ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents or assets

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents or assets

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents or assets

M/S BHARTIYA SAMRUDDHI FINANCE LTD.,,NEW DELHI vs. DCIT, NEW DELHI

In the result, appeal of the Assessee is allowed

Bench: Shri R.K. Panda & Shri Mahavir Prasad

u/s 143(3) and where there is no allegation of any failure on the part of the assessee to disclose fully and truly all material facts necessary for completion of the assessment, then initiation of re-assessment proceedings after a period of four years is invalid. 1. DCIT vs. Dakshin Haryana Bijli Vitran Nigam

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

In the result, the appeal of the assessee is allowed

Bench: Shri Kul Bharat

section 147 of the IT Act, 1961. Moreover, it is quite possible that any other income may also have escaped assessment and hence issue of notice u/s 148 becomes inevitable to bring the income that has escaped assessment under the ambit of assessment.” 2.2 Plain reading of the reasons as recorded by the Ld. Assessing Officer suggest us as follows

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

In the result, the appeal of the assessee is allowed

Bench: Shri Kul Bharat

section 147 of the IT Act, 1961. Moreover, it is quite possible that any other income may also have escaped assessment and hence issue of notice u/s 148 becomes inevitable to bring the income that has escaped assessment under the ambit of assessment.” 2.2 Plain reading of the reasons as recorded by the Ld. Assessing Officer suggest us as follows

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment order was passed u/s 147 r.w.s. 143(3) dated 31.03.2022 wherein the total income of the assessee was assessed by making additions of Rs.10,96,92,546/- after disallowing various expenses claimed. 9. Against the said order, the assessee has preferred the appeal before the Ld. CIT(A) who after considering the merits of the submissions made, had deleted

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment order was passed u/s 147 r.w.s. 143(3) dated 31.03.2022 wherein the total income of the assessee was assessed by making additions of Rs.10,96,92,546/- after disallowing various expenses claimed. 9. Against the said order, the assessee has preferred the appeal before the Ld. CIT(A) who after considering the merits of the submissions made, had deleted

DCIT, CENTRAL CIRCLE-20, NEW DELHI vs. LOTUS HERBALS P.LTD, DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment order was passed u/s 147 r.w.s. 143(3) dated 31.03.2022 wherein the total income of the assessee was assessed by making additions of Rs.10,96,92,546/- after disallowing various expenses claimed. 9. Against the said order, the assessee has preferred the appeal before the Ld. CIT(A) who after considering the merits of the submissions made, had deleted

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment order was passed u/s 147 r.w.s. 143(3) dated 31.03.2022 wherein the total income of the assessee was assessed by making additions of Rs.10,96,92,546/- after disallowing various expenses claimed. 9. Against the said order, the assessee has preferred the appeal before the Ld. CIT(A) who after considering the merits of the submissions made, had deleted

DCIT, CENTRAL CIRCLE-20, DELHI vs. LOTUS HERBALS PVT. LTD, DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment order was passed u/s 147 r.w.s. 143(3) dated 31.03.2022 wherein the total income of the assessee was assessed by making additions of Rs.10,96,92,546/- after disallowing various expenses claimed. 9. Against the said order, the assessee has preferred the appeal before the Ld. CIT(A) who after considering the merits of the submissions made, had deleted

COSMIC INFORMATICS PVT. LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE - 2, NEW DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment order was passed u/s 147 r.w.s. 143(3) dated 31.03.2022 wherein the total income of the assessee was assessed by making additions of Rs.10,96,92,546/- after disallowing various expenses claimed. 9. Against the said order, the assessee has preferred the appeal before the Ld. CIT(A) who after considering the merits of the submissions made, had deleted

COSMIC INFORMATICS PVT. LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE - 2, NEW DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment order was passed u/s 147 r.w.s. 143(3) dated 31.03.2022 wherein the total income of the assessee was assessed by making additions of Rs.10,96,92,546/- after disallowing various expenses claimed. 9. Against the said order, the assessee has preferred the appeal before the Ld. CIT(A) who after considering the merits of the submissions made, had deleted

DCIT, NEW DELHI vs. M/S. DSL SOFTWARE LTD., NEW DELHI

In the result, all the three appeals of the Revenue and cross objection of the assessee are dismissed

Bench: : Shri Amit Shukla & Shri L.P. Sahu

546 (Guj HC) • CIT vs Nirma Chemicals Works Pvt Ltd: 309 ITR 67 (Guj HC) • PCIT vs H Nagaraja: 406 ITR 242 (Kar HC) • CIT vs SRA Systems Ltd: [2019] 410 ITR 392 (Mad HC) – 10A issue In that view of the matter, reassessment initiated u/s 147/ 148 of the Act has been rightly quashed

ACIT, NEW DELHI vs. M/S. DSL SOFTWARE LTD., NEW DELHI

In the result, all the three appeals of the Revenue and cross objection of the assessee are dismissed

Bench: : Shri Amit Shukla & Shri L.P. Sahu

546 (Guj HC) • CIT vs Nirma Chemicals Works Pvt Ltd: 309 ITR 67 (Guj HC) • PCIT vs H Nagaraja: 406 ITR 242 (Kar HC) • CIT vs SRA Systems Ltd: [2019] 410 ITR 392 (Mad HC) – 10A issue In that view of the matter, reassessment initiated u/s 147/ 148 of the Act has been rightly quashed

DCIT, NEW DELHI vs. M/S. DSL SOFTWARE LTD., NEW DELHI

In the result, all the three appeals of the Revenue and cross objection of the assessee are dismissed

Bench: : Shri Amit Shukla & Shri L.P. Sahu

546 (Guj HC) • CIT vs Nirma Chemicals Works Pvt Ltd: 309 ITR 67 (Guj HC) • PCIT vs H Nagaraja: 406 ITR 242 (Kar HC) • CIT vs SRA Systems Ltd: [2019] 410 ITR 392 (Mad HC) – 10A issue In that view of the matter, reassessment initiated u/s 147/ 148 of the Act has been rightly quashed

ACIT, CENTRAL CIRCLE- 30, NEW DELHI vs. PARKASH INDUSTRIES LTD, HISAR

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

Section 153 C of the Act but in relation to Section 153A of the Act as well.Consequently, this Court does not find any error having been committed by the ITAT in accepting the plea of the Assessee that there is no 64 I.T.As. No.4039, 4040, 4041, 4042, 4043, 4064, 4065, 4066, 4067, 4068, 4069, 4070/DEL/2017 incriminating document which was seized

PRAKASH INDUSTRIES LTD.,NEW DELHI vs. ACIT, CC- 30,, NEW DELHI

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

Section 153 C of the Act but in relation to Section 153A of the Act as well.Consequently, this Court does not find any error having been committed by the ITAT in accepting the plea of the Assessee that there is no 64 I.T.As. No.4039, 4040, 4041, 4042, 4043, 4064, 4065, 4066, 4067, 4068, 4069, 4070/DEL/2017 incriminating document which was seized

PRAKASH INDUSTRIES LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 30, NEW DELHI

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

Section 153 C of the Act but in relation to Section 153A of the Act as well.Consequently, this Court does not find any error having been committed by the ITAT in accepting the plea of the Assessee that there is no 64 I.T.As. No.4039, 4040, 4041, 4042, 4043, 4064, 4065, 4066, 4067, 4068, 4069, 4070/DEL/2017 incriminating document which was seized