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Judgment
PER BENCH:
The instant batch of eight appeals involves the three assessees; a company; namely, M/s SCL Healthcare Private Limited , its director Sh. Karan Vijhani & Shri Prabal Roy, directed against the Commissioner of Income Tax (Appeals)-3 [in short, the “CIT(A)”], Gurgaon’s as many orders dated 28.10.2025, involving proceedings u/s 147 r.w.s. 143(3) & 143(3) of the Income Tax Act, 1961; hereinafter referred to as, “the Act”; respectively.
All other relevant details thereof, tax-payer wise read as under:
| Sl. No. | ITA No. (A.Y) | Appellant Name | Respondent Name | Order appealed against (Order No.) |
|---|---|---|---|---|
| 01 | 8518/Del/2025 (A.Y. 2019-20) | SCL Healthcare | Deputy Commissioner of Income Tax, | Commissioner of Income Tax (Appeals)-03, Gurgaon’s order appealed against passed in 11032/CIT(A)-3/GGN/2018-19 |
| 02 | 8519/Del/2025 (A.Y. 2020-21) | Commissioner of Income Tax (Appeals)-03, Gurgaon’s order appealed against passed in 11079/CIT(A)-3/GGN/2019-20 | ||
| 03 | 8520/Del/2025 (A.Y. 2021-22) | Private Limited, | Central Circle-01, | Commissioner of Income Tax (Appeals)-03, Gurgaon’s order appealed against passed in 10362/CIT(A)-3/GGN/2020-21 |
| 04 | 8521/Del/2025 (A.Y. 2022-23) | Commissioner of Income Tax (Appeals)-03, Gurgaon’s order appealed against passed in 101142/CIT(A)-3/GGN/2021-22 | ||
| 05 | 8634/Del/2025 (A.Y. 2023-24) | Prabal Roy | Deputy Commissioner of Income Tax, Central Circle-01, | Commissioner of Income Tax (Appeals)-03, Gurgaon’s order appealed against passed in 10102/CIT(A)-3/GGN/2022-23 |
| 06 | 8809/Del/2025 (A.Y. 2022-23) | Karan Vijhani | Deputy Commissioner of Income Tax, Central Circle-01, | Commissioner of Income Tax (Appeals)-03, Gurgaon’s order appealed against passed in 10093/CIT(A)-3/GGN/2021-22 |
| 07 | 8810/Del/2025 (A.Y. 2020-21) | Commissioner of Income Tax (Appeals)-03, Gurgaon’s order appealed against passed in 11089/CIT(A)-3/GGN/2019-20 | ||
| 08 | 8811/Del/2025 (A.Y. 2019-20) | Commissioner of Income Tax (Appeals)-03, Gurgaon’s order appealed against passed in 11095/CIT(A)-3/GGN/2018-19 |
Heard all these three assessees/appellants as well as the department at length. Case files perused.
We advert to the basic relevant facts common in all these cases. T his asse ssee/company; M/s SCL Healthcare Private Limited engaged in health care services; came to be incorporated on 20.11.2017 by one of the co-appellants herein, Shri Karan Vijhani holding 99% stake therein. The third appellant, Shri Prabal Roy happens to be one of the six doctor(s)/promoter(s) in the company. There is hardly any dispute between the parties that the learned departmental authorities carried out section 132 search action at the company’s premises “Accord Hospital” and other business residential premises on 27.07.2022. They found/seized the alleged incriminating material in the nature of diaries and documents marked as “A” indicating varying sums, as expenditure and income in respect of construction at the project site of the hospital and certain other transactions. Learned Assessing Officer thereafter completed his impugned assessments inter alia making various additions/stand upheld in the CIT(A) lower appellate discussion. It would indeed be appropriate for us to tabulate the various additions made in the assessee’s hands as under:
| Sl. No. | Asses see/ Appellant | Assessment Year | ITA N o. | Addition (s) |
|---|---|---|---|---|
| 01 | M/s SCL Healthcare Private Limited | 2019-20 | 8518/Del/ 2025 | section 69B unexplained inve st ment add ition of Rs. 2,9 1,35 ,000/- |
| section 68 unexplaine d cash cre dits addition o f Rs. 1 ,23, 02,000/-, represe nt ing income from sale of mitt i the re in and other ite ms learmed CIT(A) has conve rte d the Assessing Officer’s section 68 r .w.s. 115BBE addition to that unde r the head business income in the lowe r appe llate discussion. | ||||
| 2020-21 | 8519/Del/ 2025 | “Bus iness” income add ition o f Rs. 1,8 4,70, 900/- derive d from sale o f mitti and other ite ms | ||
