ASSISTANT COMMISSIONER OF INCOME TAX, GHAZIABAD vs. JASPAL SINGH SALUJA, GHAZIABAD

Accordingly, the appeal of Revenue is dismissed in the above terms

Bench: Shri Mahavir Singh & Shri Manish Agarwalasstt. Year: 2018-19 Acit Vs Shri Jaspal Singh Saluja 201-202, 2Nd Floor, R-7/21, New Raj Nagar, Cgo-1 Near Purani Hapur Ghaziabad- 201001 Chungi, Kamala Nehru Nagar, Uttar Pradesh Ghaziabad (Appellant) (Respondent) Pan No. Agpss0863Q

deposit like copy of complete cash books and ledger account along with the bank statements, month-wise break-up of cash sales and sales other than cash at different branches, month-wise break-up of the total purchases at different branches, statement of item wise purchases and sales, invoices of sales and purchases, VAT Returns, Rent Agreements, documentary evidence

ATISH SINGLA,NEW DELHI vs. ITO, WARD-43(7), NEW DELHI

In the result, appeal of the Assessee is allowed

Bench: Shri R.K. Panda

transfer the money to SMFOOTWARE but the appellant did not furnished the nature of such payment with documentary evidence. Keeping in view the above facts, the circumstantial evidences do not support the contention of the appellant. The Hon’ble Supreme Court has held in several cases such as Sumati Dayal [1995] 214 ITR 801(SC) that while deciding any issue

DCIT, I.T.O. DELHI vs. RATHI STEEL AND POWER LIMITED, DELHI

In the result the appeal of the Revenue stands dismissed

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraita No.2720/Del/2024, A.Y. 2017-18 Dy. Commissioner Of Vs. Rathi Steel & Power Ltd., Income Tax, Circle-19(1), Chauhan Market, Room No. 221, 2Nd Floor, Madanpur Khadar, C. R. Building, I. P. Estate Near Shopping Complex, New Delhi Sarita Vihar, New Delhi-76 Pan: Aaacr1435K (Appellant) (Respondent) Appellant By Sh. Mayank Patawari, Advocate Respondent By Sh. Ajay Kumar Arora, Sr. Dr Date Of Hearing 13/08/2025 Date Of Pronouncement 10/11/2025 Order Per Avdhesh Kumar Mishra, Am The Appeal Of The Revenue For Assessment Year (‘Ay’) 2017-18 Is Directed Against The Order Dated 27.03.2024 Of The Commissioner Of Income Tax (Appeals)-26, New Delhi [‘Cit(A)’].

price on ex-godown basis. To substantiate the above said reply, the assessee company had duly submitted complete details of sale of such defective materials (Refer Pg 638-646 of PB), from which it is evident that an aggregate of 326 items had been sold through the consignment agents. Further, the Ld. AO did not issue a valid show-cause

DEPUTY COMMISSIONER OF INCOME TAX, NEW DELHI vs. GLOBAL AGRO CORP, NEW DELHI

In the result, appeal of the Revenue is dismissed

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2017-18] Dcit Vs Global Agro Corp, Room No.1704, Plot No.07,1St Floor, E-2 Block, Central Market West Civic Centre, Avenue Road, New Delhi-110002. West Punjabi Bagh, New Delhi-110026. Pan-Aakfg2650A Appellant Respondent Revenue By Shri Dheeraj Kumar Jaiswal, Sr.Dr Assessee By Shri Nitin Gulati, Ca Date Of Hearing 17.09.2025 Date Of 21.11.2025 Pronouncement Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Revenue Against The Order Dated 19.07.2024 Passed By Ld. Commissioner Of Income Tax (A), [“Ld.Cit(A)”], National Faceless Appeal Centre (“Nfac”), Delhi In Appeal No. Cit(A), Delhi-15/10990/2019-20 U/S 250 Of The Income Tax Act,1961 [“The Act”] Arising Out Of The Assessment Order Dated 31.12.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Is A Partnership Firm, Engaged In Export Of Rice & E-Filed Its Return Of Income On 28.09.2017 Declaring Income At Inr 66,28,650/-. The Case Was Selected Through Cass & After Considering The Submissions Made By The Assessee From Time To Time, Assessment Was Completed U/S 143(3) Vide Assessment Order Dated 31.12.2019 Wherein Following Additions Were Made:

