PCIT v. Sidharth Gupta

450 ITR 534High Court2023#626 most cited
157

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2023 to 2026.

Also referred to as

PCIT v. Sidharth Gupta · Sidharth Gupta 450 ITR 534 · Allahabad High Court · Supreme Court SLP dismissal · Section 153A · Section 153D · Section 115BBE · Search and seizure assessment · Binding precedent · Assessee favourable decision · Legal issue decided

Sections most often in play

Section 153DSection 153ASection 143(3)Section 143(2)Section 148Section 132Section 147Section 115BBE

Issues it is cited on

section 115bbe(b)section 2(28c)section 117section 37bsection 271aab(1a)section 274(2)section 271aaasection 144basection 245dsection 153a(1)(a)section 243section 158bg

Judgments citing PCIT v. Sidharth Gupta

Jyoti Mediservices Private Limited, Allahabad vs. DCIT, Central Circle, Allahabad

ITA 113/ALLD/2025[2011-12]Status: DisposedITAT Allahabad21 Nov 2025AY 2011-12

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(2)Section 153ASection 153DSection 271(1)(c)Section 68

…Co. 150 I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 73 taxmann.com 146 (Orissa)/454 ITR 312 (Orissa) and aforesaid order of Hon'ble Allahabad High Court in the case of PCIT vs. Siddharth Gupta 147 taxmann.com 305 (Allahabad)/ 450 ITR 534 (Allahabad); have been dismissed by Hon'ble Supreme Court in decisions at ACIT vs. Serajuddin and Co. 163 taxmann.com 118 (SC) and vide order dated 09/08/2024 in SLP(C) Diary No.43280/2023 in the case of Pr.CIT vs. Siddharth Gupta, respectively. (J.1.2) Similarly, in the case of Pr.CIT & Anr. Vs. Sapna Gupta (supra), Hon'ble Allahabad High Court…

Ramji Vaish, Allahabad vs. DCIT(CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 38/ALLD/2023[2007-08]Status: DisposedITAT Allahabad31 Oct 2025AY 2007-08

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…ted by the superior authority, which could not be said to meet the conditions of an approval as contemplated under section 153D of the Act. The ld. AR invited our attention to the order of the Hon’ble High Court in the case of PCIT vs. Siddhartha Gupta (2023) 450 ITR 534 (All), in which the Hon’ble Allahabad High Court had held that the approval of draft assessment order, being an inbuilt protection against any arbitrary or unjust exercise of power by the ld. AO, cannot be a mechanical exercise, without application of independent mind by the Approving Authority on the material placed before it and the reasoning g…

Ramji Vaish, Allahabad vs. DCIT, (CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 37/ALLD/2023[2006-07]Status: DisposedITAT Allahabad31 Oct 2025AY 2006-07

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…ted by the superior authority, which could not be said to meet the conditions of an approval as contemplated under section 153D of the Act. The ld. AR invited our attention to the order of the Hon’ble High Court in the case of PCIT vs. Siddhartha Gupta (2023) 450 ITR 534 (All), in which the Hon’ble Allahabad High Court had held that the approval of draft assessment order, being an inbuilt protection against any arbitrary or unjust exercise of power by the ld. AO, cannot be a mechanical exercise, without application of independent mind by the Approving Authority on the material placed before it and the reasoning g…

Ramji Vaish, Allahabad vs. DCIT, (CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 36/ALLD/2023[2005-06]Status: DisposedITAT Allahabad31 Oct 2025AY 2005-06

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…ted by the superior authority, which could not be said to meet the conditions of an approval as contemplated under section 153D of the Act. The ld. AR invited our attention to the order of the Hon’ble High Court in the case of PCIT vs. Siddhartha Gupta (2023) 450 ITR 534 (All), in which the Hon’ble Allahabad High Court had held that the approval of draft assessment order, being an inbuilt protection against any arbitrary or unjust exercise of power by the ld. AO, cannot be a mechanical exercise, without application of independent mind by the Approving Authority on the material placed before it and the reasoning g…

Ramji Vaish, Allahabad vs. DCIT(CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 127/ALLD/2023[2011-12]Status: DisposedITAT Allahabad31 Oct 2025AY 2011-12

