PME POWER SOLUTIONS INDIA LTD,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, NEW DELHI

In the result, both the appeal of the assessee are allowed

Bench: Shri M. Balaganesh & Shri Vimal Kumar

68,480/-. The assessee preferred an appeal before the learned CIT(A), who dismissed the appeal in limine on the ground that the tax due on the returned income was not paid by the assessee and hence in terms of section 249(4) of the Act, the appeal would not be maintainable. Aggrieved, the assessee is in appeal before

PME POWER SOLUTIONS INDIA LTD,NEW DELHI vs. DY. COMMISSIONER OF INCOME TAX, NEW DELHI

In the result, both the appeal of the assessee are allowed

Bench: Shri M. Balaganesh & Shri Vimal Kumar

68,480/-. The assessee preferred an appeal before the learned CIT(A), who dismissed the appeal in limine on the ground that the tax due on the returned income was not paid by the assessee and hence in terms of section 249(4) of the Act, the appeal would not be maintainable. Aggrieved, the assessee is in appeal before

SRI JAGDISH PRASAD SHARMA,NEW DELHI vs. ITO, GHAZIABAD

The appeal of the assessee is dismissed

Bench: Shri Prashant Maharishi & Shri K.N.Charysri Jagdish Prasad Sharma, Vs. Ito, C/O. Mr. Sandeep Bhatnagar, Ward-1(3), Flat No. 12, 2Nd Floor, Sheel Tara Ghaziabad House, 4866/24, Ansari Road, Darya Ganj, New Delhi Pan: Azpps2130R (Appellant) (Respondent)

Section 68 upheld. (Krishan Kumar Jhamb Vs ITO & Anr (P&H) 17 DTR 249). (xii) Hon. Supreme Court in CIT v. Durga Prasad More [1971] 82 ITR 540 , at pages 545-547 made a reference to the test of human probabilities stating that “this raises the question whether the apparent can be considered as real. As laid down

VIJAY AGGARWAL,DELHI vs. ITO, WARD- 48(5), NEW DELHI

In the result, all the appeals of different assessees are partly allowed

Bench: : Shri Bhavnesh Saini & Shri L.P. Sahuassessment Year: 2010-11

3 & 4), however, the contract can be revoked before its acceptance is complete or acceptance may be revoked before the communication of acceptance is complete as against the acceptor but not afterwards (Section 5). It is submitted that in the present case both the parties have signed the agreement on 15.09.2009 and so, Section 5 of Indian Contract

ESSAR COMMUNICATIONS LIMITED,MAURITIUS vs. ACIT, CIRCLE-1 (2)(2), NEW DELHI

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI S. RIFAUR RAHMAN (Accountant Member)

Section 6(3) of the IT Act India read with Article 4(3) of the Treaty 26 (II) Judicial Dicta on tests for “control and management of affairs 223-239 situated wholly in India” 27 (III) Case of Dual Residence under the Treaty-Applicability of 235-239 Article 4(3) of Indo Mauritius DTAA Part-B-VI - Rebuttal

S R FOILS & TISSUE LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assesee is dismissed

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year : 2011-12

3). It is well established that each assessment year is separate and distinct and assessment is made on the basis of facts relevant for that year. In the assessment year 2011-12 under consideration, it is revealed from the penalty order that huge addition under section 68 has been made. This has formed the basis of imposition

HIMALAYAN DAIRIES PVT. LTD.,DELHI vs. ITO, WARD- 11(3), NEW DELHI

Bench: Ms Suchitra Kamble & Shri Prashant Maharishihimalayan Dairies Pvt. Ltd, Vs. Ito, Flat No. 10, C-1/2, Model Town, Ward-11(3), New Delhi New Delhi Pan: Aaach0252J (Appellant) (Respondent)

249 ITR 216.” 3. The assessee has raised the following additional grounds of appeal:- “1. That the learned AO and the CIT (A) erred on facts and on law wherein invoking the provisions of section 68

CHARBUJA MARMO (INDIA) PVT. LTD.,DELHI vs. PR.CIT- 2 , NEW DELHI

In the result, appeal of Assessee allowed

Bench: Shri Bhavnesh Saini & Shri B.R.R. Kumar

3) of the I.T. Act, 1961, on Dated 30.06.2014. 3.1. The Ld. Pr. CIT on examining the assessment record noticed that though the assessment was reopened under section 148 of the I.T. Act on the allegation of accommodation entry taken from Shri S.K. Jain group of concerns who were searched on 14.09.2010 by the Investigation Wing of the Income

