THE INCOME TAX APPELLATE TRIBUNAL DELHI “G” BENCH: NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER &

SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA No.1850/Del/2019 [Assessment Year : 2006-07]

S. C. Johnson Pvt. Ltd., vs DCIT, 5th Floor, Plot No.68, Circle-7(1), Sector-44, Gurugram, New Delhi Haryana-122003.

PAN-AAACL3128M APPELLANT RESPONDENT ITA No.1470/Del/2020 [Assessment Year : 2007-08]

S. C. Johnson Pvt. Ltd., vs ACIT, 5th Floor, Plot No.68, Circle-22(2), Sector-44, Gurugram, New Delhi Haryana-122003.

PAN-AAACL3128M APPELLANT RESPONDENT ITA No.1122/Del/2020 [Assessment Year : 2008-09]

S. C. Johnson Pvt. Ltd., vs Add.CIT, 5th Floor, Plot No.68, Special Range-8, Sector-44, Gurugram, New Delhi Haryana-122003.

PAN-AAACL3128M APPELLANT RESPONDENT Appellant by Shri K. M. Gupta, Adv. &

Ms. Shruti Khimta, AR Respondent by Shri Mahesh Kumar, CIT DR Date of Hearing 02.06.2025 Date of Pronouncement 28.08.2025 ORDER PER MANISH AGARWAL, AM :

The captioned appeals are filed by assessee against the different orders of Ld. CIT(A) u/s 250 of the Income Tax Act, 1961 [“the Act”] arising out of different assessment orders tabulated as under:

2. The issues being common, interlinked and related to the same assessee for Assessment Years 2006-07 to 2008-09 therefore, all these appeals by the assessee have been heard together and accordingly, adjudicated by a common order.

3. First we take appeal of the assessee in ITA No.1850/Del/2019 [Assessment Year 2006-07].

1850/Del/2019 [Assessment Year 2006-07]

4. Brief facts of the case are that the assessee is a company, engaged in the business of manufacturing and trading of insect control and air care products. The return of the income for the year under appeal was filed on 30.11.2006, declaring total income NIL after claiming deduction u/s 80IB & 80IC of the Act. The case of the assessee was picked up for scrutiny and the assessment order was passed u/s 143(3) of the Act dated 24.12.2009 wherein certain additions were made however, the same were claimed as allowed u/s 80IB & 80IC of the Act. Thereafter, reassessment proceedings were initiated in the case of assessee u/s 147 of the act and notice u/s 148 was issued on 17.11.2011. In response assessee filed return of income on 21.12.2011 stating that return of income already filed u/s 139(1) of the Act be treated as the return filed. Thereafter, no reassessment order was passed and another re- assessment notice was issued on 07.03.2013 u/s 148 of the Act for re-initiating the re-assessment proceedings u/s 147 of the Act. The assessee in response, again requested to consider the return filed u/s 139(1) as the return of income and requested for the supply of reasons recorded and filed objections before the AO. The said objections were disposed off by the AO vide order dated 13.03.2014 and thereafter, after considering the submissions of the assessee, the re-assessment order was passed on 30.03.2014 wherein income of the assessee was computed at NIL under Income Tax Act and book profit of the assessee was assessed at INR 69,62,80,147/- as against the book loss declared at INR 15,58,74,356/-.

5. Aggrieved against this order, the assessee preferred appeal before Ld.CIT(A) wherein the assessee has objected for re-opening of assessment and made submissions on the merits of the additions by the AO. Ld. CIT(A) vide impugned order dated 28.12.2018 passed for various AYrs, dismissed the contentions of the assessee.

6. Aggrieved by the order of Ld.CIT(A), the assessee is in appeal before the Tribunal by taking following grounds of appeal:-

1. “That on the facts and circumstances of the case and in law, the Ld.

CTT(A) erred in upholding the action of the Ld. AO of initiation of proceedings under section 147 of the Act and assuming jurisdiction over the appellant for the year under consideration for reopening concluded assessment under section 143(3) of the Act on complete misconception of facts of case as well as in law.

1.1 That the Ld. CIT(A) has failed to appreciate and has al