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

57,82,200/ wherein claim of deduction under section 80IC was allowed at Rs.85,59,98,358/-. In computing the income, disallowances of Rs.2,00,000/- under section 14A, Rs.4,31,154/- on account of foreign travel expenses and Rs.2,50,500/- on account of ROC charges were made. In an appeal filed by the assessee, disallowance

ACIT CIRCLE-59(1), NEW DELHI vs. NEERAJ KUMAR SINGHAL, NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kedia

57,037.5/- chargeable to tax has escaped assessment and this income needs to be assessed/reassessed u/s. 147 of the Act. If approved, notice u/ s 148 of the Act may be issued. Submitted for kind approval please" (b) The undisputed fact is that the original assessment in the case of appellant was completed

BSES YAMUNA POWER LTD.,NEW DELHI vs. DCIT, CIRCLE- 5(1), NEW DELHI

The appeal of the assessee is allowed on legal issues

Bench: Shri Anubhav Sharma & Shri Manish Agarwalbses Rajdhani Power Ltd., Dy. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd., Asst. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Yamuna Power Dy. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd. & Ors Vs. Acit Bses Yamuna Power Asst. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv., Sh. Deepesh Jain, Adv. & Sh. Shivam Gupta, Ca Department By Mr. Javed Akhtar, Cit-Dr Date Of Hearing 20/02/2025 Date Of Pronouncement 16/04/2025 O R D E R

u/s 148 which are as under: GOA No. 3 to 3.4-Validity of re-assessment proceedings 24. In the present case, reassessment proceedings under section 147/148 of the Act were initiated by the assessing officer vide notice dated 31.03.2014, ie, much beyond the period of 4 years and almost at the fag-end of the overall limitation period

BSES YAMUNA POWER LTD,DELHI vs. ACIT, CIRCLE-5(1), NEW DEL;HI

The appeal of the assessee is allowed on legal issues

Bench: Shri Anubhav Sharma & Shri Manish Agarwalbses Rajdhani Power Ltd., Dy. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd., Asst. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Yamuna Power Dy. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd. & Ors Vs. Acit Bses Yamuna Power Asst. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv., Sh. Deepesh Jain, Adv. & Sh. Shivam Gupta, Ca Department By Mr. Javed Akhtar, Cit-Dr Date Of Hearing 20/02/2025 Date Of Pronouncement 16/04/2025 O R D E R

u/s 148 which are as under: GOA No. 3 to 3.4-Validity of re-assessment proceedings 24. In the present case, reassessment proceedings under section 147/148 of the Act were initiated by the assessing officer vide notice dated 31.03.2014, ie, much beyond the period of 4 years and almost at the fag-end of the overall limitation period

COMMISSIONER OF INCOME TAX, DELHI VIII vs. INDIAN FARMERS FERTILIZERS CO-OP. LTD.

The appeal stands disposed of accordingly

reassessment proceeding initiated by the Assessing Officer u/s 147 R/W Section 148 of the Act was without jurisdiction?” 3. In order to appreciate the legal and factual points at issue in the present appeal, the facts attending this matter need to be marshalled at the outset. The respondent is a cooperative society manufacturing fertilizers. During the assessment year

RUBY SINGH,NEW DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

section 151 of the Act, the initiation of proceedings u/s. 147 of the Act and reassessment order framed u/s. 147(143(3) of the Act has to be held as invalid and deserve to be quashed. 3.1 Precisely reiterated written submissions dated 12.09.2023, the Ld. Counsel for the assessee summarised his contentions on legal grounds by vehemently submitting the following

RUBY SINGH,DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

section 151 of the Act, the initiation of proceedings u/s. 147 of the Act and reassessment order framed u/s. 147(143(3) of the Act has to be held as invalid and deserve to be quashed. 3.1 Precisely reiterated written submissions dated 12.09.2023, the Ld. Counsel for the assessee summarised his contentions on legal grounds by vehemently submitting the following

RUBY SINGH,NEW DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

section 151 of the Act, the initiation of proceedings u/s. 147 of the Act and reassessment order framed u/s. 147(143(3) of the Act has to be held as invalid and deserve to be quashed. 3.1 Precisely reiterated written submissions dated 12.09.2023, the Ld. Counsel for the assessee summarised his contentions on legal grounds by vehemently submitting the following

RUBY SINGH ,NEW DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

section 151 of the Act, the initiation of proceedings u/s. 147 of the Act and reassessment order framed u/s. 147(143(3) of the Act has to be held as invalid and deserve to be quashed. 3.1 Precisely reiterated written submissions dated 12.09.2023, the Ld. Counsel for the assessee summarised his contentions on legal grounds by vehemently submitting the following

RUBY SINGH,NEW DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

section 151 of the Act, the initiation of proceedings u/s. 147 of the Act and reassessment order framed u/s. 147(143(3) of the Act has to be held as invalid and deserve to be quashed. 3.1 Precisely reiterated written submissions dated 12.09.2023, the Ld. Counsel for the assessee summarised his contentions on legal grounds by vehemently submitting the following