NIDHI RANI,PANIPAT vs. INCOME TAX OFFICE, WARD-1, PANIPAT, PANIPAT

In the result, appeal of the assessee is allowed

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] Smt. Nidhi Rani Vs Ito 1361, Sector-25, Part-Ii Ward-1, Panipat, Haryana-132103 Panipat Pan-Arrpr9400P Appellant Respondent Appellant By Dr. Rakesh Gupta, Adv. Shri Somil Agarwal, Adv. & Shri Saksham Agarwal, Ca Respondent By Shri Shyam Manohar Singh, Sr.Dr Date Of Hearing 24.09.2025 Date Of Pronouncement 19.12.2025 Order

3. 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. A.O in making addition of Rs.3,37,97,251/- on account of estimation of profit and has further erred in rejecting the books of accounts of the assessee and impugned order

M/S. SRI BALAJI FORGINGS (P) LTD.,NEW DELHI vs. PR. CIT- 8, NEW DELHI

In the result, appeal of Assessee is allowed

Bench: Shri Bhavnesh Saini, J.M. & Shri Prashant Maharishi, A.M.

3) of the I.T. Act, 1961, on Dated 30.06.2014. 3.1. The Ld. Pr. CIT on examining the assessment record noticed that though the assessment was reopened under section 148 of the I.T. Act on the allegation of accommodation entry taken from Shri S.K. Jain group of concerns who were searched on 14.09.2010 by the Investigation Wing of the Income

SHRI JANAK GOEL,GURGAON vs. DCIT, NEW DELHI

In the result all, the grounds of appeal raised in the appeal memo as well as the additional ground raised by the assessee are dismissed

Bench: Shri Prashant Maharishi & Shri K.N.Chary

3 different persons. The learned assessing officer accepted the deposit of INR 50,000 out of the cash withdrawal of 9/9/2003. However, with respect to the other explanation he disbelieved and made an addition of INR 48,000/– as unexplained income under section 68 of the income tax act. Further

ACIT, NEW DELHI vs. SH. INDERPAL SINGH WADHAWAN, NEW DELHI

In the result ground No. 2 of the appeal of the assessee is allowed

Bench: I.C.Sudhir & Shri Prashant Maharishiinder Pal Singh Wadhawan, Jcit, E/1/7, Ii Nd Floor, East Patel Vs. Circle-33, Nagar, New Delhi New Delhi Pan: Aarps6904L (Appellant) (Respondent) Acit, Inder Pal Singh Wadhawan, Circle-33(1), Room No.1505, E/1/7, Ii Nd Floor, Vs. 15Th Floor, Dr. Shyama Prasad East Patel Nagar, New Delhi Mukherjee Civil Centre, New Delhi Pan: Aarps6904L (Appellant) (Respondent) Inder Pal Singh Wadhawan, Acit, E/1/7, Ii Nd Floor, East Patel Circle-33, Vs. Nagar, New Delhi New Delhi Pan: Aarps6904L (Appellant) (Respondent) Acit, Inder Pal Singh Wadhawan, Circle-33(1), Room No.1505, 15Th E/1/7, Ii Nd Floor, Vs. Floor, Dr. Shyama Prasad East Patel Nagar, New Delhi Mukherjee Civil Centre, Pan: Aarps6904L New Delhi (Appellant) (Respondent)

68 as unexplained credit in the hands of the assessee therefore we will deal with this issue as and when we deal with the addition made by the Ld. assessing officer which has been deleted by the Ld. CIT (A). In any case, this is a separate transaction which is required to be treated according to the provisions

MR. INDER PAL SINGH WADHAWAN,NEW DELHI vs. JCIT, NEW DELHI

In the result ground No. 2 of the appeal of the assessee is allowed

Bench: I.C.Sudhir & Shri Prashant Maharishiinder Pal Singh Wadhawan, Jcit, E/1/7, Ii Nd Floor, East Patel Vs. Circle-33, Nagar, New Delhi New Delhi Pan: Aarps6904L (Appellant) (Respondent) Acit, Inder Pal Singh Wadhawan, Circle-33(1), Room No.1505, E/1/7, Ii Nd Floor, Vs. 15Th Floor, Dr. Shyama Prasad East Patel Nagar, New Delhi Mukherjee Civil Centre, New Delhi Pan: Aarps6904L (Appellant) (Respondent) Inder Pal Singh Wadhawan, Acit, E/1/7, Ii Nd Floor, East Patel Circle-33, Vs. Nagar, New Delhi New Delhi Pan: Aarps6904L (Appellant) (Respondent) Acit, Inder Pal Singh Wadhawan, Circle-33(1), Room No.1505, 15Th E/1/7, Ii Nd Floor, Vs. Floor, Dr. Shyama Prasad East Patel Nagar, New Delhi Mukherjee Civil Centre, Pan: Aarps6904L New Delhi (Appellant) (Respondent)

