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

JINDAL STEEL & POWER LTD.,NEW DELHI vs. PRCIT, GURUGRAM

In the result appeal of the assessee is allowed on the issue of the impugned order passed beyond the prescribed time, other issues are left open

reassessment order is neither erroneous and nor prejudicial to the interest of the revenue as the twin conditions are not satisfied. He also relied upon several judicialprecedents for the same. V. He relied upon the fact that merely because of the reason that the learned assessing officer did not carry out the inquiries as envisaged by the learned

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

RRB ENERGY LTD.,NEW DELHI vs. ITO, NEW DELHI

Bench: Shri G. D. Agrawal, Hon’Ble & Shri Kuldip Singh

reassessment proceedings u/s 147/148 of the Income Tax Act, 1961 without any reason or basis or material; ii) in acting u/s 147 r.w.s. 143 (3) of the Act to redo the assessment solely on the basis of change of opinion and in 2 I.T.A.No.1874./Del/2013 violation of the parameters envisaged under the proviso to section 147

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

In the result, the reassessment is held to be bad in law the appeal of the assessee on this point is allowed

Bench: Sh. N. K. Billaiya & Sh. Kuldip Singhassessment Year: 2008-09 Jindal Steel & Power Ltd. Dcit Circle -1 (1), 5Th Floor, Jindal Centre Vs 12, Bhikaji Cama Place Hsidc Building, New Delhi – 110066 Vanijya Nikunj, Udyog Pan : Aaacj7097D Vihar, Phase-V, Gurgaon (Appellant) (Respondent)

reassessment proceedings were initiated notice u/s 148 of the Act was issued on 24.03.2015. With this notice the Assessing Officer sought to reopen the assessment framed vide order dated 19.09.2013 the reasons recorded by the Assessing Officer for reopening assessment reads as under :- Name and address of the assessee M's Jindai Steel and Power Limited. O P Jindai Mary

M/S. A.T. KEARNEY INDIA PRIVATE LIMITED,GURGAON vs. ITO, NEW DELHI

In the result the ground No

Bench: Smt Diva Singh & Shri Prashant Maharishiat Kearney India Private Ito, Limited, Ward-1(1), Vs. 6Th Floor, Tower-D, Global New Delhi Business Park, Gurgaon Pan:Aadca1436G (Appellant) (Respondent) At Kearney India Private Ito, Limited, Ward-1(1), Vs. 6Th Floor, Tower-D, Global New Delhi Business Park, Gurgaon Pan:Aadca1436G (Appellant) (Respondent)

reassessment proceedings under section 147 of the Act on the basis of proceedings concluded for a subsequent assessment year and not A T Kearney India Private Limited V ITO A Y 2005-06 & 2007-08 ITA no 510& 511 /Del/2014 Page 27 of 31 on the basis of any tangible material available for the concerned assessment year. 1.3. Based

M/S. A.T. KEARNEY INDIA PRIVATE LIMITED,GURGAON vs. ITO, NEW DELHI

In the result the ground No

Bench: Smt Diva Singh & Shri Prashant Maharishiat Kearney India Private Ito, Limited, Ward-1(1), Vs. 6Th Floor, Tower-D, Global New Delhi Business Park, Gurgaon Pan:Aadca1436G (Appellant) (Respondent) At Kearney India Private Ito, Limited, Ward-1(1), Vs. 6Th Floor, Tower-D, Global New Delhi Business Park, Gurgaon Pan:Aadca1436G (Appellant) (Respondent)

reassessment proceedings under section 147 of the Act on the basis of proceedings concluded for a subsequent assessment year and not A T Kearney India Private Limited V ITO A Y 2005-06 & 2007-08 ITA no 510& 511 /Del/2014 Page 27 of 31 on the basis of any tangible material available for the concerned assessment year. 1.3. Based

HCL SINGAPORE PTE. LTD (SUCCESSOR TO AXON SOLUTIONS SINGAPORE PTE LIMITED),DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, similar grounds of appeal, in all the captioned

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

147 of the Act are without jurisdiction 3.1 That on the facts and circumstances of the case and in law, the reassessment proceedingsundertaken by the assessing officer culminating in final assessment order are without jurisdiction, void ab initio and bad in law. 3.2 That the assessing officer erred on facts and in law in passing final assessment order without appreciating

HCL TECHNOLOGIES NORWAY AS ,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, similar grounds of appeal, in all the captioned