| 2021-22 | 8520/De l /2025 | section 68 ‘Business’ Incom e addition o f Rs. 2,7 2,39 ,900/-represe nt ing re ceipts from sale o f mitti and other ite ms. | ||
| 2022-23 | 8521/De l /2025 | Amount of Rs. 5,7 9,12 ,000/-represe nt ing doctor’s OPD receipts treat ed as the com pany’s business income. | ||
| 2 | P raba l Ro y | 2023-24 | 8634/Del/ 2025 | Sectio n 69 r .w.s/ 115BBE une xplaine d investment in go ld jewelle ry o f Rs. 37,78,8 54/- cash seized Rs. 6,32,890/- |
| 3 | Karna Vijhan i | 2022-23 | 8809/Del/ 2025 | Sectio n 69A r .w.s. 115BBE addition of R s. 2,2 6,58 8/- |
| 2019-20 | 8811/Del/ 2025 | section 69B “pro tective” additio n of Rs. 4 L akhs of contr ibution to the company | ||
| Sectio n 69A r.w.s 115BBE loans addition of Rs. 8,34,38,989/- | ||||
| 2020-21 | 8810/Del/ 2025 | Sectio n 68 r .w.s. 115BBE addition of unexplained cas h credits amounting to Rs. 1,06,50,000/- |
It is in this factual backdrop that the first and thir d assessees/appellants herein i.e ., M/s SCL Healthcare Private Limited in ITA No. 8521/Del/2025 and Shri Karan Vijhani in ITA No. 8809/Del/2025; both in assessment year 2022-23, raise their identical legal ground/argument that the learned Assessing Officer’s impugned “regular” assessments framed u/s 143(3) of the Act, are not sustainable in law as the same ought to have been finalized u/s 148 of the Act given the fact that the aforesaid search had taken place on 27.07.2022(supra). The Revenue’s case, on the other hand, is that there is no such bar in framing a “regular” assessment even after a search takes place as proceedings in both these cases were pending as on the date of search i.e., 27.07.2022.
We find that the instant issue is no more res integra in light of this tribunal’s recent decision in Montage Enterprises Private Limited vs DCIT in ITA No. 5458/Del/2025 dated 29.12.2025 decided against the department as under:
“2.We notice at the outset that there arises the first and foremost issue of validity of the impugned section 143(3) assessment itself framed by the learned DCIT, Central Circle-II, Noida as per the assessee’s pleadings in its appeal ITA No.5458/Del/2025. A combined perusal of both these case files indicates that the assessee/appellant is engaged in the business of manufacturing and sale of flexible packaging material etc. It has filed its return for the impugned assessment year 2022-23 on 29.10.2022, declaring loss of Rs.64,53,88,702/-. And the same was taken for scrutiny. The learned departmental authorities thereafter carried out section 132 search action as well as section 133A survey in its case on 21.02.2023. There is further no dispute that the learned Assessing Officer then proceeded to frame the impugned assessment on 30th March, 2024 in its case inter alia making various disallowances/additions etc., involving varying sums, which stand partly upheld in the CIT(A)’s lower appellate discussion.
3.It is in this factual backdrop that the assessee seeks to raise it’s precise question challenging validity of the impugned assessment for the sole reason that the same ought to have been framed under section 148 with approval under section 148B of the Act in light of Homelife Buildcon (P.) Ltd. Vs. DCIT, (2025) 176 taxmann.com 614 (Chandigarh – Trib.) as relied in Jamna Das Nikkamal Jain Saraf Pvt. Ltd. Vs DCIT (ITA No. 403/Chd./2025) decided on 04.11.2025, adjudicating the very issue against the department as under:
“11.4In conclusion, it was submitted that since the year under appeal formed part of the three assessment years immediately preceding the year in which search was conducted, the assessment ought to have been framed under section 148 with approval u/s 148B. The framing of the assessment u/s 143(3) and approval taken only for the purposes of section 143(3) was thus asserted to be fundamentally defective, non-compliant with statutory mandate, and consequently void ab initio. On these grounds, following the ratio in Homelife Buildcon Pvt. Ltd., it was prayed that the impugned assessment be quashed.
