SEEMA GOEL,DELHI vs. CIT A, DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

148A(b). Thereafter, the Revenue issued notices under Section 148 of the new regime between July and August 2022. Invalidation of the Section 148 notices issued under the new regime on the ground that they were issued beyond the time limit specified under the Income Tax Act read with TOLA will completely frustrate the judicial exercise undertaken

SEEMA GOEL,DELHI vs. CIT A, DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

148A(b). Thereafter, the Revenue issued notices under Section 148 of the new regime between July and August 2022. Invalidation of the Section 148 notices issued under the new regime on the ground that they were issued beyond the time limit specified under the Income Tax Act read with TOLA will completely frustrate the judicial exercise undertaken

K K SPUN INDIA LIMITED,DELHI vs. DCIT CENTRAL CIRCLE-2 NEW DELHI, JHANDEWALAN DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

148A(b). Thereafter, the Revenue issued notices under Section 148 of the new regime between July and August 2022. Invalidation of the Section 148 notices issued under the new regime on the ground that they were issued beyond the time limit specified under the Income Tax Act read with TOLA will completely frustrate the judicial exercise undertaken

K K SPUN INDIA LIMITED,DELHI vs. DCIT, JHANDEWALAN DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

148A(b). Thereafter, the Revenue issued notices under Section 148 of the new regime between July and August 2022. Invalidation of the Section 148 notices issued under the new regime on the ground that they were issued beyond the time limit specified under the Income Tax Act read with TOLA will completely frustrate the judicial exercise undertaken

THE HISAR LEADING BANK CO-OP NON-AGRI THRIFT & CREDIT SOCIETY,HISAR vs. INCOME-TAX OFFICER, WARD-1, HISAR, HISAR

In the result, Appeal of the Assessee is allowed

sections": [ "147", "144B", "68", "115BBE", "148", "148A", "149", "151", "139(1)", "142(1)", "163", "132", "132A" ], "issues": "Whether the notice

AP GOYAL CHARITABLE TRUST ,EAST DELHI, DELHI INDIA vs. ITO, CIVIC CENTRE,NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshap Goyal Charitable Trust, Vs. Ito, Ward B-125, Anand Vihar, Exempt-1(1), East Delhi, Delhi-110092 Delhi, Civic Centre, Delhi-110002 (Appellant) (Respondent) Pan: Aabta8575B

68. In addition to the above, the time granted to the petitioner to respond to the notice dated 30.05.2022-the period of two weeks-is also required to be excluded by virtue of the third proviso to Section 149 (1) of the Act. The petitioner had furnished its response to the notice under Section 148A

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-

148A(d) of the Act; for the purpose of assessing its alleged unexplained transactions. The Revenue could hardly dispute the clinching fact that the learned lower authorities had obtained the necessary approval of the learned Principal Commission of Income Tax -7, Delhi, under 2 | P a g e ITA No.602/Del/2025 & C.O. No. 106/Del/2025 section

INCOME TAX OFFICER, WARD-20(3), DELHI, NEW DELHI vs. RMP HOLDINGS PVT LTD, NEW DELHI

In the result the appeal of the Revenue is dismissed

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2017-18 Ito, Vs. Rmp Holdings Pvt. Ltd. New Delhi 138-C, Block -B Group -4 Dilshad Garden New Delhi Pan No.Aaacr5533N (Appellant) (Respondent)

section 147 r.w.s 144B of the Income ( in short “the Act”) dated 23-05-2023 for A.Y. 2017-18. 2. The assessee has raised the following grounds in appeal: “1. Whether on the fact and circumstances of the case and in law. The Ld. CIT(A) while allowing the appeal on the issue had incorrectly interpreted the judgment

AP GOYAL CHARITABLE TRUST,EAST DELHI, DELHI INDIA vs. ITO, CIVIC CENTRE,NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

68 and provisions of section 115BBE of the Act also invoked. Further addition of Rs. 7,500/- was also made as Income from Other Sources. 3. Against this order, an appeal was filed before the Ld. CIT(A) who vide impugned order dt. 27.01.2025 dismissed the appeal of the assessee by not admitting the same in terms of section

ACIT CIRCLE-28(1), NEW DELHI vs. MUNJAL HOLDINGS, NEW DELHI

In the result, appeal of the Revenue is dismissed

Bench: SHRI SUDHIR KUMAR (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

68 of the Act and further addition of Rs. 170,84,24,858/- was made by holding the short-term capital loss as ingenuine loss. 3. Against the said order, assessee preferred an appeal before Ld. CIT(A), who allowed the appeal of the assessee on the ground that the very foundation of assessment i.e. the notice

TRAVELPORT GLOBAL DISTRIBUTION SYSTEM BV,NETHERLAND vs. THE ASSISTANT COMMISSIONER OF INCOME TAX,, NEW DELHI

In the result, Appeal of the Assessee is allowed

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Travelport Global Distribution Vs Assistant Commissioner Of System Bv, Taurusavenue Income Tax, Circle 33A-2132 Ls, Po Box 3064- International Taxation 1(3)(1) 2130Kb, Hoofddrop, The Civic Centre, Minto Road, Netherlands, Netherland New Delhi Pan: Aaccg2258D Appellant Respondent Assessee By Sh. S. K. Agarwal, Adv, Sh. Vibha Bansal, Ca & Sh. Arihant Jain, Ca Revenue By Sh. Saroj Kumar Dubey, Cit(Dr) Date Of Hearing 28/08/2025 Date Of Pronouncement 24/10/2025 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Final

