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

reassessment proceedings u/s. 147 of the Act and issuance of said notice u/s. 148, therefore, our conclusion drawn for assessment year 2013-14 (supra) would apply mutatis mutandis to the identical and similar grounds no. 2 to 2.2 of assessee in other 06 appeals. Consequently, grounds no. 2 to 2.2 of the assessee in other 06 appeals

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

reassessment proceedings u/s. 147 of the Act and issuance of said notice u/s. 148, therefore, our conclusion drawn for assessment year 2013-14 (supra) would apply mutatis mutandis to the identical and similar grounds no. 2 to 2.2 of assessee in other 06 appeals. Consequently, grounds no. 2 to 2.2 of the assessee in other 06 appeals

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

reassessment proceedings u/s. 147 of the Act and issuance of said notice u/s. 148, therefore, our conclusion drawn for assessment year 2013-14 (supra) would apply mutatis mutandis to the identical and similar grounds no. 2 to 2.2 of assessee in other 06 appeals. Consequently, grounds no. 2 to 2.2 of the assessee in other 06 appeals

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

reassessment proceedings u/s. 147 of the Act and issuance of said notice u/s. 148, therefore, our conclusion drawn for assessment year 2013-14 (supra) would apply mutatis mutandis to the identical and similar grounds no. 2 to 2.2 of assessee in other 06 appeals. Consequently, grounds no. 2 to 2.2 of the assessee in other 06 appeals

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

reassessment proceedings u/s. 147 of the Act and issuance of said notice u/s. 148, therefore, our conclusion drawn for assessment year 2013-14 (supra) would apply mutatis mutandis to the identical and similar grounds no. 2 to 2.2 of assessee in other 06 appeals. Consequently, grounds no. 2 to 2.2 of the assessee in other 06 appeals

SHARK PACKAGING (INDIA) PRIVATE LIMITED,DELHI vs. ITO,WARD-23(1), NEW DELHI

In the result, the appeal of the assessee for AY 2012-13 is partly allowed only on ground no

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

unexplained credit and it is not clear that the transactions were taken place with whom in that case there were absolutely no details available and the information supplied was extremely scanty and vague and in that light of the fact in view of said preposition initiation of proceedings u/s. 147 of the Act and issuance of notice u/s

SHARK PACKAGING (INDIA) PVT LTD,NEW DELHI vs. ITO WARD - 23(1), NEW DELHI

In the result, the appeal of the assessee for AY 2012-13 is partly allowed only on ground no

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

unexplained credit and it is not clear that the transactions were taken place with whom in that case there were absolutely no details available and the information supplied was extremely scanty and vague and in that light of the fact in view of said preposition initiation of proceedings u/s. 147 of the Act and issuance of notice u/s

SHARK PACKAGING (INDIA) PVT LTD,NEW DELHI vs. ITO WARD - 23(1), NEW DELHI

In the result, the appeal of the assessee for AY 2012-13 is partly allowed only on ground no

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

unexplained credit and it is not clear that the transactions were taken place with whom in that case there were absolutely no details available and the information supplied was extremely scanty and vague and in that light of the fact in view of said preposition initiation of proceedings u/s. 147 of the Act and issuance of notice u/s

WARM FORGINGS P.LTD,NEW DELHI vs. DCIT, CIRCLE-27(1), NEW DELHI

In the result, appeal of the assessee is allowed as indicated

Bench: Shri Challa Nagendra Prasad & Dr. B.R.R. Kumarआ.अ.सं/.I.T.A No.1148/Del/2019 िनधा"रणवष"/Assessment Year: 2010-11 बनाम Warm Forgings P. Ltd., Dcit Plot No.117 & 118, A-3, Vs. Circle 27(1), Sector-11, Rohini, New Delhi. New Delhi. Pan No.Aabcc7684C अपीलाथ" Appellant ""यथ"/Respondent

147 of the Act by the AO without independent application of mind to the facts of the case and without verification of the material placed on his record during the original assessment proceedings completed u/s 143(3) of the Act. Thus the reopening of the assessment is bad in law and the assessment order so made should be cancelled

MAHESH KUMAR,DELHI vs. ITO,WARD-68(6), DELHI

In the result, Ground no. 3 as raised by the assessee deserves to be allowed and the impugned addition cannot be sustained

Bench: Justice (Retd.) C.V. Bhadang(), Shri Mahavir Singh & Shri Brajesh Kumar Singh[Assessment Year: 2012-13] Mahesh Kumar, Vs Ito, 6/305/1A, Doonger Ward-68(6), Mohalla, Delhi-110032. Delhi. Pan-Aoopk6335A Appellant Respondent Appellant By Shri Neeraj Mangla, Ca Respondent By Shri Krishna K. Ramawat, Sr. Dr Date Of Hearing 06.08.2025 Date Of Pronouncement 06.08.2025

unexplained u/s 68 of the Act amounting to Rs.15.48 lakhs and another addition of purchase of property added u/s 68 of the Act amounting to Rs.20,62,375/-. We noted that very basis of reasons recorded for issuance notice for re-opening of assessment u/s 147 r.w.s 148 of the Act does not survive, the re-opening