12.The Ld. CIT-DR Shri Manav Bansal opposed the contention, stating that the return for A.Y. 2022-23 was filed prior to the date of search, and validly selected for scrutiny under CASS. The AO was competent to complete the assessment u/s 143(3).
12.1He contended that section 148B applies only to “reassessment” and not to “regular assessments.” The AO’s approval from Addl. CIT, being in line with the CBDT Instruction No. 7/2022 dated 15.07.2022, fulfils the supervisory requirement. The DR also submitted that Homelife Buildcon is distinguishable, as the AO therein relied on third-party search data, whereas the present case is based on assessee’s own seized material.
13.We have carefully considered the rival submissions and perused the record. It is undisputed that search u/s 132 was conducted on 24.11.2022, relevant to A.Y. 2023-24. Thus, A.Y. 2022- 23 is one of the three preceding years under Explanation 2(iv) to section 148. The Explanation reads that if a search is initiated, “the Assessing Officer shall be deemed to have information suggesting escapement of income for the three assessment years immediately preceding the assessment year relevant to the previous year in which the search is initiated.
13.1Therefore, the only permissible statutory course was to issue notice u/s 148 and obtain prior approval u/s 148B before passing assessment order.
13.2As the Assessing Officer completed the assessment under section 143(3) of the Act without issuing the notice under section 148 of the Act. Therefore, the question before us is whether the assessment proceedings initiated under section 143(3) of the Act can be validly continued and completed after a search under section 132 has been conducted in the case of the same assessee, without following the procedure prescribed under section 148 (Explanation 2) of the Act.
13.3In our considered opinion, the answer lies in the scheme of the Act itself. Section 143 provides the general framework for regular assessment, whereas sections 147–148 (post-2021 regime) deal with reassessment based on information suggesting escapement of income, including that unearthed during a search.
A plain reading of section 143(2) shows that such notice can be issued only when a return of income is furnished under section 139 or in response to a notice under section 142(1). It empowers the Assessing Officer to scrutinize that return if he considers that income has been understated or tax underpaid. However, when a search under section 132 takes place and materials are found indicating possible escapement of income, the statute envisages a different route for carrying out assessment or reassessment under section 147 read with section 148, which is the special mechanism for bringing to tax the income discovered in consequence of a search.
Although section 148 (inserted w.e.f. 01.04.2021) does not begin with a non-obstante clause similar to the erstwhile section 153A, its context and Explanation 2 make it clear that where a search is initiated, the jurisdiction thereafter must flow through this special channel, subject to prior satisfaction and approval of the Principal Commissioner or Commissioner. The legislative intent is to ensure that when a search is carried out, the assessment is framed under the specific provisions meant for such cases and not under the general provision of section 143(3). Further we may mention that no notice under section 143(2) could have been issued after 3 months from the from the end of the financial year in which the return is furnished. In the present case the original return of income was filled on 4/11/2022 for the assessment year 202223 and 143 (2) was issued on 21/6/2023 , therefore also the assessment was framed under 143(3) of the Act is not sustainable. In other words the time required for issuing the notice under 143(2) had already expired, and the revnue can not be allowed to issued issue 143(2) on 21.6.2023 after the search was carried out and notice had been issued on 21.6.2023 and assessment was framed under 143(3) of the Act. The relevant portion of section 143(3) reads as under:-
“143(2) Where a return has been furnished under section 139, or in response to a notice under sub-section (1) of section 142, the Assessing Officer or the prescribed income-tax authority, as the case may be, if considers it necessary or expedient to ensure that the assessee has not understated the income or has not computed excessive loss or has not under-paid the tax in any manner, shall serve on the assessee a notice requiring him, on a date to be specified therein, either to attend the office of the Assessing Officer or to produce any evidence on which the assessee may rely in support of the return: Provided that no notice under this sub-section shall be issued after the expiry of three months from the end of the financial year in which the return is furnished.”
This position finds substantial support from the ratio of various decisions of Hon'ble High Court and Hon'ble Supreme Court. The Courts unanimously held that once a search has been conducted and proceedings are triggered under section 153A, the Assessing Officer cannot continue parallel proceedings under section 143(3) or section 147 for the same assessment year, because the entire assessment for that year stands merged in the search assessment. The Courts emphasized that the existence of a special procedure for assessment consequent to a search is a complete code in itself; therefore, ordinary assessments abate and cannot coexist with the search-based assessment.
