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22 results for “TDS”+ Reopening of Assessmentclear

Sorted by relevance

Mumbai1,015Delhi763Chennai581Pune368Bangalore305Kolkata175Ahmedabad164Indore157Hyderabad153Jaipur96Chandigarh81Cochin70Visakhapatnam68Raipur58Rajkot51Lucknow41Patna30Nagpur30Surat29Guwahati23Agra22Karnataka15Panaji13Amritsar12Cuttack10Dehradun8Jabalpur6Ranchi6SC5Jodhpur3Allahabad3Calcutta2Telangana2Varanasi1Kerala1

Key Topics

Section 14861Section 14743Section 234E20Section 200A18TDS17Section 148A16Section 14416Section 142(1)13Section 220(2)12Addition to Income

BADARIPRASAD,GUNA vs. INCOME TAX OFFICER GUNA, GUNA

In the result, appeal filed by the assessee is allowed

ITA 473/AGR/2025[2018-19]Status: DisposedITAT Agra21 Jan 2026AY 2018-19

Bench: Shri M. Balaganeshbadriprasad, Vs. Income Tax Officer, Heerabagh Colony, Guna, Guna, Gwalior Gwalior (Appellant) (Respondent) Pan: Arapr6314B

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 144BSection 147Section 148Section 148ASection 151Section 151A

reopen the assessment is bad in law after the CBDT Faceless Scheme notified from 29.03.2022 (supra) read with section 151/151A of the Act, which legal issue we will deal first. 9. We note that on this legal issue there are divergent views expressed by different Hon’ble High Courts. However, it is noted that on this issue

Showing 1–20 of 22 · Page 1 of 2

10
Reassessment8
Reopening of Assessment6

HARICHARAN RATHORE,ASHOK NAGAR vs. INCOME TAX OFFICER,ASHOK NAGAR, ASHOK NAGAR

In the result, appeal filed by the assessee is allowed

ITA 472/AGR/2025[2020-21]Status: DisposedITAT Agra21 Jan 2026AY 2020-21

Bench: Shri M. Balaganeshharicharan Rathore, Vs. Ito, 125, Path Kheda, Ashok Ashok Nagar, Nagar, Mp Mp (Appellant) (Respondent) Pan: Csqpr0999M Assessee By : Shri Rajendra Sharma, Adv Shri Manuj Sharma, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 21/01/2026

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 144BSection 147Section 148Section 148ASection 151Section 151A

reopen the assessment is bad in law after the CBDT Faceless Scheme notified from 29.03.2022 (supra) read with section 151/151A of the Act, which legal issue we will deal first. 9. We note that on this legal issue there are divergent views expressed by different Hon‟ble High Courts. However, it is noted that on this issue

NARAYANI RATHORE,SHIVPURI vs. ASSESSMENT UNIT,INCOME TAX DEPARTMENT, DELHI

In the result, appeal filed by the assessee is allowed

ITA 444/AGR/2025[2018-19]Status: DisposedITAT Agra21 Jan 2026AY 2018-19

Bench: Shri M. Balaganeshnarayani Rathore, Vs. Assessment Unit, Peeroth Shivpuri, Income Tax Shivpuri, Mp Department, National Faceless Appeal Centre, Delhi (Appellant) (Respondent) Pan: Dhgpr1886H

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 144BSection 147Section 148Section 148ASection 151Section 151A

reopen the assessment is bad in law after the CBDT Faceless Scheme notified from 29.03.2022 (supra) read with section 151/151A of the Act, which legal issue we will deal first. 9. We note that on this legal issue there are divergent views expressed by different Hon’ble High Courts. However, it is noted that on this issue

ASHOK SAHU,JHANSI vs. INCOME TAX OFFICER, WARD 2(3)(1), JHANSI, JHANSI

In the result, appeal filed by the assessee is allowed

ITA 452/AGR/2025[2018-19]Status: DisposedITAT Agra21 Jan 2026AY 2018-19

Bench: Shri M. Balaganeshashok Sahu, Vs. Income Tax Officer, Purana Bazar, Chirgaon, Ward-2(3)(1), Jhansi Jhansi (Appellant) (Respondent) Pan: Jgsps3446H Sunita, Vs. Assessment Unit, Ward No. 2, Chobyana Income Tax Talrehat Lake View Department, Camp, Lalitpur, Lalitpur, National Faceless Up Appeal Centre, Delhi (Appellant) (Respondent) Pan: Jgps3438H

