ITAT Allahabad Judgments — October 2025

VISHNU KUMAR KESARWANI ,PRAYAGRAJ vs INCOME TAX OFFICER, WARD- 2(3), ALLAHABAD, ALLAHABAD

ITA 116/ALLD/2025[2011-12]Status: Disposed31 Oct 2025AY 2011-12Partly Allowed

The Tribunal condoned the delay in filing the appeal, accepting the assessee's claim of improper notice service by the CIT(A). The ex-parte appellate order of the CIT(A) was set aside, and all disputed issues regarding additions in the assessment order were restored to the CIT(A) for fresh adjudication after providing a reasonable opportunity to the assessee.

YOGI SATYAM,ALLAHABAD vs ITO, WARD- 1(5), ALLAHABAD

ITA 8/ALLD/2023[2015-16]Status: Disposed31 Oct 2025AY 2015-16Partly Allowed

The Tribunal held that the reopening of assessment under Section 147 was valid as income had escaped assessment. While upholding the addition of excess receipts over payments, it directed deletion of ad-hoc disallowances on cash expenses.

YOGI SATYAM,ALLAHABAD vs ITO, WARD- 1 (5), ALLAHABAD

ITA 5/ALLD/2023[2012-13]Status: Disposed31 Oct 2025AY 2012-13Partly Allowed

The Tribunal held that the reopening of assessment under Section 147 was valid as income had escaped assessment. While upholding the addition of excess receipts over payments, it directed deletion of ad-hoc disallowances on cash expenses.

SANJANA,ALLAHABAD vs ITO, WARD- 1 (5), ALLAHABAD

ITA 53/ALLD/2023[2015-16]Status: Disposed31 Oct 2025AY 2015-16Partly Allowed

The Tribunal held that the reopening of assessment under Section 147 was valid as income had escaped assessment. While upholding the addition of excess receipts over payments, it directed deletion of ad-hoc disallowances on cash expenses.

SANJANA,ALLAHABAD vs ITO, WARD- 1 (5), ALLAHABAD

ITA 52/ALLD/2023[2014-15]Status: Disposed31 Oct 2025AY 2014-15Partly Allowed

The Tribunal held that the reopening of assessment under Section 147 was valid as income had escaped assessment. While upholding the addition of excess receipts over payments, it directed deletion of ad-hoc disallowances on cash expenses.

SANJANA,ALLAHABAD vs ITO, WARD- 1(5), ALLAHABAD

ITA 51/ALLD/2023[2013-14]Status: Disposed31 Oct 2025AY 2013-14Partly Allowed

The Tribunal held that the reopening of assessment under Section 147 was valid as income had escaped assessment. While upholding the addition of excess receipts over payments, it directed deletion of ad-hoc disallowances on cash expenses.

YOGI SATYAM,ALLAHABAD vs ITO, WARD- 1(5), ALLAHABAD

ITA 7/ALLD/2023[2014-15]Status: Disposed31 Oct 2025AY 2014-15Partly Allowed

The Tribunal held that the reopening of assessment under Section 147 was valid as income had escaped assessment. While upholding the addition of excess receipts over payments, it directed deletion of ad-hoc disallowances on cash expenses.

YOGI SATYAM,ALLAHABAD vs ITO, WARD- 1 (5), ALLAHABAD

ITA 6/ALLD/2023[2013-14]Status: Disposed31 Oct 2025AY 2013-14Partly Allowed

The Tribunal held that the reopening of assessment under Section 147 was valid as income had escaped assessment. While upholding the addition of excess receipts over payments, it directed deletion of ad-hoc disallowances on cash expenses.

SANJANA,ALLAHABAD vs ITO, WARD-1(5), ALLAHABAD

ITA 54/ALLD/2023[2016-17]Status: Disposed31 Oct 2025AY 2016-17Partly Allowed

The Tribunal held that the reopening of assessment under Section 147 was valid as income had escaped assessment. While upholding the addition of excess receipts over payments, it directed deletion of ad-hoc disallowances on cash expenses.

