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

price of the flat. A final defence also has been taken that the case also does not qualify within the ambit of Section 149 of the Act, as there is no income chargeable to tax represented in the form of an 'asset', which has escaped assessment amounting to Rs. 50,00,000/- or more and therefore, the notice issued under

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

price of the flat. A final defence also has been taken that the case also does not qualify within the ambit of Section 149 of the Act, as there is no income chargeable to tax represented in the form of an 'asset', which has escaped assessment amounting to Rs. 50,00,000/- or more and therefore, the notice issued under

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

price of the flat. A final defence also has been taken that the case also does not qualify within the ambit of Section 149 of the Act, as there is no income chargeable to tax represented in the form of an 'asset', which has escaped assessment amounting to Rs. 50,00,000/- or more and therefore, the notice issued under

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

price of the flat. A final defence also has been taken that the case also does not qualify within the ambit of Section 149 of the Act, as there is no income chargeable to tax represented in the form of an 'asset', which has escaped assessment amounting to Rs. 50,00,000/- or more and therefore, the notice issued under

HCL AUSTRALIA SERVICES PTY LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, similar grounds of appeal, in all the captioned

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

148A read with section 148 of the Act culminating in the final assessment order, without appreciating that there is no escapement of income in the hands of the Appellant for the relevant year. 3.6 That the final assessment order pertaining to assessment year 2017-18 is barred by limitation in terms of section 149(1)(b) as the conditions mentioned

HCL SINGAPORE PTE. LTD (SUCCESSOR TO AXON SOLUTIONS SINGAPORE PTE LIMITED),DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, similar grounds of appeal, in all the captioned

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

148A read with section 148 of the Act culminating in the final assessment order, without appreciating that there is no escapement of income in the hands of the Appellant for the relevant year. 3.6 That the final assessment order pertaining to assessment year 2017-18 is barred by limitation in terms of section 149(1)(b) as the conditions mentioned

HCL TECHNOLOGIES NORWAY AS ,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, similar grounds of appeal, in all the captioned

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

148A read with section 148 of the Act culminating in the final assessment order, without appreciating that there is no escapement of income in the hands of the Appellant for the relevant year. 3.6 That the final assessment order pertaining to assessment year 2017-18 is barred by limitation in terms of section 149(1)(b) as the conditions mentioned

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)

Transfer Pricing Officer (TPO') dated 22 July 2022, thereby violating the mandatory provisions of Sec 92CA(4) read with 144C(10) and 144C(13) of the Act. The Final assessment order thus deserves to be quashed. 6 18. On the facts and circumstances of the case and in law, the Assessing Officer (Technical Unit) has erred in referring the case

DHARAMPAL SATYAPAL LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE 29, NEW DELHI

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year : 2015-16 Dharampal Satyapal Ltd., Vs. Acit, 98, Okhla Industrial Estate Central Circle-29, Phase Iii, New Delhi. Tehkhand, New Delhi – 110 020. Pan: Aaacd0132H (Appellant) (Respondent) Assessee By : Shri R.S. Singhvi; Shri Satya Jeet Goel; & Shri Rajat Garg, Cas Revenue By : Shri Amit Jain, Cit-Dr Date Of Hearing : 11.09.2025 Date Of Pronouncement : 15.10.2025 Order

pricing adjustment u/s 92CA being reduction in Rs. 151,40,78,090/- claim of deduction u/s 80IC in respect transaction of transfer of goods from non-eligible unit to eligible units 2.4 The DRP disposed-off the objections vide order dated 30/09/2024 wherein the DRP allowed the objection with respect of TP adjustment and rejected the objection regarding addition

BOOKING.COM B.V.,THE NETHERLANDS vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE 1(1)(2), INTERNATIONAL TAXATION, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri M Balaganesh & Shri Vimal Kumarbooking.Com B.V. Vs. Acit, Circle -1(1)(2) Oosterdokskade 163, International Taxation, 1011 Dl, Amsterdam, The Civic Centre, Minto Road, Netherlands, New Delhi – 110002 Haryana 122002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aagcb2395A Appellant .. Respondent

prices independently using a self-service tool. Key features of the arrangement: • The Appellant acts as an intermediary/ aggregator between bookers and Accommodations. • Reservations are concluded directly between the booker and the Accommodations. P a g e | 9 Booking.com B.V. (AY: 2018-19) • Post-checkout, the Appellant earns commission from Accommodations based on a pre-agreed percentage of the booking

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

148A(d) dated 31.07.2022 [W.P.(C) 3807/2023], 23.07.2022 [W.P.(C) 3804/2023], and 29.07.2022 [W.P. (C) 3808/2023], respectively as well as the notices under Section 148 dated 31.07.2022 [W.P.(C) 3807/2023], 23.07.2022 [W.P.(C) 3804/2023], and 29.07.2022 [W.P.(C) 3808/2023], respectively are hereby quashed.” 11. Even Hon’ble High Court of Calcutta in the case of CIT(Exemption