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 144BSection 147Section 148Section 148ASection 151Section 151A

reopen the assessment is bad in law after the CBDT Faceless Scheme notified from 29.03.2022 (supra) read with section 151/151A of the Act, which legal issue we will deal first. 9. We note that on this legal issue there are divergent views expressed by different Hon‟ble High Courts. However, it is noted that on this issue

SUNITA,SAHU vs. ASSESSMENT UNIT,INCOME TAX DEPARTMENT, DELHI

In the result, appeal filed by the assessee is allowed

ITA 432/AGR/2025[2018-19]Status: DisposedITAT Agra21 Jan 2026AY 2018-19

Bench: Shri M. Balaganeshashok Sahu, Vs. Income Tax Officer, Purana Bazar, Chirgaon, Ward-2(3)(1), Jhansi Jhansi (Appellant) (Respondent) Pan: Jgsps3446H Sunita, Vs. Assessment Unit, Ward No. 2, Chobyana Income Tax Talrehat Lake View Department, Camp, Lalitpur, Lalitpur, National Faceless Up Appeal Centre, Delhi (Appellant) (Respondent) Pan: Jgps3438H

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 144BSection 147Section 148Section 148ASection 151Section 151A

reopen the assessment is bad in law after the CBDT Faceless Scheme notified from 29.03.2022 (supra) read with section 151/151A of the Act, which legal issue we will deal first. 9. We note that on this legal issue there are divergent views expressed by different Hon‟ble High Courts. However, it is noted that on this issue

AVNEESH KUMAR CHATURVEDI,AGRA vs. I.T.O-2(2), AGRA

In the result, this appeal by the assessee stands partly allowed

ITA 386/AGR/2017[2008-09]Status: DisposedITAT Agra25 Jul 2023AY 2008-09

Bench: Shri Shamim Yahya & Shri Yogesh Kumar Us[Assessment Year: 2008-09]

Section 143(3)Section 144Section 147Section 148Section 40A(3)

TDS certificates, and two, the payments of Rs.15,48,900/-, which had been made through bearer cheques by the assessee which came within the ambit of section 40A(3) of the Act. Thereafter, assessment has been completed us 144/148 vide the impugned order dated 18.02.2015 determining the assessed income at Rs. 9,93,660/- as against the originally assessed income

KAMLESH KATARE,GWALIOR vs. ITO, TDS-GWALIOR, GWALIOR

The appeal stand allowed in terms of our above order

ITA 111/AGR/2023[2013-14]Status: DisposedITAT Agra28 Mar 2025AY 2013-14

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No. 111/Agr/2023 (िनधा"रणवष" / Assessment Year: 2013-14) Shri Kamlesh Katare Ito (Tds) बनाम/ 79, Jotinagar, Thatipur Gwalior Vs. Morar, Gwalior "थायीलेखासं./जीआइआरसं./Pan/Gir/Tan No.Bplk-03165-B (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Ashok Vijaywargiya, Ca- Ld. Ar ""थ"कीओरसे/Respondent By : Shri Shailendra Shrivastava – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 13-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 28-03-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aggrieved By Levy Of Late Filing Fees U/S 234E Qua Tds Return In Form 26Q For 4Th Quarter Of Financial Year 2012-13, The Assessee Is In Further Appeal Before Us. 2. From The Records, It Emerges That The Assessee Was Saddled With Later Filing Fees U/S 234E For Rs.22,800/- While Processing Tds Return As Filed By The Assessee. The Assessee Sought Rectification Thereof U/S 154 Which Was Rejected By Ld. Ao. Aggrieved, The Assessee Filed Further Appeal Which Met With No Success. Aggrieved, The Assessee Is In Further Appeal Before Us.

For Appellant: Shri Ashok Vijaywargiya, CA- Ld. ARFor Respondent: Shri Shailendra Shrivastava – Ld. Sr. DR
Section 154Section 200ASection 234E

Assessment Year: 2013-14) Shri Kamlesh Katare ITO (TDS) बनाम/ 79, Jotinagar, Thatipur Gwalior Vs. Morar, Gwalior "थायीलेखासं./जीआइआरसं./PAN/GIR/TAN No.BPLK-03165-B (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant by : Shri Ashok Vijaywargiya, CA- Ld. AR ""थ"कीओरसे/Respondent by : Shri Shailendra Shrivastava – Ld. Sr. DR सुनवाईकीतारीख/Date of Hearing : 13-02-2025 घोषणाकीतारीख /Date of Pronouncement