Drawing this analogy to the current regime, it is evident that when a search takes place and information is unearthed suggesting escapement of income, the Assessing Officer must act under section 148 (which now performs the role formerly assigned to section 153A) rather than continuing with a pending section 143(3) proceeding. The legislative intent remains the same — to prevent multiplicity of proceedings and ensure that only one comprehensive order is passed, factoring in both the pre-search and postsearch materials.
The rationale is further reinforced by the well-settled principle of generalia specialibus non derogant — the special provision overrides the general. Section 148 (as a special provision triggered by search information) must prevail over section 143 (the general provision for regular scrutiny). Allowing the Assessing Officer to continue and conclude proceedings under section 143(3) after a search would defeat this legislative scheme and render the safeguards, such as prior approval of the Principal Commissioner, redundant.
Accordingly, we hold that once a search is initiated under section 132 and material is found relating to the assessee, the pending assessment under section 143(3) cannot validly continue, as the time for issuing the 143(2) in response to original return of income had already expired, therefore the Assessing Officer must necessarily proceed in accordance with the special provisions contained in section 148 of the Act.”
Learned CIT(DR) representing the Revenue vehe mently supports the impugned assessment that the Assessing O fficer had r ightly finalized the same under the normal provisio n once the entire issue was pending before him as on the date of search.
We have given our thoughtful consideration to the assessee’s and the Revenue’s foregoing vehement submissions. We find mer it in the assessee’s legal ground herein once the impugned se arch had taken place in its case, no normal assessme nt under section 143(3) of the Act could have been framed in light of the tribunal’s fore going twin decisions going against the department. We thus ado pt the above extracted reason mutatis mutandis to quash the impugne d assessment framed by the learned Assessing Officer on 30th March, 2024 in very terms.
We adopt the above detailed discussion mutatis mutandis to quash the learned Assessing Officer’s impugned assessments in both these assessees’ cases framed u/s 143(3) of the Act for want of initiation of section 148 proceedings in very terms. These instant twin appeals ITA Nos. 8521 & 8809/Del/2025 succeed therefore.
We next advert to M/s SCL Healthcare Private Limited’s remaining three cases i.e., ITA Nos. 8518 to 8520/Del/2025 for assessment years 2019-20 to 2021-22; respectively. The first and foremost common issue herein raised at its behest is that of correctness of both the learned lower authorities’ identical action treating the receipts derived from sale of mitti/excavated soil and other items at the hospital project site; as liable to be assessed as “business” income. We must emphasize here that the learned Assessing Officer in assessment year 2019-20 had made section 68 unexplained cash credits addition of Rs. 1,23,02,000/- which stands converted under the “head” business income in the lower appellate discussion. The assessee submits in its backdrop that apart from the settled law that the learned CIT(A) could not have changed the head of income or introduced such a new head in lower appellate proceedings; as the case may be; in light of CIT vs Shapoorji Pallonji Mistry [1962] 44ITR 891(SC) and CIT vs Kanpur Coal Syndicate [1964] 53 ITR 225(SC) and CIT vs Sardari Lal & Co. [2001] 251 ITR 864(Del) (FB), there is at least no dispute on facts that it was all along in the process of setting up the “Accord Super Speciality Hospital” after acquisition of plot of land in village Budena, Faridabad. And that it had to excavate and remove the soil thereupon in order to make it fit for the hospital construction. We must make it clear that even the learned lower authorities do not raise any dispute once they have treated the assessee’s receipts as business income. The assessee’s plea accordingly is that such a receipt derived before the commencement of its actual business activity; and, which is inextricably connected with the setting up of a new capital asset, is capital in nature only thereby reducing the cost of construction than forming taxable income. We find in this factual backdrop that hon’ble Bombay high court’s latest decision in PCIT vs Tata Power Company Limited in ITA No. 21/2020 decided on 23.07.2016; has rejected the Revenue’s very stand assessing such receipts as business income, as under:
instead of revenue in nature when the whole of income has been earned on account of setting up the business and the income is primarily in the nature of business income earned from running the business?
ii.On the facts and in the circumstances of the case and in law, whether Hon’ble ITAT was right in holding that pre-installation period broadband income and income from sale of scrap is capital in nature by relying upon the decision of Hon’ble SC in the case of CIT Vs. Bokaro Steel Ltd. (1999) 236 ITR 315 (SC), since instant case is distinguishable with that of Bokaro Steel Plant wherein the issue was of interest and rent income generated from setting up the plant?
iii.Whether, on the facts and in the circumstances of the case and in law, the Tribunal erred in interpreting the import of Sec. 80 IA(5) in calculation of deduction available u/s. 80IA?