SANJANA,ALLAHABAD vs ITO, WARD-1(5), ALLAHABAD

ITA 50/ALLD/2023[2012-13]Status: Disposed31 Oct 2025AY 2012-13Partly Allowed

The Tribunal held that the reopening of assessment under Section 147 was valid as income had escaped assessment. While upholding the addition of excess receipts over payments, it directed deletion of ad-hoc disallowances on cash expenses.

M/S JAI MAA SHARDA SERVICE STATION,ALLAHABAD vs ACIT, CENTRAL CIRCLE, ALLAHABAD

ITA 24/ALLD/2019[2010-11]Status: Disposed31 Oct 2025AY 2010-11Partly Allowed

The Tribunal held that while the Range Head's approval was not granted mechanically, the approvals were not obtained for each assessment year and each assessee as required. Consequently, the assessment orders under section 153A were defective. The matters were restored to the Assessing Officer for obtaining fresh approvals.

M/S SUBHASH STONE PRODUCT PRIVATE LIMITED,SONEBHADRA vs ASSTT. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, ALLAHABAD

ITA 108/ALLD/2019[2010-11]Status: Disposed31 Oct 2025AY 2010-11Partly Allowed

The Tribunal held that while the Range Head's approval was not granted mechanically, the approvals were not obtained for each assessment year and each assessee as required. Consequently, the assessment orders under section 153A were defective. The matters were restored to the Assessing Officer for obtaining fresh approvals.

M/S JAI MAA SHARDA SERVICE STATION,ALLAHABAD vs ACIT, CENTRAL CIRCLE, ALLAHABAD

ITA 25/ALLD/2019[2011-12]Status: Disposed31 Oct 2025AY 2011-12Partly Allowed

The Tribunal held that while the Range Head's approval was not granted mechanically, the approvals were not obtained for each assessment year and each assessee as required. Consequently, the assessment orders under section 153A were defective. The matters were restored to the Assessing Officer for obtaining fresh approvals.

ASSTT. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, ALLAHABAD vs VIJAY STONE PRODUCTS, SONEBHADRA

ITA 64/ALLD/2019[2010-11]Status: Disposed31 Oct 2025AY 2010-11Partly Allowed

The Tribunal held that while the Range Head's approval was not granted mechanically, the approvals were not obtained for each assessment year and each assessee as required. Consequently, the assessment orders under section 153A were defective. The matters were restored to the Assessing Officer for obtaining fresh approvals.

RAMJI VAISH,ALLAHABAD vs DCIT(C.C.), ALLAHABAD

ITA 101/ALLD/2023[2008-09]Status: Disposed31 Oct 2025AY 2008-09Partly Allowed

The Tribunal held that while the Range Head's approval was not granted mechanically, the approvals were not obtained for each assessment year and each assessee as required. Consequently, the assessment orders under section 153A were defective. The matters were restored to the Assessing Officer for obtaining fresh approvals.

RAMJI VAISH,ALLAHABAD vs DCIT, (CC), ALLAHABAD

ITA 36/ALLD/2023[2005-06]Status: Disposed31 Oct 2025AY 2005-06Partly Allowed

The Tribunal held that while the Range Head's approval was not granted mechanically, the approvals were not obtained for each assessment year and each assessee as required. Consequently, the assessment orders under section 153A were defective. The matters were restored to the Assessing Officer for obtaining fresh approvals.

ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, ALLAHABAD vs VIJAY STONE PRODUCT, SONEBHADRA

ITA 65/ALLD/2019[2011-12]Status: Disposed31 Oct 2025AY 2011-12Partly Allowed

The Tribunal held that while the Range Head's approval was not granted mechanically, the approvals were not obtained for each assessment year and each assessee as required. Consequently, the assessment orders under section 153A were defective. The matters were restored to the Assessing Officer for obtaining fresh approvals.

SUBHASH STONE PRODUCT (P) LTD.,SONEBHADRA vs ASSTT. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, ALLAHABAD

ITA 107/ALLD/2019[2008-09]Status: Disposed31 Oct 2025AY 2008-09Partly Allowed

The Tribunal held that while the Range Head's approval was not granted mechanically, the approvals were not obtained for each assessment year and each assessee as required. Consequently, the assessment orders under section 153A were defective. The matters were restored to the Assessing Officer for obtaining fresh approvals.

