PR. COMMISSIONER OF INCOME TAX - 1 vs M/S AGROHA FINCAP LTD.

* IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment delivered on: 06.10.2025 ITA 60/2024 PR. COMMISSIONER OF INCOME TAX – 1 .....Appellant versus M/S AGROHA FINCAP LTD. .....Respondent Advocates who appeared in this case For the Appellant : Mr. Vipul Agrawal, SSC with Ms. Sakshi Shairwal, Mr. Akshat Singh, JSCs and Mr. Gaoraang Ranjan and Ms Harshita Kotru, Advs. For the Respondent : Mr. Arvind Kumar, Adv. CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR JUDGMENT V. KAMESWAR RAO, J. 1. This appeal has been filed with the following prayers: “(a) To frame the substantial Questions of Law mentioned in Para 2 of the appeal; (b) To frame any other substantial Question of Law which may arise from the impugned order dated 07.07.2023. (c)To set aside the impugned order dated 07.07.2023 of the Ld. ITAT in ITA No. 2859/Del/2022” 2. This appeal is filed against the order dated 07.07.2023 in ITA No. 2859/Del/2022. The Appellant in this appeal is the Principal Commissioner 3. The Appellant in their assessment order dated 28.11.2016 had recorded that the Respondent/Assessee was incorporated on 28.08.1995. The business of the Assessee for the Assessment Year (‘AY’, here