2.As far as questions (i) and (ii) are concerned, the Assessee is in the line of business of generation and distribution of power. During the relevant Assessment Year, the Assessee earned income from trial runs of its broadband project and sale of scrap generated prior to the installation of the project and treated the income as capital work in progress and claimed depreciation. The Assessee did not offer the said income to tax. The Assessing Officer treated these receipts as revenue receipts and brought them to tax. On appeal, the Commissioner of Income Tax (Appeals) [for short “CIT(A)”] upheld the order of the Assessing Officer. Aggrieved by the order of the CIT(A), the Assessee preferred an Appeal before the ITAT.
3.Upon appreciation of the material on record, the ITAT recorded a finding of fact that the Assessee's broadband unit was under trial runs and had not yet been installed when the income of Rs. 9,81,38,257/- arose from the said project. Similarly, scrap was generated prior to the installation of the broadband project and the sale thereof generated income of Rs. 1,27,67,139/-. Hence, the ITAT concluded that both these incomes were inextricably linked with the broadband project, which was in the installation phase, and that the Assessee had rightly treated the income as capital work-in-progress. Consequently, the same could not be brought to tax, was the conclusion. In arriving at this conclusion, the ITAT placed reliance upon the decision of the Supreme Court in the case of CIT Vs. Bokaro Steel reported in 236 ITR 315.
4.The learned Counsel appearing on behalf of the Appellant Revenue, sought to distinguish the decision of the Supreme Court in Bokaro Steel by contending that it dealt only with the capitalisation of interest and not with the capitalisation of income received by the Assessee.
5.We have carefully considered the decision of the Supreme Court in the case of Bokaro Steel. The issue before the Hon'ble Supreme Court was that the Assessee Company was in the process of constructing its own factory and installing its plant, and its business had not yet commenced. During the relevant assessment years, the Assessee received the following amounts prior to the commencement of its business:
(a)Rent received from contractors for quarters provided to their employees;
(b)Hire charges received for plant and machinery supplied to contractors;
(c)Interest received on advances made to contractors to facilitate construction work;
(d)Royalty received for excavation and use of stones from the Assessee's land in construction;
6.With regard to the first three receipts, the Supreme Court held that the arrangements which were made between the Assessee and the contractors pertaining to these three receipts, were arrangements which are intrinsically connected with the construction of its plant. The receipts have been adjusted against the charges payable to the contractors and have gone to reduce the cost of construction. Therefore, they have been rightly held to be capital receipts and not income of the Assessee. The Hon'ble Supreme Court further held that the same reasoning would apply to the fourth category of income, namely, the royalty received by the Assessee. To the extent of such
We thus conclude in very terms that the learned lower authorities’ impugned action assessing the assessee’s receipts derived from sale of mitti etc from hospital site during the course of setting up the same as business income in all these assessment years is not sustainable which is hereby reversed. The appellant/company assessee’s second substantive ground in assessment year 2019-20, the sole substantive grievance in assessment year 2020-21 as well as in the main appeal ITA No. 8519/Del/2025 and sole ground in assessment year 2021-22’s appeal with ITA No. 8520/Del/2025, involving varying sums, succeeds therefore.
We now deal with M/s SCL Healthcare Private Limited’s former substantive ground in assessment year 2019-20 appeal ITA No. 8518/Del/2025, challenging section 69B unexplained investment addition of Rs. 2,91,35,000/- made in both the lower proceedings. The same is admittedly stated to be based on the seized excel sheet “HCL accounts as on March, 2019” indicating the alleged investments. We notice from a perusal of the seized documents itself that he clinching figure therein taken as “291.35” which has been extrapolated to Rs. 2,91,35,000/- in issue without even corroboration or substantiation thereof in both the lower proceedings. Coupled with this situation, the same was admittedly seized from Sh. Karan Vijhani laptop than from assessee’s premises itself thereby negating the necessary statutory presumption of correctness thereof against the company u/s 292C of the Act. We thus see no reason to sustain the impugned addition which is hereby deleted in very terms. This assessee’s instant appeal ITA No. 8518/Del/2025 for assessment year 2019-20 is accepted.