RAMJI VAISH,ALLAHABAD vs DCIT(CC), ALLAHABAD

ITA 126/ALLD/2023[2010-11]Status: Disposed31 Oct 2025AY 2010-11Partly Allowed

The Tribunal held that while the Range Head's approval was not granted mechanically, the approvals were not obtained for each assessment year and each assessee as required. Consequently, the assessment orders under section 153A were defective. The matters were restored to the Assessing Officer for obtaining fresh approvals.

VIJAY STONE PRODUCT,SONEBHADRA vs ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, ALLAHABAD

ITA 30/ALLD/2019[2007-08]Status: Disposed31 Oct 2025AY 2007-08Partly Allowed

The Tribunal held that while the Range Head's approval was not granted mechanically, the approvals were not obtained for each assessment year and each assessee as required. Consequently, the assessment orders under section 153A were defective. The matters were restored to the Assessing Officer for obtaining fresh approvals.

VIJAY STONE PRODUCT,SONEBHADRA vs ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, ALLAHABAD

ITA 32/ALLD/2019[2010-11]Status: Disposed31 Oct 2025AY 2010-11Partly Allowed

The Tribunal held that while the Range Head's approval was not granted mechanically, the approvals were not obtained for each assessment year and each assessee as required. Consequently, the assessment orders under section 153A were defective. The matters were restored to the Assessing Officer for obtaining fresh approvals.

RAMJI VAISH,ALLAHABAD vs DCIT, (CC), ALLAHABAD

ITA 37/ALLD/2023[2006-07]Status: Disposed31 Oct 2025AY 2006-07Partly Allowed

The Tribunal held that while the Range Head's approval was not granted mechanically, the approvals were not obtained for each assessment year and each assessee as required. Consequently, the assessment orders under section 153A were defective. The matters were restored to the Assessing Officer for obtaining fresh approvals.

VIJAY STONE PRODUCT,SONEBHADRA vs ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, ALLAHABAD

ITA 31/ALLD/2019[2009-10]Status: Disposed31 Oct 2025AY 2009-10Partly Allowed

The Tribunal held that while the Range Head's approval was not granted mechanically, the approvals were not obtained for each assessment year and each assessee as required. Consequently, the assessment orders under section 153A were defective. The matters were restored to the Assessing Officer for obtaining fresh approvals.

VIJAY STONE PRODUCT,SONEBHADRA vs ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, ALLAHABAD

ITA 33/ALLD/2019[2011-12]Status: Disposed31 Oct 2025AY 2011-12Partly Allowed

The Tribunal held that while the Range Head's approval was not granted mechanically, the approvals were not obtained for each assessment year and each assessee as required. Consequently, the assessment orders under section 153A were defective. The matters were restored to the Assessing Officer for obtaining fresh approvals.

RAMJI VAISH,ALLAHABAD vs DCIT(CC), ALLAHABAD

ITA 125/ALLD/2023[2009-10]Status: Disposed31 Oct 2025AY 2009-10Partly Allowed

The Tribunal held that while the Range Head's approval was not granted mechanically, the approvals were not obtained for each assessment year and each assessee as required. Consequently, the assessment orders under section 153A were defective. The matters were restored to the Assessing Officer for obtaining fresh approvals.

YOGI SATYAM,ALLAHABAD vs ITO, WARD-1(5), ALLAHABAD

ITA 9/ALLD/2023[2016-17]Status: Disposed31 Oct 2025AY 2016-17Partly Allowed

The Tribunal held that the reopening of assessment under Section 147 was valid as income had escaped assessment. While upholding the addition of excess receipts over payments, it directed deletion of ad-hoc disallowances on cash expenses.

RAMJI VAISH,ALLAHABAD vs DCIT(CC), ALLAHABAD

ITA 127/ALLD/2023[2011-12]Status: Disposed31 Oct 2025AY 2011-12Partly Allowed

The Tribunal held that while the Range Head's approval was not granted mechanically, the approvals were not obtained for each assessment year and each assessee as required. Consequently, the assessment orders under section 153A were defective. The matters were restored to the Assessing Officer for obtaining fresh approvals.