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

148A(d) dated 31.07.2022 [W.P.(C) 3807/2023], 23.07.2022 [W.P.(C) 3804/2023], and 29.07.2022 [W.P. (C) 3808/2023], respectively as well as the notices under Section 148 dated 31.07.2022 [W.P.(C) 3807/2023], 23.07.2022 [W.P.(C) 3804/2023], and 29.07.2022 [W.P.(C) 3808/2023], respectively are hereby quashed.” 11. Even Hon’ble High Court of Calcutta in the case of CIT(Exemption

STEELWILL GLOBOTECH PRIVATE LIMITED,FARIDABAD, HARYANA vs. INCOME TAX OFFICER, WARD 1(4), FARIDABAD, FARIDABAD, HARYANA

In the result, ground nos

Transfer Pricing Adjustment on account of interest on loan advances Rs.9,03,814/-. He submitted that it is a well settled law that where no addition is made in respect of the reasons for which assessment was reopened, the addition on other grounds is unsustainable. In support of his submissions, he placed reliance on following decisions: i. Ranbaxy Laboratories

INCOME TAX OFFICER, WARD-62(1), NEW DELHI, NEW DELHI vs. GIRISH KUMAR GUPTA, DELHI

In the result, the appeal of the Revenue is dismissed and cross objections filed by the assessee is allowed

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

transfer the shares on backdates. 2.5.) that many incongruities as pointed out by AO in assessment order remained to be controverted as from contract note in respect of purchase of said scrip, it is noticed that trade numbers are same for four trading options. 3. that assessee has shown to purchase 30,000 equity share of M/s Risa International

MAGNOLIA MARTINIQUE CLOTHING PRIVATE LIMITED,DELHI vs. DCIT, CENTRAL CIRCLE-17, NEW DELHI, DELHI

In the result, all the appeals filed by the assessee are partly allowed

Bench: Shri Satbeer Singh Godara & Shri S.Rifaur Rahman

transferred the amount to its beneficiaries. On perusal of list of managed and operated by him. 5. Consequently, a survey operation was carried out at the premises of the assessee on 07.11.2017. During the course of survey action on the assessee, no inward and outward stock registers for the purchases made from F.Y. 2012-13 to 2015-16 were found

MAGNOLIA MARTINIQUE CLOTHING PRIVATE LIMITED,DELHI vs. DCIT, CENTRAL CIRCLE 17, NEW DELHI, DELHI

In the result, all the appeals filed by the assessee are partly allowed

Bench: Shri Satbeer Singh Godara & Shri S.Rifaur Rahman

transferred the amount to its beneficiaries. On perusal of list of managed and operated by him. 5. Consequently, a survey operation was carried out at the premises of the assessee on 07.11.2017. During the course of survey action on the assessee, no inward and outward stock registers for the purchases made from F.Y. 2012-13 to 2015-16 were found

MAGNOLIA MARTINIQUE CLOTHING PRIVATE LIMITED,DELHI vs. DCIT, CENTRAL CIRCLE 17, NEW DELHI, DELHI

In the result, all the appeals filed by the assessee are partly allowed

Bench: Shri Satbeer Singh Godara & Shri S.Rifaur Rahman

transferred the amount to its beneficiaries. On perusal of list of managed and operated by him. 5. Consequently, a survey operation was carried out at the premises of the assessee on 07.11.2017. During the course of survey action on the assessee, no inward and outward stock registers for the purchases made from F.Y. 2012-13 to 2015-16 were found

MAGNOLIA MARTINIQUE CLOTHING PRIVATE LIMITED,DELHI vs. DCIT, CENTRAL CIRCLE 17, NEW DELHI, DELHI

In the result, all the appeals filed by the assessee are partly allowed

Bench: Shri Satbeer Singh Godara & Shri S.Rifaur Rahman

transferred the amount to its beneficiaries. On perusal of list of managed and operated by him. 5. Consequently, a survey operation was carried out at the premises of the assessee on 07.11.2017. During the course of survey action on the assessee, no inward and outward stock registers for the purchases made from F.Y. 2012-13 to 2015-16 were found

AMIT GOYAL HUF,NEW DELHI vs. THE INCOME TAX OFFICER, NEW DELHI

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

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manish Agarwal, Hon’Bleasstt. Year : 2015-16 Amit Goyal Huf, Vs. Income Tax Officer, M-59, Greater Kailash-Ii, Ward 30(1), Civic Centre, New Delhi – 110 048 New Delhi (Pan: Aalha3711R) (Appellant) (Respondent) Appellant By : Shri Lalit Mohan, Ca Respondent By : Shri Krishna Kumar Ramawat, Sr. Dr

transferred in her name on 16.02.2013. The said shares were lodged for dematerialization and were dematerialized on 16.03.2014 with NSDL. The company's IPO was listed on BSESME Segment on 19.03.2013 at an issue price of Rs. 35/- which opened at Rs. 37.25/- and closed at 39.10/- .The assessee sold these shares starting from 27.03.2014 to 11.07.2014 at around