INCOME TAX OFFICER, WARD 3(1), DELHI, DELHI vs. ARTISTIC FINANCE PRIVATE LIMITED, DELHI

In the result, Ground no. 3 as raised by the assessee deserves to be allowed and the impugned addition cannot be sustained

Bench: Justice (Retd.) C.V. Bhadang(), Shri Mahavir Singh & Shri Brajesh Kumar Singh[Assessment Year: 2012-13] Mahesh Kumar, Vs Ito, 6/305/1A, Doonger Ward-68(6), Mohalla, Delhi-110032. Delhi. Pan-Aoopk6335A Appellant Respondent Appellant By Shri Neeraj Mangla, Ca Respondent By Shri Krishna K. Ramawat, Sr. Dr Date Of Hearing 06.08.2025 Date Of Pronouncement 06.08.2025

unexplained u/s 68 of the Act amounting to Rs.15.48 lakhs and another addition of purchase of property added u/s 68 of the Act amounting to Rs.20,62,375/-. We noted that very basis of reasons recorded for issuance notice for re-opening of assessment u/s 147 r.w.s 148 of the Act does not survive, the re-opening

ITO, WARD- 21(4), NEW DELHI vs. RUKMINI IRON PVT. LTD., DELHI

In the result, the Cross Objection of the assessee is allowed and the appeal filed by the Revenue is dismissed

Bench: Shri C.M. Garg & Shri Pradip Kumar Kediaassessment Year: 2009-10 Ito, Vs. Rukmini Iron Pvt. Ltd., Ward-21(4), X-55/102, Loha Mandi, New Delhi. Naraina, Delhi. Pan: Aaccr7910H Co No.66/Del/2018 (Ita No.550/Del/2018) Assessment Year: 2009-10 Rukmini Iron Pvt. Ltd., Vs. Ito, X-55/102, Loha Mandi, Ward-21(4), Naraina, New Delhi. Delhi. Pan: Aaccr7910H (Appellant) (Respondent) Assessee By : Shri Suresh Gupta, Ca Revenue By : Shri Ramdhan Meena, Sr. Dr Date Of Hearing : 29.08.2022 Date Of Pronouncement : 20.09.2022 Order Per C.M. Garg, Jm: This Appeal Filed By The Revenue Is Directed Against The Order Dated 26.10.2017 Of The Cit(A)-38, Delhi, Relating To Assessment Year 2009-10. In This Case, The Assessee Has Filed A Cross Objection. Co No.66/Del/2018 2. The Grounds Of Appeal Raised By The Revenue Read As Under:- “1. "On The Facts & Under The Circumstances Of The Case, The Ld Cit(A) Has Erred In Law & Facts In Deleting The Addition Of Rs. 2,40,00,000/- Made By The Ao U/S 68 Of Income Tax Act, 1961, Ignoring The Decision Of The Ld. Cit (A) In The Case Of Surender Kumar Jain (S. K. Jain) Wherein, It Is Held That Jain Brothers Are Equally Involved In The Accommodation Entry Business & Maintain The Documents & Record. " 2. "On The Facts & Under The Circumstances Of The Case, The Ld Cit(A) Has Erred In Law & Facts In Deleting The Addition Of Rs 2,40,00,000/- Under Section 68 Of The Act By Ignoring The Ratio Decidendi In The Case Of Cit Vs. M/S N. R. Portfolio Pvt. Ltd. (2014), 2 Itr-Ol-68 & Pcit-7 Vs. Bikram Singh In It A No. 55/2017 Dated 25/08/2017 On Identical Issue Of Addition As Unexplained Share Capital U/S 68 Of The It Act. 3 The Appellant Craves To Be Allowed To Add & Alter Any Fresh Grounds(S) Of Appealand/Or Delete Or Amend Any Of The Ground(S) Of Appeal."

unexplained credit u/s 68 of the Act in the books of account of the assessee. Thereafter, in para 15.1, the AO noted that it was clear that the assessee has not disclosed fully and truly all material facts necessary for its assessment for assessment year 2009-10. Therefore, he has reason to believe that entry found and seized cash/cheque book

ACIT, CIRCLE-26(2), NEW DELHI vs. VIKRAM ELECTRIC EQUIPMENT P.LTD, NEW DELHI

The appeal of the Revenue is dismissed as\ninfructuous

unexplained credits u/s\n68 of the I.T. Act, 1961 without calling for any report from\nthe AO inspite of the fact that the AO in his order dated\n31.12.2016 passed u/s 147/143(3) of the I.T. Act, 1961 had\nclearly mentioned that no much time was left with him\nduring the assessment proceedings to verify the identity,\ngenuneness and creditworthiness

PASSION REALTECH PVT LTD,GURGAON vs. ACIT, CENTRAL CIRCLE-2, FARIDABAD

In the result, Appeals in ITA

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

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

PASSION REALTECH PVT LTD,GURGAON vs. ;ACIT, CENTRAL CIRCLE-2, FARIDABAD

In the result, Appeals in ITA

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

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

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

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