68. In addition to the above, the time granted to the petitioner to respond to the notice dated 30.05.2022 – the period of two weeks – is also required to be excluded by virtue of the third proviso to Section 149(1) of the Act. The petitioner had furnished its response to the notice under Section 148A

SANGEETA KHANDELWAL,NEW DELHI vs. DCIT, CIRCLE 28 (1), DELHI, NEW DELHI

In the result, Appeals of the Assessee are allowed

Bench: Shri Yogesh Kumar U.S. & Shri Naveen Chandra

68. In addition to the above, the time granted to the petitioner to respond to the notice dated 30.05.2022 – the period of two weeks – is also required to be excluded by virtue of the third proviso to Section 149(1) of the Act. The petitioner had furnished its response to the notice under Section 148A

SANGEETA KHANDELWAL,NEW DELHI vs. DCIT, CIRCLE 28 (1), DELHI, NEW DELHI

In the result, Appeals of the Assessee are allowed

Bench: Shri Yogesh Kumar U.S. & Shri Naveen Chandra

68. In addition to the above, the time granted to the petitioner to respond to the notice dated 30.05.2022 – the period of two weeks – is also required to be excluded by virtue of the third proviso to Section 149(1) of the Act. The petitioner had furnished its response to the notice under Section 148A

MITTAL HOMES PVT LTD,DELHI vs. ITO WARD-17(1), DELHI

In the result, the appeal of the Assessee is allowed

68", "Section 143(1)(a)", "Section 148", "Section 148A(b)", "Section 149", "Section 151"], "issues

DCIT CIRCLE 43(1), NEW DELHI vs. CHARU GOEL, DELHI

In the result,the appeal filed by the Revenue and the Cross

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.4863/Del/2024 िनधा"रणवष"/Assessment Year: 2014-15 Dcit, Vs. Charu Goel, Circle 43(1), 6/22, East Punjabi Bagh, 1704, 17Th Floor, E 2 Block, New Delhi. Civic Centre, New Delhi. Pan No.Aalpg3062F अपीलाथ" Appellant ""यथ"/Respondent & Co No.16/Del/2025 (Arising Out Of Ita No.4863/Del/2024) िनधा"रणवष"/Assessment Year: 2014-15 बनाम Charu Goel, Dcit, 6/22, East Punjabi Bagh, Vs. Circle 43(1), 1704, 17Th Floor, E 2 Block, New Delhi. Pan No.Aalpg3062F Civic Centre, New Delhi. अपीलाथ" Appellant ""यथ"/Respondent

68. After 1 April 2021, the Income-tax Act has to be read along with the substituted provisions. The substituted provisions apply retrospectively for past assessment years as well. On 1 April 2021, TOLA was still in existence, and the Revenue could not have ignored the application of TOLA and its notifications. Therefore, for issuing are assessment notice under section

RAJESH BATRA,NEW DELHI vs. ITO WARD 29(1), DELHI

In the result ITA No.4420/Del/2025 is allowed

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A Nos.4419, 4420 & 4421/Del/2025 िनधा"रणवष"/Assessment Years:2012-13, 2014-15 & 2015-16 बनाम Shri Rajesh Batra, Income Tax Officer, B-96, Shivalik, New Delhi. Vs. Ward 29(1), Pan No.Aahpb4919N Delhi. अपीलाथ" Appellant ""यथ"/Respondent

68. After 1 April 2021, the Income-tax Act has to be read along with the substituted provisions. The substituted provisions apply retrospectively for past assessment years as well. On 1 April 2021, TOLA was still in existence, and the Revenue could not have ignored the application of TOLA and its notifications. Therefore, for issuing are assessment notice under section

RAJESH BATRA,NEW DELHI vs. ITO WARD 29(1), DELHI

In the result ITA No.4420/Del/2025 is allowed

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A Nos.4419, 4420 & 4421/Del/2025 िनधा"रणवष"/Assessment Years:2012-13, 2014-15 & 2015-16 बनाम Shri Rajesh Batra, Income Tax Officer, B-96, Shivalik, New Delhi. Vs. Ward 29(1), Pan No.Aahpb4919N Delhi. अपीलाथ" Appellant ""यथ"/Respondent

68. After 1 April 2021, the Income-tax Act has to be read along with the substituted provisions. The substituted provisions apply retrospectively for past assessment years as well. On 1 April 2021, TOLA was still in existence, and the Revenue could not have ignored the application of TOLA and its notifications. Therefore, for issuing are assessment notice under section

RAJESH BATRA,NEW DELHI vs. ITO, WARD 29(1), DELHI

In the result ITA No.4420/Del/2025 is allowed

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A Nos.4419, 4420 & 4421/Del/2025 िनधा"रणवष"/Assessment Years:2012-13, 2014-15 & 2015-16 बनाम Shri Rajesh Batra, Income Tax Officer, B-96, Shivalik, New Delhi. Vs. Ward 29(1), Pan No.Aahpb4919N Delhi. अपीलाथ" Appellant ""यथ"/Respondent

68. After 1 April 2021, the Income-tax Act has to be read along with the substituted provisions. The substituted provisions apply retrospectively for past assessment years as well. On 1 April 2021, TOLA was still in existence, and the Revenue could not have ignored the application of TOLA and its notifications. Therefore, for issuing are assessment notice under section