DY. COMMISSIONER OF INCOME TAX, NOIDA vs. M/S RUDRA BUILDWELL HOMES PVT. LTD, DELHI

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2016-17 Vs. M/S. Rudra Buildwell Homes Dcit, Central Circle-I, Noida Pvt. Ltd., 53, Okhla Phase, Delhi Pan: Aafcr6959P (Appellant) (Respondent) With C.O. No.106/Del/2025 [Arising Out Of Ita No.602/Del/2025] Assessment Year: 2016-17 M/S. Rudra Buildwell Vs. Dcit, Central Circle-I, Homes Pvt. Ltd., Noida A-66, Sector-63, Noida Pan: Aafcr6959P (Appellant) (Respondent) Assessee By Sh. Rohit Kapoor, Adv. Sh. Veersen Agarwal, Itp Department By Sh. Rajesh Chandra, Cit(Dr) Date Of Hearing 12.08.2025 Date Of Pronouncement 29.08.2025 Order Per Satbeer Singh Godara, Jm This Revenue’S Appeal Ita No.602/Del/2025 & Assessee’S Cross Objection C.O. No. 106/Del/2025 For Assessment Year 2016-

144B proceeded by section 143(3) assessment completed in its case on 29.12.2018 along with books of account etc. It further places strong reliance on learned CIT(A)’s detailed discussion deleting the impugned addition. 8. We have given our thoughtful consideration to the Revenue’s and the assessee’s foregoing vehement rival submissions. We are of the considered

COMPAREX INDIA P.LTD,NEW DELHI vs. ITO, CIRCLE-4(2), NEW DELHI

In the result, the appeal filed by the assessee is partly allowed

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

68,496/- instead of INR 1,69,80,644- 2. On the facts and in law, the Ld. AO has erred while computing the tax liability for relevant AY by not allowing deduction on account of Section 80G amounting to INR 15,14,475/- already claimed by the Appellant in its Return of Income. Interest and Penalty Grounds

SAVEGENIE E-MARKETING PRIVATE LIMITED,GURGAON vs. ITO, WARD-4(1), GURGOAN

In the result, the appeal of the assessee in ITA No

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

section 68 of the IT Act 1961 and added back to the assessee's total income for the year under consideration vide his order u/s 147 r.w. 144B

HARISH NARANG,PANIPAT vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, ROHTAK, ROHTAK

In the result, the appeal of the assessee is dismissed

Bench: Shri Anubhav Sharma& Shri Amitabh Shukla[Assessment Year: 2018-19] Harish Narang, The Principal Commissioner Of H. No.238, Ward No.8, Income Tax, Rohtak, Panipat, Haryana-132103 Vs Aayakar Bhawan, Opp. Mansarover Park, Rohtak, Haryana-124001 Pan:Acvpn4090J Appellant Respondent Assessee By Shri Amit Kaushik, Adv. Revenue By Ms. Amisha S. Gupt, Cit(Dr) Date Of Hearing 16.10.2025 Date Of Pronouncement 31.12.2025

144B of the ld. AO dated 16.03.2023 alludes that the response of the assessee to the statutory notices was Page 4 of 19 lukewarm. Perusal of pages 7 to 19 of the order of ld. AO dated 16.03.2023 (supra) indicates that he has meticulously analyzed the evidences at hand to conclude that the conclusion drawn in the order under section

ECOENERGY INSIGHTS LTD ( FORMERLY KNOWN AS CHUBB ALBA CONTROL SYSTEMS P.LTD),NEW DELHI vs. DCIT, CIRCLE-4(2), NEW DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaecoenergy Insights Ltd., Vs. Dcit, (Formerly Known As Chubb Alba Control Circle 4 (2), Systems P. Ltd.), New Delhi. Ground Floor, 18, Netaji Subhash Marg, Daryaganj, New Delhi – 110 002. (Pan :Aaaca0031C) (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao, Advocate Shri Parth, Advocate Shri Pratik Rath, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 12.08.2025 Date Of Order : 10.11.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 25.07.2022Passed By The Assessment Unit, Income Tax Department Under Section 147 Read With Section 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Ay 2018-19 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act.