transferred to Gandhidham to Delhi and why the cash was not deposited in the bank account at Gandhidham. The assessee in reply stated that the banks at Gandhidham had not accepted the cash since it was demonetized currency and there was heavy rush in the bank therefore, the bank had denied to accept the cash. Under these circumstances, cash

MARUBENI INDIA PVT. LTD

In the result the appeal of the revenue in ITA No

transfer pricing report which it was required to submit by section 92E of the Act, the assessee chose five comparable companies and the average margin came to 8.37%. The TPO computed the arm‟s length remuneration in the following manner: - “Computation of Remuneration at Arm’s Length 2013:DHC:2072-DB ITA 1042/2011 & 1114/2011 Page 5 of 22 Personal

ASHOK KUMAR,HARYANA vs. PR, CIT, ROHTAK, HARYANA

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaassessment Year: 2016-17 Ashok Kumar, Vs Pcit, S/O Naseeb Chand, Rohtak, Dangra Road, Near Bus Stand, Haryana. Tohana, Distt. Fatehabad, Haryana – 125120. Pan: Ammpk4875B (Applicant) (Respondent) Assessee By : Shri Lalit Mohan, Ca Revenue By : Ms Sunita Verma, Cit, Dr Date Of Hearing : 04.03.2024 Date Of Pronouncement : 21.03.2024

transfer of cash deposited by the assessee two concerns namely M/s Edelweiss Broking Ltd and M/s Sharekhan Ltd during the year under consideration. Assessment order dated 06-12-2018 u/s 143(3) of the Act for the A.Y. 16-17 is cancelled with the direction to pass an order afresh in accordance with law keeping in view the observations made

DCIT, CENTRAL CIRCLE, GHAZIABAD vs. SUSHIL TYAGI, DELHI

Accordingly, Ground No. 2 raised by the revenue is dismissed

Bench: Shri M. Balaganesh & Shri Vimal Kumardcit, Vs. Sushil Tyagi, Central Circle, A-2, Ganpati Ghaziabad Apartments, Civil Lines, New Delhi (Appellant) (Respondent) Pan:Aejpt6739A Dcit, Vs. Yogender Singh, Central Circle, J-6A, Sector-23, Ghaziabad Sanjay Nagar, Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Yogender Singh, Vs. Dcit, J-6A, Sector-23, Central Circle, Sanjay Nagar, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Naveen Tyagi, Vs. Dcit, G-302, Vvip Central Circle, Addresses, Raj Nagar Ghaziabad Extention, Ghaziabad (Appellant) (Respondent) Pan:Admpt6420A Sarika Tyagi, Vs. Dcit, H-100, Patel Nagar,- Central Circle, 3, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Afapt5986P Assessee By : Shri Rajeev Khandelwal, Ca Shri Gagan Khandelwal, Adv Shri Jaind Jaiswal, Adv Revenue By: Ms. Sapna Bhatia, Cit Dr Date Of Hearing 23/08/2024 Date Of Pronouncement /10/2024

transfer of the unsecured loan amount. Looking to the facts of the case, it is clear that all the three limbs of a genuine cash credit ie identity, genuineness of transaction and creditworthiness are well established. Therefore no adverse inference needs to be drawn in the matter of this cash credit. 6.5 The assessee company has furnished the following