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

147 of the Act are without jurisdiction 3.1 That on the facts and circumstances of the case and in law, the reassessment proceedingsundertaken by the assessing officer culminating in final assessment order are without jurisdiction, void ab initio and bad in law. 3.2 That the assessing officer erred on facts and in law in passing final assessment order without appreciating

HCL AUSTRALIA SERVICES PTY LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, similar grounds of appeal, in all the captioned

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

147 of the Act are without jurisdiction 3.1 That on the facts and circumstances of the case and in law, the reassessment proceedingsundertaken by the assessing officer culminating in final assessment order are without jurisdiction, void ab initio and bad in law. 3.2 That the assessing officer erred on facts and in law in passing final assessment order without appreciating

M/S. JINDAL PHOTO LTD.,NEW DELHI vs. ACIT, NEW DELHI

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

801A can be claimed even though Form 10CCB was not filed with the return of income but was filed during the course of assessment. 27. To summarize, the ld AR stated that the aforesaid judgement has been rendered by the Supreme Court in the context of specific statutory timeline for withdrawal of claim as mandated under section 10B(8), which

DCIT, CIRCLE- I, FARIDABAD vs. HEENA INDUSTRIES PVT. LTD., FARIDABAD

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing) Henna Export Corporation, Addl. Cit, 1031/2, Link Road, Range : 1, Vs. Old Faridabad. Faridabad. Pan : Aabfh7670N & Ita Nos. 6575, 6576, 6577, 6578, 6579 & 6580/Del/2017 (Assessment Years : 2008-09 To 2013-14) Dcit, M/S. Heena Industries Circle-1, Pvt. Ltd., Vs. Faridabad. Plot No. 45, Sector : 27– A, Faridabad. Pan : Aabch7692B & Ita Nos. 6570, 6571, 6572, 6573 & 6574/Del/2017 (Assessment Years : 2008-09 To 2010-11, 2012-13 & 2013-14) Dcit, Henna Export Corporation, Circle-1, 1031/2, Link Road, Vs. Faridabad. Old Faridabad. Pan : Aabfh7670N & C. O. Nos. 76, 77, 78, 79 & 80/Del/2020. [ In Ita Nos. 6570, 6571, 6572, 6573 & 6574/Del/2017 ] (Assessment Years : 2008-09 To 2010-11, 2012-13 & 2013-14) Henna Export Corporation, Dcit, 1031/2, Link Road, Circle-1, Vs. Old Faridabad. Faridabad. Pan : Aabfh7670N (Appellant) (Respondent)

section 80IC(7) and 801A(10) of the Income Tax Act, 1961? “ C. O. Nos. 76, 77, 78, 79 & 80/Del/2020 – [By the assessee] (Heena export Corporation) “ 1. Because the action is being challenged on facts & law, for the assumption & misapplication of jurisdiction for reassessment proceedings and the sanction being 'a fit case for issue of notice' is being challenged while

HENNA EXPORTS CORPORATION,HARYANA vs. ADDL. CIT, FARIDABAD

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing) Henna Export Corporation, Addl. Cit, 1031/2, Link Road, Range : 1, Vs. Old Faridabad. Faridabad. Pan : Aabfh7670N & Ita Nos. 6575, 6576, 6577, 6578, 6579 & 6580/Del/2017 (Assessment Years : 2008-09 To 2013-14) Dcit, M/S. Heena Industries Circle-1, Pvt. Ltd., Vs. Faridabad. Plot No. 45, Sector : 27– A, Faridabad. Pan : Aabch7692B & Ita Nos. 6570, 6571, 6572, 6573 & 6574/Del/2017 (Assessment Years : 2008-09 To 2010-11, 2012-13 & 2013-14) Dcit, Henna Export Corporation, Circle-1, 1031/2, Link Road, Vs. Faridabad. Old Faridabad. Pan : Aabfh7670N & C. O. Nos. 76, 77, 78, 79 & 80/Del/2020. [ In Ita Nos. 6570, 6571, 6572, 6573 & 6574/Del/2017 ] (Assessment Years : 2008-09 To 2010-11, 2012-13 & 2013-14) Henna Export Corporation, Dcit, 1031/2, Link Road, Circle-1, Vs. Old Faridabad. Faridabad. Pan : Aabfh7670N (Appellant) (Respondent)

section 80IC(7) and 801A(10) of the Income Tax Act, 1961? “ C. O. Nos. 76, 77, 78, 79 & 80/Del/2020 – [By the assessee] (Heena export Corporation) “ 1. Because the action is being challenged on facts & law, for the assumption & misapplication of jurisdiction for reassessment proceedings and the sanction being 'a fit case for issue of notice' is being challenged while