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…ted by the superior authority, which could not be said to meet the conditions of an approval as contemplated under section 153D of the Act. The ld. AR invited our attention to the order of the Hon’ble High Court in the case of PCIT vs. Siddhartha Gupta (2023) 450 ITR 534 (All), in which the Hon’ble Allahabad High Court had held that the approval of draft assessment order, being an inbuilt protection against any arbitrary or unjust exercise of power by the ld. AO, cannot be a mechanical exercise, without application of independent mind by the Approving Authority on the material placed before it and the reasoning g…

Ramji Vaish, Allahabad vs. DCIT(CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 126/ALLD/2023[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…ted by the superior authority, which could not be said to meet the conditions of an approval as contemplated under section 153D of the Act. The ld. AR invited our attention to the order of the Hon’ble High Court in the case of PCIT vs. Siddhartha Gupta (2023) 450 ITR 534 (All), in which the Hon’ble Allahabad High Court had held that the approval of draft assessment order, being an inbuilt protection against any arbitrary or unjust exercise of power by the ld. AO, cannot be a mechanical exercise, without application of independent mind by the Approving Authority on the material placed before it and the reasoning g…

Ramji Vaish, Allahabad vs. DCIT(CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 125/ALLD/2023[2009-10]Status: DisposedITAT Allahabad31 Oct 2025AY 2009-10

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…ted by the superior authority, which could not be said to meet the conditions of an approval as contemplated under section 153D of the Act. The ld. AR invited our attention to the order of the Hon’ble High Court in the case of PCIT vs. Siddhartha Gupta (2023) 450 ITR 534 (All), in which the Hon’ble Allahabad High Court had held that the approval of draft assessment order, being an inbuilt protection against any arbitrary or unjust exercise of power by the ld. AO, cannot be a mechanical exercise, without application of independent mind by the Approving Authority on the material placed before it and the reasoning g…

Ramji Vaish, Allahabad vs. DCIT(C.C.), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 101/ALLD/2023[2008-09]Status: DisposedITAT Allahabad31 Oct 2025AY 2008-09

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…ted by the superior authority, which could not be said to meet the conditions of an approval as contemplated under section 153D of the Act. The ld. AR invited our attention to the order of the Hon’ble High Court in the case of PCIT vs. Siddhartha Gupta (2023) 450 ITR 534 (All), in which the Hon’ble Allahabad High Court had held that the approval of draft assessment order, being an inbuilt protection against any arbitrary or unjust exercise of power by the ld. AO, cannot be a mechanical exercise, without application of independent mind by the Approving Authority on the material placed before it and the reasoning g…

Asstt. Commissioner of Income Tax, Central Circle, Allahabad vs. Vijay Stone Product, Sonebhadra

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 65/ALLD/2019[2011-12]Status: DisposedITAT Allahabad31 Oct 2025AY 2011-12

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…ted by the superior authority, which could not be said to meet the conditions of an approval as contemplated under section 153D of the Act. The ld. AR invited our attention to the order of the Hon’ble High Court in the case of PCIT vs. Siddhartha Gupta (2023) 450 ITR 534 (All), in which the Hon’ble Allahabad High Court had held that the approval of draft assessment order, being an inbuilt protection against any arbitrary or unjust exercise of power by the ld. AO, cannot be a mechanical exercise, without application of independent mind by the Approving Authority on the material placed before it and the reasoning g…

Asstt. Commissioner of Income Tax Central Circle, Allahabad vs. Vijay Stone Products, Sonebhadra

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 64/ALLD/2019[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…ted by the superior authority, which could not be said to meet the conditions of an approval as contemplated under section 153D of the Act. The ld. AR invited our attention to the order of the Hon’ble High Court in the case of PCIT vs. Siddhartha Gupta (2023) 450 ITR 534 (All), in which the Hon’ble Allahabad High Court had held that the approval of draft assessment order, being an inbuilt protection against any arbitrary or unjust exercise of power by the ld. AO, cannot be a mechanical exercise, without application of independent mind by the Approving Authority on the material placed before it and the reasoning g…

