4. That no proper statutory approval has been taken by the Assessing officer U/s 151 of the I.T. Act, 1961, as required. If any approval is taken then the approval is in very mechanical manner without application of mind by the statutory authority hence the proceedings initiated U/s 147/148 is illegal