144B(8). Further section 1448 details functions of Assessment Unit, Technical unit, Verification Unit and Review Unit (section 1448(3)]. Section 130 facilitates concurrent jurisdiction for faceless assessment officers. Careful consideration of section 1448 would show that there is no provision for Technical Unit to make reference to TPO, as Technical Unit itself is authorised

INCOME TAX OFFICER, WARD-29(1), DELHI, DELHI vs. M/S. DISCOVERY SALES, DELHI

Bench: Shri Anubhav Sharma & Shri Manish Agarwalito, Ward 29(1) Vs. M/S Discovery Sales Room No. 1002, E-2 Csc-11, Rbi Colony, Block, Civic Centre, Panchsheel Park Minto Road Delhi – 110016 Delhi – 110002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aacad8701C Appellant .. Respondent

68, it could not pass final order by adding said amount as 'unexplained money' under section 69A without giving assessee an opportunity to explain. 8.2.2 Thus, considering the facts of the issue, discussions made above and also respectfully relying on the judgments cited supra, it is held that the AO has not followed the provisions of section 144B

AMWAY INDIA ENTERPRISES PVT. LTD.,NEW DELHI vs. ADDI. NATIOANL E- ASSESSMENT CENTRE, NEW DELHI

In the result, the appeal filed by the assessee is partly allowed

Bench: Shri R.K. Panda & Shri Challa Nagendra Prasadassessment Year: 2016-17 Amway India Enterprises Pvt. Ltd., Vs Addl. National E-Assessment 1St Floor, Elegance Tower, Centre, Plot No.8, Non Heirarchial New Delhi. Commercial Centre, Jasola Vihar, New Delhi – 110 025. Pan: Aaaca5603Q (Appellant) (Respondent) Assessee By : Shri Sudesh Kumar Garg, Advocate Ms Bhavya Garg, Ca & Shri Prince Bansal, Ca Revenue By : Shri Surender Pal, Cit, Dr Date Of Hearing : 08.02.2022 Date Of Pronouncement : 30.03.2022 Order Per R.K. Panda, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30Th April, 2021 Passed By The Ao U/S 143(3)/144C(13) R.W.S. 144B Of The It Act, 1961 For The Assessment Year 2016-17. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Wholly Owned Subsidiary Of Amway Corporation Engaged In The Business Of Direct Selling Of Consumer Products. It Sells Its Products Through Multi-Level Marketing (Mlm). Mlm Marketing Allows Direct Sellers To Build A Business Through Their Own Sales Efforts & Inviting Others To Become Direct Sellers. The Assessee Filed Its Return Of Income On 30.11.2016 Declaring A Loss Of Rs.113,69,23,009/-. Since The Assessee Had Entered Into Certain International Transactions With Its Ae, The Ao Referred The Matter To The Tpo For Determination Of The Alp Of The International Transaction Entered Into By It.

144B of the IT Act, 1961 for the assessment year 2016-17. 2. Facts of the case, in brief, are that the assessee is a wholly owned subsidiary of Amway Corporation engaged in the business of direct selling of consumer products. It sells its products through multi-level marketing (MLM). MLM marketing allows direct sellers to build a business through

JONES LANG LASALLE PROPERTY CONSULTANTS (INDIA) PRIVATE LIMITED,DELHI, INDIA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 13(1), DELHI, INDIA

In the result, the appeal of the assessee is allowed and the Stay

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2020-21 & Stay Application No.61/Del/2025 ( In Ita No. 3964/Del/2024 ) Assessment Year: 2020-21

144B of the Act is time barred having been passed beyond the time limit prescribed under section 144C(13) for completion of assessment. 4. In the alternative to ground no. 3, directions issued by Ld. DRP under section 144C(5) have been issued beyond time limit prescribed under section 144C(12). 5. Without prejudice to the above

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-49(1) , NEW DELHI vs. SURESH KUMAR GOYAL, NEW DELHI

The appeal is allowed

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 2018-19 Vs. Sh. Suresh Kumar Goyal, Acit, Circle-49(1), A-1/102, Ground Floor, New Delhi Janak Puri, Delhi Pan: Aaapg4996R (Appellant) (Respondent) Assessee By None Department By Sh. Manish Gupta, Sr. Dr

section 68, as follows: “2. Facts of the case: The appellant is an individual and was running the business of waste and metal scrap from the last several years in the name of M/s Goyal Iron & Steel Traders. Assessee filed his original Return of Income on 31.10.2018 declaring total income of Rs. 22,79,120/- and a revised Return