Vijay Stone Product, Sonebhadra vs. Asstt. Commissioner of Income Tax, Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 33/ALLD/2019[2011-12]Status: DisposedITAT Allahabad31 Oct 2025AY 2011-12

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…ted by the superior authority, which could not be said to meet the conditions of an approval as contemplated under section 153D of the Act. The ld. AR invited our attention to the order of the Hon’ble High Court in the case of PCIT vs. Siddhartha Gupta (2023) 450 ITR 534 (All), in which the Hon’ble Allahabad High Court had held that the approval of draft assessment order, being an inbuilt protection against any arbitrary or unjust exercise of power by the ld. AO, cannot be a mechanical exercise, without application of independent mind by the Approving Authority on the material placed before it and the reasoning g…

Vijay Stone Product, Sonebhadra vs. Asstt. Commissioner of Income Tax, Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 32/ALLD/2019[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…ted by the superior authority, which could not be said to meet the conditions of an approval as contemplated under section 153D of the Act. The ld. AR invited our attention to the order of the Hon’ble High Court in the case of PCIT vs. Siddhartha Gupta (2023) 450 ITR 534 (All), in which the Hon’ble Allahabad High Court had held that the approval of draft assessment order, being an inbuilt protection against any arbitrary or unjust exercise of power by the ld. AO, cannot be a mechanical exercise, without application of independent mind by the Approving Authority on the material placed before it and the reasoning g…

Vijay Stone Product, Sonebhadra vs. Asstt. Commissioner of Income Tax, Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 31/ALLD/2019[2009-10]Status: DisposedITAT Allahabad31 Oct 2025AY 2009-10

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…ted by the superior authority, which could not be said to meet the conditions of an approval as contemplated under section 153D of the Act. The ld. AR invited our attention to the order of the Hon’ble High Court in the case of PCIT vs. Siddhartha Gupta (2023) 450 ITR 534 (All), in which the Hon’ble Allahabad High Court had held that the approval of draft assessment order, being an inbuilt protection against any arbitrary or unjust exercise of power by the ld. AO, cannot be a mechanical exercise, without application of independent mind by the Approving Authority on the material placed before it and the reasoning g…

Vijay Stone Product, Sonebhadra vs. Asstt. Commissioner of Income Tax, Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 30/ALLD/2019[2007-08]Status: DisposedITAT Allahabad31 Oct 2025AY 2007-08

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…ted by the superior authority, which could not be said to meet the conditions of an approval as contemplated under section 153D of the Act. The ld. AR invited our attention to the order of the Hon’ble High Court in the case of PCIT vs. Siddhartha Gupta (2023) 450 ITR 534 (All), in which the Hon’ble Allahabad High Court had held that the approval of draft assessment order, being an inbuilt protection against any arbitrary or unjust exercise of power by the ld. AO, cannot be a mechanical exercise, without application of independent mind by the Approving Authority on the material placed before it and the reasoning g…

M/S Jai Maa Sharda Service Station, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 25/ALLD/2019[2011-12]Status: DisposedITAT Allahabad31 Oct 2025AY 2011-12

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…ted by the superior authority, which could not be said to meet the conditions of an approval as contemplated under section 153D of the Act. The ld. AR invited our attention to the order of the Hon’ble High Court in the case of PCIT vs. Siddhartha Gupta (2023) 450 ITR 534 (All), in which the Hon’ble Allahabad High Court had held that the approval of draft assessment order, being an inbuilt protection against any arbitrary or unjust exercise of power by the ld. AO, cannot be a mechanical exercise, without application of independent mind by the Approving Authority on the material placed before it and the reasoning g…

M/S Jai Maa Sharda Service Station, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 24/ALLD/2019[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…ted by the superior authority, which could not be said to meet the conditions of an approval as contemplated under section 153D of the Act. The ld. AR invited our attention to the order of the Hon’ble High Court in the case of PCIT vs. Siddhartha Gupta (2023) 450 ITR 534 (All), in which the Hon’ble Allahabad High Court had held that the approval of draft assessment order, being an inbuilt protection against any arbitrary or unjust exercise of power by the ld. AO, cannot be a mechanical exercise, without application of independent mind by the Approving Authority on the material placed before it and the reasoning g…