68 as unexplained credit in the hands of the assessee therefore we will deal with this issue as and when we deal with the addition made by the Ld. assessing officer which has been deleted by the Ld. CIT (A). In any case, this is a separate transaction which is required to be treated according to the provisions

MR. INDER PAL SINGH WADHAWAN,NEW DELHI vs. ACIT, NEW DELHI

In the result ground No. 2 of the appeal of the assessee is allowed

Bench: I.C.Sudhir & Shri Prashant Maharishiinder Pal Singh Wadhawan, Jcit, E/1/7, Ii Nd Floor, East Patel Vs. Circle-33, Nagar, New Delhi New Delhi Pan: Aarps6904L (Appellant) (Respondent) Acit, Inder Pal Singh Wadhawan, Circle-33(1), Room No.1505, E/1/7, Ii Nd Floor, Vs. 15Th Floor, Dr. Shyama Prasad East Patel Nagar, New Delhi Mukherjee Civil Centre, New Delhi Pan: Aarps6904L (Appellant) (Respondent) Inder Pal Singh Wadhawan, Acit, E/1/7, Ii Nd Floor, East Patel Circle-33, Vs. Nagar, New Delhi New Delhi Pan: Aarps6904L (Appellant) (Respondent) Acit, Inder Pal Singh Wadhawan, Circle-33(1), Room No.1505, 15Th E/1/7, Ii Nd Floor, Vs. Floor, Dr. Shyama Prasad East Patel Nagar, New Delhi Mukherjee Civil Centre, Pan: Aarps6904L New Delhi (Appellant) (Respondent)

68 as unexplained credit in the hands of the assessee therefore we will deal with this issue as and when we deal with the addition made by the Ld. assessing officer which has been deleted by the Ld. CIT (A). In any case, this is a separate transaction which is required to be treated according to the provisions

JINDAL STAINLESS LTD.,HISAR vs. DCIT, NEW DELHI

Accordingly, ground number 2 of the appeal of the learned AO for 2007 – 08 is dismissed

Bench: Smt Diva Singh & Shri Prashant Maharishi

249 HR SS Plate Grade J4 382.805 68,362 2,61,69,462 HR SS Coils JSL Tube HRAP 734.765 56,902 4,18,09,522 The remaining grades of Stainless Steel products were not exported to unrelated parties during the same month in all transactions. Wherever such comparable uncontrolled transactions of export to unrelated parties in the same month

DCIT, NEW DELHI vs. M/S JSL LTD.,, HISAR

Accordingly, ground number 2 of the appeal of the learned AO for 2007 – 08 is dismissed

Bench: Smt Diva Singh & Shri Prashant Maharishi

249 HR SS Plate Grade J4 382.805 68,362 2,61,69,462 HR SS Coils JSL Tube HRAP 734.765 56,902 4,18,09,522 The remaining grades of Stainless Steel products were not exported to unrelated parties during the same month in all transactions. Wherever such comparable uncontrolled transactions of export to unrelated parties in the same month

M/S. HONDA SIEL POWER PRODUCTS LTD.,GAUTAM BUDH NAGAR vs. DCIT, NEW DELHI

In the result, both the appeals of the assessee-company are partly allowed for statistical purposes

Bench: : Shri I.C. Sudhir & Shri L.P. Sahu

68,200 against the returned total income of Rs.31,80,76,602. Transfer Pricing Issues: 2. That the assessing officer erred on facts and in law in making addition to the income of the appellant to the extent of Rs.11,36,67,464 on account of the alleged difference in the arm’s length price of international transactions

ITO WARD - 7(2), NEW DELHI vs. DKS SALES (P) LIMITED, NEW DELHI

Appeal is dismissed in above terms

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2014-15 Vs. M/S. Dks Sales (P) Ltd., Income Tax Officer, Ward-7(2), A-24, A-Block, Kirti Nagar, New Delhi New Delhi Pan: Aaecd4730F (Appellant) (Respondent) Assessee By None Department By Sh. Rajesh Kumar Dhanesta, Sr. Dr

68 of paper book. The outstanding balance of OD account was Rs. 3,03,24,423/- as on 31-03-2014, which can be verified form the financial statement of the appellant company. (Placed at page no 1 to 21 of paper book). Such amount has been transferred to appellant's company current account no 409000074606 maintained also with