ACIT, NEW DELHI vs. SHRI HRIDEY VIKRAM BHATIA, NEW DELHI

The appeal is allowed

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 2018-19 Vs. Sh. Suresh Kumar Goyal, Acit, Circle-49(1), A-1/102, Ground Floor, New Delhi Janak Puri, Delhi Pan: Aaapg4996R (Appellant) (Respondent) Assessee By None Department By Sh. Manish Gupta, Sr. Dr

section 68, as follows: “2. Facts of the case: The appellant is an individual and was running the business of waste and metal scrap from the last several years in the name of M/s Goyal Iron & Steel Traders. Assessee filed his original Return of Income on 31.10.2018 declaring total income of Rs. 22,79,120/- and a revised Return

MANOJ KUMAR,PANIPAT vs. INCOME TAX OFFICER, WARD -1, PANIPAT, PANIPAT

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2018-19] Manoj Kumar Vs Ito Prop. Avitex India, Barsat Ward-1 Road, Opp.Kirpal Ashram, Panipat Panipat, Haryana-132103. Pan-Aaepo2553J Appellant Respondent Assessee By Shri Suresh Kumar Gupta, Ca Revenue By Ms. Amisha S.Gutpa, Cit Dr Date Of Hearing 27.11.2025 Date Of Pronouncement 29.01.2026 Order Per Manish Agarwal, Am : The Captioned Appeal Is Filed By Assessee Against The Order Dated 27.03.2025 Passed By Ld. Pr. Commissioner Of Income Tax, Rohtak [“Ld. Pr. Cit”] U/S 263 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 24.02.2023 Passed U/S 147 R.W.S. 144B Of The Act Pertaining To Assessment Year 2018-19. 2. Brief Facts Of The Case Are That The Assessee Filed His Return Of Income On 18.10.2018, Declaring Total Income Of Inr 5,12,820/-. Based On The Available That The Assessee Had Accepted Accommodation Entries In The Form Of Bogus Purchases From M/S. Soni Textiles Of Inr 11,47,500/-, Case Was Re-Opened By Issue Of Notice U/S 148 On 29.03.2022. In Response To The Notice, Assessee Filed Return Of Income On 25.11.2022, Declaring Total Income Of Inr 5,12,820/-. Thereafter, Various Notices Were Issued From Time To Time However, Were Remained Uncompiled With. Thereafter, Ao Vide Order Dated 24.02.2023 Passed U/S 147 R.W.S. 144B Of The Act Assessed The Income Of The Assessee At Inr 16,60,320/- By Making Addition Of Alleged Bogus Purchases.

144B of the Act assessed the income of the assessee at INR 16,60,320/- by making addition of alleged bogus purchases. 3. Thereafter, ld. PCIT has initiated the revision proceedings u/s 263 of the Act vide issue of show cause notice on 18.03.2025 and when no reply was filed by the assessee, the ld. PCIT pass the impugned order

SANDEEP KUMAR,NEW DELHI vs. ITO - WARD 1, PANIPAT, PANIPAT

In the result, appeal of the assessee is allowed

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2018-19] Sandeep Kumar, Vs Ito C/O-B-50, Lgf, South Ward-1 Extension Part-Ii, Panipat New Delhi -110049 Pan-Aueps5626A Appellant Respondent Appellant By Shri Shantanu Jain, Adv. Ms. Jahnavi Khanna, Adv. Shri Gurjeet Singh, Ca Respondent By Shri Khitesh Gupta, Sr.Dr Date Of Hearing 26.11.2025 Date Of Pronouncement 28.11.2025 Order

144B of the Act dated 24.03.2023 which is sought to be revised u/s 263 of the Act itself was invalid on various grounds and thus proceedings initiated u/s 263 of the Act against the invalid reassessment order is clearly bad in law. 6. That the appellant craves the leave to add, amend, modify, DLEETE any of the grounds of appeal

JOGINDER KUMAR & SONS HUF,PANIPAT vs. PCIT ROTAK, ROTAK

In the result, the appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwaljoginder Kumar & Sons Huf Pcit, 352/6, Near S D Modern School, Rohtak. Panipat-132103. Vs. Pan- Aachj6257L (Appellant) (Respondent) Assessee By Shri Dhurv Goel, Ca Department By Shri Pradumna Kumar Singh, Sr. Dr Date Of Hearing 04.09.2025 Date Of Pronouncement 27.11.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of The Ld. Principal Commissioner Of Income Tax, Rohtak (‘The Pcit’ In Short) Passed U/S 263 Of The Income Tax Act, 1961 Dated 21.03.2025 Wherein The Ld. Pcit Held The Assessment Order As Erroneous & Prejudicial To The Interest Of The Revenue In Terms Of Explanation 2 Of Section 263 & Direct The Ao To Conduct Fresh Enquiries & Passed The Speaking Order.