RUBY SINGH,NEW DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

section 151 of the Act, the initiation of proceedings u/s. 147 of the Act and reassessment order framed u/s. 147(143(3) of the Act has to be held as invalid and deserve to be quashed. 3.1 Precisely reiterated written submissions dated 12.09.2023, the Ld. Counsel for the assessee summarised his contentions on legal grounds by vehemently submitting the following

RUBY SINGH ,NEW DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

section 151 of the Act, the initiation of proceedings u/s. 147 of the Act and reassessment order framed u/s. 147(143(3) of the Act has to be held as invalid and deserve to be quashed. 3.1 Precisely reiterated written submissions dated 12.09.2023, the Ld. Counsel for the assessee summarised his contentions on legal grounds by vehemently submitting the following

MAHESHWARI ROLLER FLOUR MILLS PVT LTD,NEW DELHI vs. ITO WARD - 16(1), NEW DELHI

In the result, appeal of the Assessee allowed

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

57 ITA.No.4257/Del./2019 Maheshwari Roller Flour Mills Pvt. Ltd., New Delhi.. 3.3. In the case of Pr. CIT vs., G And G Pharma India Ltd., [2016] 384 ITR 147 (Del.), the Hon’ble Delhi High Court held as under : “Reassessment condition precedent application of mind by assessing officer to materials prior to forming reason to believe income

JINDAL STEEL & POWER LTD.,DELHI vs. DCIT, GURGAON

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

Bench: Shri R. K. Panda & Smt. Beena A. Pillaiassessment Year : 2005-06 Jindal Steel & Power Ltd., Dcit, Circle- 1(1), Jindal Centre, Gurgaon. 12, Bhikaji Cama Place, Vs. Delhi.

147 of the Income Tax Act, 1961 : On completion of scrutiny assessment proceedings U/s 143(3) of the Act vide order dated 31.12.2007, returned income of Rs.1,46,94,07,460/- was enhanced by the AO to Rs.2,12,42,01,723/- making certain additions. Subsequently, it has been noticed that deduction under Section 80IB of the Act has been

VRC TOWNSHIP P LTD.,DELHI vs. ITO, NEW DELHI

In the result, appeal of the Assessee allowed

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

reassessment order invalid”. 3.4. In the case of Sarthak Securities Co. (P) Ltd., 329 ITR 110 (Del.), the Hon’ble Delhi High Court held as under : “No independent application of mind by the Assessing officer but acting under information from Inv. Wing - Notice U/s. 147 to be quashed”. 3.5. The assessee also submitted that assessment is barred by time

DCIT CIRCLE-10(1), NEW DELHI vs. ANJANI KUMAR GOENKA, NEW DELHI

In the result, appeal by the Revenue is dismissed in the aforesaid manner

Bench: Shri Shamim Yahya & Shri Sudhir Kumara.Yr. : 2011-12 Dcit, Cirlce-10(1), Anjani Kumar Goenka, C.R. Building, Vs. N-86, Connaught Place, I.P. Estate, New Delhi – 1 New Delhi – 2 (Pan: Aagpg6344M) (Appellant) (Respondent) Appellant By : Sh. Amit Goel, Ca Respondent By : Mr. Javed Akhtar, Cit(Dr) Date Of Hearing : 08.10.2024 Date Of Pronouncement : 15.10.2024 Order

57,68,340/-. In this case, a search operation was carried out u/s. 132 of the Act at the premises of the assesse on 26.07.2017. The reasons recorded before issue of notice u/s. 148 of the Act to the assesse on 17.10.2018 and notice u/s. 143(2) was also issued on 4.12.2018. It transpires from the reasons recorded before issue

MADHU APARTMENT PVT. LTD.,DELHI vs. ITO, WARD- 16(1), NEW DELHI

In the result, appeal of the Assessee allowed

Bench: Shri Bhavnesh Saini & Shri B.R.R. Kumar

reassessment order invalid”. 3.4. In the case of Sarthak Securities Co. (P) Ltd., 329 ITR 110 (Del.), the Hon’ble Delhi High Court held as under : “No independent application of mind by the Assessing officer but acting under information from Inv. Wing - Notice U/s. 147 to be quashed”. 3.5. The assessee also submitted that assessment is barred by time

MADHU APARTMENT PVT. LTD.,DELHI vs. ITO, WARD- 16(1), NEW DELHI

In the result, appeal of the Assessee allowed

Bench: Shri Bhavnesh Saini & Shri B.R.R. Kumar

reassessment order invalid”. 3.4. In the case of Sarthak Securities Co. (P) Ltd., 329 ITR 110 (Del.), the Hon’ble Delhi High Court held as under : “No independent application of mind by the Assessing officer but acting under information from Inv. Wing - Notice U/s. 147 to be quashed”. 3.5. The assessee also submitted that assessment is barred by time