NAVEEN TYAGI,GHAZIABAD vs. DCIT, CENTRAL CIRCLE , GHAZIABAD

Accordingly, Ground No. 2 raised by the revenue is dismissed

Bench: Shri M. Balaganesh & Shri Vimal Kumardcit, Vs. Sushil Tyagi, Central Circle, A-2, Ganpati Ghaziabad Apartments, Civil Lines, New Delhi (Appellant) (Respondent) Pan:Aejpt6739A Dcit, Vs. Yogender Singh, Central Circle, J-6A, Sector-23, Ghaziabad Sanjay Nagar, Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Yogender Singh, Vs. Dcit, J-6A, Sector-23, Central Circle, Sanjay Nagar, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Naveen Tyagi, Vs. Dcit, G-302, Vvip Central Circle, Addresses, Raj Nagar Ghaziabad Extention, Ghaziabad (Appellant) (Respondent) Pan:Admpt6420A Sarika Tyagi, Vs. Dcit, H-100, Patel Nagar,- Central Circle, 3, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Afapt5986P Assessee By : Shri Rajeev Khandelwal, Ca Shri Gagan Khandelwal, Adv Shri Jaind Jaiswal, Adv Revenue By: Ms. Sapna Bhatia, Cit Dr Date Of Hearing 23/08/2024 Date Of Pronouncement /10/2024

transfer of the unsecured loan amount. Looking to the facts of the case, it is clear that all the three limbs of a genuine cash credit ie identity, genuineness of transaction and creditworthiness are well established. Therefore no adverse inference needs to be drawn in the matter of this cash credit. 6.5 The assessee company has furnished the following

YOGENDER SINGH,GHAZIABAD vs. DCIT, CENTRAL CIRCLE, GHAZIABAD

Accordingly, Ground No. 2 raised by the revenue is dismissed

Bench: Shri M. Balaganesh & Shri Vimal Kumardcit, Vs. Sushil Tyagi, Central Circle, A-2, Ganpati Ghaziabad Apartments, Civil Lines, New Delhi (Appellant) (Respondent) Pan:Aejpt6739A Dcit, Vs. Yogender Singh, Central Circle, J-6A, Sector-23, Ghaziabad Sanjay Nagar, Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Yogender Singh, Vs. Dcit, J-6A, Sector-23, Central Circle, Sanjay Nagar, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Naveen Tyagi, Vs. Dcit, G-302, Vvip Central Circle, Addresses, Raj Nagar Ghaziabad Extention, Ghaziabad (Appellant) (Respondent) Pan:Admpt6420A Sarika Tyagi, Vs. Dcit, H-100, Patel Nagar,- Central Circle, 3, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Afapt5986P Assessee By : Shri Rajeev Khandelwal, Ca Shri Gagan Khandelwal, Adv Shri Jaind Jaiswal, Adv Revenue By: Ms. Sapna Bhatia, Cit Dr Date Of Hearing 23/08/2024 Date Of Pronouncement /10/2024

transfer of the unsecured loan amount. Looking to the facts of the case, it is clear that all the three limbs of a genuine cash credit ie identity, genuineness of transaction and creditworthiness are well established. Therefore no adverse inference needs to be drawn in the matter of this cash credit. 6.5 The assessee company has furnished the following

SARIKA TYAGI,GHAZIBAD vs. DCIT, CENTRAL CIRCLE, GHAZAIBAD

Accordingly, Ground No. 2 raised by the revenue is dismissed

Bench: Shri M. Balaganesh & Shri Vimal Kumardcit, Vs. Sushil Tyagi, Central Circle, A-2, Ganpati Ghaziabad Apartments, Civil Lines, New Delhi (Appellant) (Respondent) Pan:Aejpt6739A Dcit, Vs. Yogender Singh, Central Circle, J-6A, Sector-23, Ghaziabad Sanjay Nagar, Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Yogender Singh, Vs. Dcit, J-6A, Sector-23, Central Circle, Sanjay Nagar, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Naveen Tyagi, Vs. Dcit, G-302, Vvip Central Circle, Addresses, Raj Nagar Ghaziabad Extention, Ghaziabad (Appellant) (Respondent) Pan:Admpt6420A Sarika Tyagi, Vs. Dcit, H-100, Patel Nagar,- Central Circle, 3, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Afapt5986P Assessee By : Shri Rajeev Khandelwal, Ca Shri Gagan Khandelwal, Adv Shri Jaind Jaiswal, Adv Revenue By: Ms. Sapna Bhatia, Cit Dr Date Of Hearing 23/08/2024 Date Of Pronouncement /10/2024