We now deal with the second assessee, Shri Prabal Roy’s appeal ITA No. 8634/Del/2025 for assessment year 2023-24. His first and foremost substantive ground seeks to reverse both the learned lower authorities’ assessment and lower appellate findings making section 69B r.w.s. 115BBE unexplained investment in gold addition of Rs. 37,78,854/- forming subject matter of the tribunal’s apt adjudication. The same admittedly represents the assessee’s total jewellery found during search weighing 1843.753 grams. That being the case, his sole substantive argument is that both the learned lower authorities’ have nowhere granted benefit of the CBDT’s benevolent circular/instructions dated 11.05.1994 for his entire family comprising of seven members. We thus direct the learned Assessing Officer to recompute and verify the assessee’s impugned investments in gold and jewellery etc in light of the said circular as per law in very terms.
Next comes the second substantive issue of unexplained money addition of Rs. 3,05,000/- out of the total cash seized amounting to Rs. 6,32,890/-. We are of the considered view that a lumpsump addition of Rs. 1 lakh only keeping in mind the assessee’s cash in hand and in light of his socio-economic status will be just and proper with a rider that the same shall not be treated as precedent. The assessee gets relief of Rs. 2,05,000/-in other words. His appeal ITA No. 8634/Del/2025 is partly accepted.
The third assessee/appellant herein, Shri Karan Vijhani has filed its appeal ITA No. 8811/Del/2025 in assessment year 2019-20 seeking to delete the first and foremost “protective” addition of Rs. 44 lakhs u/s 69B of the Act based on the aforesaid excel sheet. He submits that the learned CIT(A) has deleted the identical addition made in the co-searched parties and Shri Prabal Roy’s hands; as not sustainable in law. The same is found to be based on the excel sheet(supra) wherein the relevant figures reads the sum of Rs “44” extrapolated to “44 lakhs”. We thus find no reason to sustain the impugned addition which is hereby deleted in light of our preceding detailed discussion.
Next comes the second substantive issue between the parties i.e. correctness of the learned lower authorities’ action making 69A r.w.s. 115BBE addition of Rs. 8,34,38,989/- which represents various unsecured loans coming from the company/assessee’s doctors and his family members already shown in the regular books. That being the case, we hereby quote Smt. Sarika Jain vs CIT (2017) 249 TAXMANN. 625 (Allahabad) that such an addition could not be made u/s 69A of the Act since all these various items of loan etc. had been duly declared in their regular books. We accordingly delete the impugned addition in very terms. The asseseee’s instant appeal ITA No. 8811/Del/2025 succeeds in very terms.
Coming to the assessee’s appeal ITA No. 8810/Del/2025 in assessment year 2020-21, both the parties are very much in agreement with the learned CIT(A) has passed his lower appellate order ex-parte against him. Learned counsel’s case is that he could not appear to plead and prove his case in the lower appellate proceedings on account of various communication gaps which could not be altogether denied as well. We thus deem it appropriate to restore the assessee’s instant appeal back to the Assessing Officer for this afresh appropriate adjudication within three effective opportunities as per law. This assessee’s appeal ITA No. 8810/Del/2025 is allowed for statistical purposes.
No other ground or argument has been pressed before us.
To sum up, these three assessees’ appeals i.e,
| Sl. No. | ITA No. | Appellant Name | Respondent Name | Result |
|---|---|---|---|---|
| 01 | 8518/Del/2025 | SCL Healthcare Private Limited, | Deputy Commissioner of Income Tax, Central Circle-01, | Allowed |
| 02 | 8519/Del/2025 | Allowed | ||
| 03 | 8520/Del/2025 | Allowed | ||
| 04 | 8521/Del/2025 | Allowed | ||
| 05 | 8634/Del/2025 | Prabal Roy | Deputy Commissioner of Income Tax, Central Circle-01, | Partly allowed |
| 06 | 8809/Del/2025 | Karan Vijhani | Deputy Commissioner of Income Tax, Central Circle-01, | Allowed |
| 07 | 8810/Del/2025 | Allowed for statistical purposes | ||
| 08 | 8811/Del/2025 | Allowed |
A copy of this common order be placed in the respective case files.