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

4. Section 801 A(7) specifically provides for audit of books of accounts to arrive at the profit derived from the undertaking. But, in the instant case during the proceedings u/s 263 of the IT. Act for A.Y. 2005-06 the counsels of the assessee admitted (in writing) before the Commissioner of Income Tax, Hissar that the assessee company does

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

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, 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

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

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)

4. Briefly stated the facts of the case are the return of income was filed on 29.09.2009 which was subsequently revised on 29.03.2010. The return was selected for scrutiny assessment and accordingly assessment was framed u/s 143 (3) of the Act vide order dated 27.12.2010. The said assessment order was revised by the PCIT u/s

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)

4 the amount of deduction u/s 10A to this level. It is clear from the facts of the case narrated above that the assessee is otherwise entitled to deduction u/s 10A in respect of export of eligible goods. The fact that the Assessing Officer himself allowed deduction u/s 10A @ 20% proves that all the eligible conditions

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)

4 the amount of deduction u/s 10A to this level. It is clear from the facts of the case narrated above that the assessee is otherwise entitled to deduction u/s 10A in respect of export of eligible goods. The fact that the Assessing Officer himself allowed deduction u/s 10A @ 20% proves that all the eligible conditions

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

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 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

DCIT CENTRAL CIRCLE-17, NEW DELHI vs. AL AMMAR FROZEN FOODS EXPORTS PVT. LTD, NEW DELHI

In the result, appeal of the Revenue is dismissed and cross\nobjection filed by the assessee is dismissed as infructuous

u/s 801A\nelectronically. During the course of assessment\nproceedings, the assessee failed to point out this\ndiscrepancy and thus there is non- disclosure of true and\ncomplete particulars.\n\nii) As regards the third proviso to section 147, it is\nstated that the same is with respect to the relevant\n assessment year for which the matter is subjected

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

In the result, all the appeals of the assessee in ITA No

801A(4) in the return of income filed in response to notice\nunder Section 153A of the Act, also to be considered as if the assessee has\nmade a claim on or before filing the return under Section 139(1), and\nfurther, it is contrary to the scheme of regular assessment and search\nassessment and is devoid of merits........... Further

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

801A(4) in the return of income filed in response to notice\nunder Section 153A of the Act, also to be considered as if the assessee has\nmade a claim on or before filing the return under Section 139(1), and\nfurther, it is contrary to the scheme of regular assessment and search\nassessment and is devoid of merits........... Further