M/S Subhash Stone Product Private Limited, Sonebhadra vs. Asstt. Commissioner of Income Tax Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 108/ALLD/2019[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…ted by the superior authority, which could not be said to meet the conditions of an approval as contemplated under section 153D of the Act. The ld. AR invited our attention to the order of the Hon’ble High Court in the case of PCIT vs. Siddhartha Gupta (2023) 450 ITR 534 (All), in which the Hon’ble Allahabad High Court had held that the approval of draft assessment order, being an inbuilt protection against any arbitrary or unjust exercise of power by the ld. AO, cannot be a mechanical exercise, without application of independent mind by the Approving Authority on the material placed before it and the reasoning g…

Subhash Stone Product (P) Ltd., Sonebhadra vs. Asstt. Commissioner of Income Tax Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 107/ALLD/2019[2008-09]Status: DisposedITAT Allahabad31 Oct 2025AY 2008-09

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…ted by the superior authority, which could not be said to meet the conditions of an approval as contemplated under section 153D of the Act. The ld. AR invited our attention to the order of the Hon’ble High Court in the case of PCIT vs. Siddhartha Gupta (2023) 450 ITR 534 (All), in which the Hon’ble Allahabad High Court had held that the approval of draft assessment order, being an inbuilt protection against any arbitrary or unjust exercise of power by the ld. AO, cannot be a mechanical exercise, without application of independent mind by the Approving Authority on the material placed before it and the reasoning g…

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Aman Feed Industries, Khanna

In the result, appeals of the assessee for A

ITA 457/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh16 Oct 2025AY 2019-20

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1252, 1253,1254,1255/Chd/2024 "नधा"रण वष" / A.Y.: 2015-16, 2017-18, 2018-19,2019-20 M/S Aman Feed Industries, The Dcit, E-2, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 116,181,457/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs M/S Aman Feed Industries, Central Circle-1, E-2, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms, Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025

For Appellant: Shri Ashwani Kumar, Shri Kulbhushan Goyal &For Respondent: Shri Manav Bansal, CIT DR
Section 145(3)Section 153ASection 153DSection 250Section 68

…आयकर अपील"य अ"धकरण,च"डीगढ़ "यायपीठ, च"डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL DIVISION BENCH, ‘A’ CHANDIGARH BEFORE SHRI RAJPAL YADAV, VICE PRESIDENT AND SHRI KRINWANT SAHAY, ACCOUNTANT MEMBER आयकर अपील सं./ ITA Nos. 1252, 1253,1254,1255/CHD/2024 "नधा"रण वष" / A.Y.: 2015-16, 2017-18, 2018-19,2019-20 M/s Aman Feed Industries, The DCIT, E-2, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./PAN NO: AACFA3624L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ ITA Nos. 116,181,457/CHD/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The DCIT, Vs M/s Aman Feed Industries, Central Circle-1, E-2, F…

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. M/S Afi Agro Pvt. Ltd., Khanna

In the result, all the appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 373/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh16 Oct 2025AY 2019-20

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1256, 1257,1258/Chd/2024 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 Afi Agro Private Limited, The Dcit, A-1, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aaeca6479L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 179,180,373/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs Afi Agro Private Limited, Central Circle-1, A-1, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aaeca6479L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms. Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025 Physical Hearing O R D E R Per Raj Pal Yadav, Vp

For Appellant: Shri Ashwani Kumar, Shri Kulbhushan Goyal &For Respondent: Shri Manav Bansal, CIT DR
Section 132Section 139(1)Section 139(4)Section 143(2)Section 153ASection 153D

…आयकर अपील"य अ"धकरण,च"डीगढ़ "यायपीठ, च"डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL DIVISION BENCH, ‘A’ CHANDIGARH BEFORE SHRI RAJPAL YADAV, VICE PRESIDENT AND SHRI KRINWANT SAHAY, ACCOUNTANT MEMBER आयकर अपील सं./ ITA Nos. 1256, 1257,1258/CHD/2024 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 AFI Agro Private Limited, The DCIT, A-1, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./PAN NO: AAECA6479L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ ITA Nos. 179,180,373/CHD/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The DCIT, Vs AFI Agro Private Limited, Central Circle-1, A-1, Focal Point,…