144B of the Action 27.03.2023. 2. The return of income for A.Y. 2018-19 was filed by you on 29.10.2018 declaring total income of Rs. 16,22,290/-. The case was reopened u/s 147 of the Income Tax Act, 1961. The assessment u/s 147 of the Income Tax Act, 1961 was completed on 27.03.2023 at assessed income

CHINTAMANI COMMODITIES,JHILMIL INDUSTRIAL AREA vs. PCIT, DELHI

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singhchintamani Commodities Vs. Pcit, 20 A-20, Jhilmil Industrial Room No. 106, Vikas Area, Shahdhra Bhawan, I P Estate Delhi - 110095 Delhi – 110002 "थायीलेखासं./जीआइआरसं./Pan/Gir No:Aagfc9374B Appellant .. Respondent

68 of the Act, the PCIT wrongly mentioned the same under Section 69C of the Act which is factually incorrect as rightly pointed out by the Ld. Counsel for the assessee appearing before us. Furthermore, the submission made on the legal ground that once the order passed by the Ld. AO under Section 147 r.w.s 144B

ITO-28(1), CIVIC CENTER NEW DELHI vs. ARPITAM BUILDERS LLP, SOUTH DELHI

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2022-23] Ito, Vs Arpitam Builders Llp G-3, Ward 28(1), 2Nd Floor, Maharani E-2 Block, Bagh, East Of Kailash, Civic Center. Delhi-110065. New Delhi-110002 Pan: Abqfa2725F Appellant Respondent Appellant By Shri Dayainder Singh Sidhu, Cit Dr Respondent By Shri Mayank Patwari & Shri Akash Ojha, Advocates Date Of Hearing 18.08.2025 Date Of Pronouncement 07.11.2025 Order Per Manish Agarwal, Am :

144B of the Act by assessing the total income at Rs.15,68,27,535/- by making addition of Rs.15,65,35,565/- alleging the same as unexplained cash credit u/s 68 of the Act. 3. Against this order, assessee preferred an appeal before Ld. CIT(A), who after considering the submissions, vide impugned order dated 26.12.2024, allowed the appeal

ARVIND KUMAR PROP. M/S SHREE BALAJI TRADING CO.,PANIPAT vs. ADDL/JT/ASST COMMISSIONER OF INCOME TAX/INCOME TAX OFFICER, NFAC, DELHI, DELHI

In the result, the appeal of the assessee is partly allowed for statistical\npurposes as indicated above

sections": [ "147", "148", "143(2)", "142(1)", "68", "115BBE", "151", "144B" ], "issues": "Whether the cash deposits made during the demonetization

AJAY KUMAR,KARNAL vs. ITO,WARD-1, KARNAL

In the result, appeal of the assessee is partly allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2013-14] Ajay Kumar, Vs Ito, 399, M/S. Ajay Enterprises, Ward-1, Karnal G.T.Road, New Anaj Mandi, Karnal, Haryana-132001. Pan-Agipk1566F Appellant Respondent Appellant By Shri Rajiv Sachdeva, Ca Respondent By Shri Ajay Kumar Arora, Sr.Dr Date Of Hearing 15.07.2025 Date Of Pronouncement 10.10.2025 Order

144B of the Act pertaining to assessment year 2013-14. 2. Brief facts of the case are that the assessee is an individual and engaged in the business of trading of food grains. The return of income was filed on 30.09.2013, declaring total income of INR 4,21,380/-. The AO received information from the office of DDIT (Inv.), Panipat

M/S FAIRDEAL INFORMATION TECHNOLOGY PRIVATE LIMITED,NEW DELHI vs. INCOME TAX OFFICER, WARD 9(1), DELHI

In the result all the three grounds of appeal of the assessee are allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalm/S Fairdeal Information Income Tax Officer, Technology Private Limited, Ward-9(1), 116A, First Floor, Somdutt Vs. New Delhi. Chamber-1, 5, Bhikaji Cama Place, New Delhi-110066. Pan-Aaacf9581G (Appellant) (Respondent) Assessee By Shri Ashwani Kumar, Ca & Shri Ankur Agarwal, Ca Department By Ms. Indu Bala Saini, Sr. Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 13/02/2026

144B of the Act dated 22.05.2023 by making addition of Rs.13,58,00,000/- u/s 68 of Act. 3. Against the said order, assessee preferred an appeal before Ld. CIT(A) who allowed part relief to the assessee and deleted the additions of Rs.1,58,00,000/- on account of loans received, however, confirmed the additions of Rs.12