RAMJI VAISH,ALLAHABAD vs DCIT(CC), ALLAHABAD

ITA 38/ALLD/2023[2007-08]Status: Disposed31 Oct 2025AY 2007-08Partly Allowed

The Tribunal held that while the Range Head's approval was not granted mechanically, the approvals were not obtained for each assessment year and each assessee as required. Consequently, the assessment orders under section 153A were defective. The matters were restored to the Assessing Officer for obtaining fresh approvals.

RAM PRAVESH SINGH,SONEBHADRA vs ACIT, CIRCLE 3, MIRZAPUR

ITA 134/ALLD/2025[2015-16]Status: Disposed31 Oct 2025AY 2015-16Partly Allowed

The Tribunal found that the assessee was not afforded a reasonable opportunity during both the assessment and the first appellate proceedings. Consequently, the CIT(A)'s order was set aside, and the disputed issues regarding additions were restored to the Assessing Officer for a fresh de novo assessment after providing due opportunity to the assessee.

SAINT MARYS EDUCATIONAL SOCIETY,ALLAHABAD vs INCOME TAX OFFICER (EXEMPTION), PRAYAGRAJ, PRAYAGRAJ

ITA 61/ALLD/2025[2018-19]Status: Disposed31 Oct 2025AY 2018-19Dismissed

The Income Tax Appellate Tribunal affirmed the CIT(A)'s decision, ruling that the assessee was not eligible for exemption under Section 11 for the assessment year 2018-19 because it did not possess valid Section 12AA registration for that period. The subsequent registration was prospective, effective from AY 2019-20, thus the denial of exemption for AY 2018-19 was correct.

M/S.H.K.INFRAVENTURES PVT. LTD.,ALLAHABAD vs ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, ALLAHABAD

ITA 28/ALLD/2019[2015-16]Status: Disposed30 Oct 2025AY 2015-16Partly Allowed

The Tribunal held that the Assessing Officer erred by making the addition without referring the matter to the Valuation Cell for determining the fair market value. Therefore, the issue of addition was restored to the AO for a de novo assessment after obtaining a valuation report and providing reasonable opportunity to the assessee. The related penalty under section 271(1)(c) was also restored to the AO for a fresh order.

H K INFRAVENTURE PVT. LTD.,ALLAHABAD vs ASSISTANT COMMISSIONER OF INCOME TAX NFAC, DELHI, DELHI

ITA 120/ALLD/2025[2015-16]Status: Disposed30 Oct 2025AY 2015-16Partly Allowed

The Tribunal held that the Assessing Officer erred by making the addition without referring the matter to the Valuation Cell for determining the fair market value. Therefore, the issue of addition was restored to the AO for a de novo assessment after obtaining a valuation report and providing reasonable opportunity to the assessee. The related penalty under section 271(1)(c) was also restored to the AO for a fresh order.

SANGAM EANTA UDYOG,PRATAPGARH vs NATIONAL FACELESS APPEAL CENTRE, , DELHI

ITA 131/ALLD/2025[2015-16]Status: Disposed30 Oct 2025AY 2015-16Dismissed

The Tribunal upheld the CIT(A)'s order, finding it to be just, fair, and well-reasoned. The assessee failed to reconcile the significant variation between total bank credits (including cash deposits) and reported sales, and did not provide sufficient details like purchase bills, sales invoices, or a cash book to substantiate the generation of cash. Thus, the Tribunal found no reason to interfere with the conclusions of the lower authorities.

SHRI MAHAVEER CHARITABLE TRUST ,ALLAHABAD vs ITO(EXEMPTION), ALLAHABAD

ITA 181/ALLD/2024[2013-14]Status: Disposed14 Oct 2025AY 2013-14Partly Allowed

The Tribunal held that the setting aside of the Section 263 order revived the original assessment order. The assessee's appeal against the original assessment was dismissed on technical grounds, but the appeal on merits was restored to the CIT(A) for fresh consideration.