transfer of the unsecured loan amount. Looking to the facts of the case, it is clear that all the three limbs of a genuine cash credit ie identity, genuineness of transaction and creditworthiness are well established. Therefore no adverse inference needs to be drawn in the matter of this cash credit. 6.5 The assessee company has furnished the following

DCIT CENTRAL CIRCLE , GHAZIABAD vs. YOGENDER SINGH , GHAZIABAD

Accordingly, Ground No. 2 raised by the revenue is dismissed

Bench: Shri M. Balaganesh & Shri Vimal Kumardcit, Vs. Sushil Tyagi, Central Circle, A-2, Ganpati Ghaziabad Apartments, Civil Lines, New Delhi (Appellant) (Respondent) Pan:Aejpt6739A Dcit, Vs. Yogender Singh, Central Circle, J-6A, Sector-23, Ghaziabad Sanjay Nagar, Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Yogender Singh, Vs. Dcit, J-6A, Sector-23, Central Circle, Sanjay Nagar, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Naveen Tyagi, Vs. Dcit, G-302, Vvip Central Circle, Addresses, Raj Nagar Ghaziabad Extention, Ghaziabad (Appellant) (Respondent) Pan:Admpt6420A Sarika Tyagi, Vs. Dcit, H-100, Patel Nagar,- Central Circle, 3, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Afapt5986P Assessee By : Shri Rajeev Khandelwal, Ca Shri Gagan Khandelwal, Adv Shri Jaind Jaiswal, Adv Revenue By: Ms. Sapna Bhatia, Cit Dr Date Of Hearing 23/08/2024 Date Of Pronouncement /10/2024

transfer of the unsecured loan amount. Looking to the facts of the case, it is clear that all the three limbs of a genuine cash credit ie identity, genuineness of transaction and creditworthiness are well established. Therefore no adverse inference needs to be drawn in the matter of this cash credit. 6.5 The assessee company has furnished the following

DCIT, CC-15, NEW DELHI vs. BDR BUILDERS & DEVELOPERS P. LTD., NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usasstt. Year: 2012-13 Dcit, Vs. Bdr Builders & Developers P. Ltd,B- Central Circle-15, 393, Zakir Nagar So, South East Delhi, New Delhi New Delhi-1100025 (Appellant) (Respondent) Pan No. Assessee By : Dr. Rakesh Gupta, Adv. Revenue By : Sh. Kanv Bali, Sr. Dr Date Of Hearing: 28.02.2023 Date Of Pronouncement: 16.03.2023

deposits, nature & purpose of all the transactions and identity/ genuineness/ creditworthiness of these transactions. It is further observed that BDR Builders & Developers P. Ltd the AO had neither done any enquiry/investigation w.r.t. these entries received from Mr Manoj Sethi nor referred to any adverse statement of Mr Manoj Sethi against the appellant or his bank account transactions nor analysed & appreciated

INCOME TAX OFFICER, DELHI vs. MOHD RIZWAN, DELHI

In the result, addition of Rs

transfer of goods and purchases bills were received afterwards and the goods were in the possession of M/s. Surya Services through delivery challan which can be verified from M/s. Sintex Plast Containers, Kalol (N.G.). After considering the facts and submissions of the appellant it is noticed that M/s. Surya Services belonging to the same group was not assessed

ACIT, NEW DELHI vs. PHOOLA RANI CHADHA, NEW DELHI

In the result, the appeal of the assessee is partly allowed for statistical purpose

Bench: Ms. Madhumita Roy & Shri Khettra Mohan Royphoola Rani Chadha Vs. Acit, Circle 30(1) Plot No. 23, Civic Centre, Road No. D-4 Dlf, Minto Road Phase-1, Dlf City New Delhi – 110002 Gurgaon, Haryana 122002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaapc1676L Appellant .. Respondent Acit, Vs. Phoola Rani Chadha Room No. 1001, 10Th C-51, Defence Colony Floor, E-2, Block, New Delhi – 110024 Civic Centre, Minto Road Delhi – 110002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaapc1676L Appellant .. Respondent

cash was deposited from earlier withdrawals is acceptable. As a result, ground no. 2c is allowed.” 3. The CIT(A) has further giving on account of fixed deposit by holding as follows: “4.2 Adjudication of ground no. 2(d); Fund flow and Time deposits mentioned in the above table are reflected in the Standard Chartered Bank statement submitted

PHOOLA RANI CHADHA,NEW DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 30(1), NEW DELHI

In the result, the appeal of the assessee is partly allowed for statistical purpose

Bench: Ms. Madhumita Roy & Shri Khettra Mohan Royphoola Rani Chadha Vs. Acit, Circle 30(1) Plot No. 23, Civic Centre, Road No. D-4 Dlf, Minto Road Phase-1, Dlf City New Delhi – 110002 Gurgaon, Haryana 122002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaapc1676L Appellant .. Respondent Acit, Vs. Phoola Rani Chadha Room No. 1001, 10Th C-51, Defence Colony Floor, E-2, Block, New Delhi – 110024 Civic Centre, Minto Road Delhi – 110002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaapc1676L Appellant .. Respondent

cash was deposited from earlier withdrawals is acceptable. As a result, ground no. 2c is allowed.” 3. The CIT(A) has further giving on account of fixed deposit by holding as follows: “4.2 Adjudication of ground no. 2(d); Fund flow and Time deposits mentioned in the above table are reflected in the Standard Chartered Bank statement submitted

FABINDIA OVERSEAS PVT. LTD.,NEW DELHI vs. JOINT CIT SPECIAL RANGE-3, NEW DELHI

In the result, the appeal of the assessee is partly allowed and that of the Revenue is dismissed

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

cash management service charges; (iii) depository charges on maintenance of DEMAT accounts; (iv) charges for warehousing services for commodities; (v) underwriting service charges; (vi) clearing charges (MICR charges); (vii) credit card or debit card commission for transaction between the merchant establishment and acquirer bank. 2. This notification shall come into force from the 1 st day of January

DCIT, CIRCLE-9(1), NEW DELHI vs. FABINDIA OVERSEAS PVT. LTD., NEW DELHI

In the result, the appeal of the assessee is partly allowed and that of the Revenue is dismissed

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

cash management service charges; (iii) depository charges on maintenance of DEMAT accounts; (iv) charges for warehousing services for commodities; (v) underwriting service charges; (vi) clearing charges (MICR charges); (vii) credit card or debit card commission for transaction between the merchant establishment and acquirer bank. 2. This notification shall come into force from the 1 st day of January

PICO DEEPALI OVERLAYS CONSORTIUM (BY DEEPALI DESIGNS EXHIBITS (P.) LTD.),DELHI vs. DCIT, CENTRAL CIRCLE-17, NEW DELHI

In the result, both the captioned appeals filed by the assessee are allowed

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2011-12 Pico Deepali Overlays Vs. Dcit, Central Circle-17, Consortium, C/O Mna & Co., Delhi Cas, Suite 444, Tower-B, Spazedge, Sector 47, Sohna Road, Gurgaon – 122 018 Pan :Aabap1880F (Appellant) (Respondent)

deposited as is evident from page no.392 of Volume-I of paper books. All the payments were made through cheque. 7.6 Ground no.7 is regarding transfer prices. In second round, Ld. AO has merely said that there is no need to vitiate his earlier order since it has not been set aside. In fact, TPO in order dated 27.01.2021 page