CIVIL SURGEON CUM HOSPITAL SUPERINTANDENT BHIND (M.P.),BHIND vs. INCOME TAX OFFICER TDS OFFICE, GWALIOR

In the result, assessee’s appeals ITA Nos

ITA 596/AGR/2025[2014-15]Status: DisposedITAT Agra19 Feb 2026AY 2014-15

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 154Section 200Section 200ASection 220(2)Section 234ESection 250

reopen the said question unless he has made payment under protest.” 6. In view of the above, respectfully following ‘Shri Fatehraj Singhvi and Others’ (supra), ‘Sibia Healthcare Pvt. Ltd. vs. DCIT (TDS)’, order dated 09.06.2015 passed in ITA No.90/ASR/2015, for A.Y.2013-14, by the Amritsar Bench of the Tribunal, and ‘Shri Kaur Chand Jain vs. DCIT, CPC (TDS) Ghaziabad’, order dated

CIVIL SURGEON CUM HOSPITAL SUPERINTANDENT BHIND (M.P.),BHIND vs. INCOME TAX OFFICER TDS OFFICE GWALIOR, GWALIOR

In the result, assessee’s appeals ITA Nos

ITA 595/AGR/2025[2015-16]Status: DisposedITAT Agra19 Feb 2026AY 2015-16

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 154Section 200Section 200ASection 220(2)Section 234ESection 250

reopen the said question unless he has made payment under protest.” 6. In view of the above, respectfully following ‘Shri Fatehraj Singhvi and Others’ (supra), ‘Sibia Healthcare Pvt. Ltd. vs. DCIT (TDS)’, order dated 09.06.2015 passed in ITA No.90/ASR/2015, for A.Y.2013-14, by the Amritsar Bench of the Tribunal, and ‘Shri Kaur Chand Jain vs. DCIT, CPC (TDS) Ghaziabad’, order dated

CIVIL SURGEON CUM HOSPITAL SUPERINTANDENT BHIND (M.P.),BHIND vs. INCOME TAX OFFICER TDS OFFICE GWALIOR, GWALIOR

In the result, assessee’s appeals ITA Nos

ITA 594/AGR/2025[2015-16]Status: DisposedITAT Agra19 Feb 2026AY 2015-16

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 154Section 200Section 200ASection 220(2)Section 234ESection 250

reopen the said question unless he has made payment under protest.” 6. In view of the above, respectfully following ‘Shri Fatehraj Singhvi and Others’ (supra), ‘Sibia Healthcare Pvt. Ltd. vs. DCIT (TDS)’, order dated 09.06.2015 passed in ITA No.90/ASR/2015, for A.Y.2013-14, by the Amritsar Bench of the Tribunal, and ‘Shri Kaur Chand Jain vs. DCIT, CPC (TDS) Ghaziabad’, order dated

CIVIL SURGEON CUM HOSPITAL SUPERINTANDENT BHIND,BHIND vs. AESSESSING OFFICER TDS OFFICE, AAYAKAR BHAVWAN CITY CENTRE FLOOR FIRST

In the result, assessee’s appeals ITA Nos

ITA 589/AGR/2025[2015-16]Status: DisposedITAT Agra19 Feb 2026AY 2015-16

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 154Section 200Section 200ASection 220(2)Section 234ESection 250

reopen the said question unless he has made payment under protest.” 6. In view of the above, respectfully following ‘Shri Fatehraj Singhvi and Others’ (supra), ‘Sibia Healthcare Pvt. Ltd. vs. DCIT (TDS)’, order dated 09.06.2015 passed in ITA No.90/ASR/2015, for A.Y.2013-14, by the Amritsar Bench of the Tribunal, and ‘Shri Kaur Chand Jain vs. DCIT, CPC (TDS) Ghaziabad’, order dated

GUMAN SINGH KUSHWAH,SHIVPURI vs. INCOME TAX OFFICER, ASHOKNAGAR

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 544/AGR/2025[2014-15]Status: DisposedITAT Agra22 Jan 2026AY 2014-15

Bench: Shri M. Balaganeshgumnam Singh Kushwah, Vs. Income Tax Officer, Infront Of Collector Kothi, Ashok Nagar, Shiv Colony, Shivpuri, Mp Mp (Appellant) (Respondent) Pan: Bcjpk2729Q Assessee By : Shri Ashish Goyal, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 22/01/2026

For Appellant: Shri Ashish Goyal, CAFor Respondent: Shri Anil Kumar, Sr. DR
Section 142(1)Section 143(3)Section 144Section 147Section 148Section 194Section 194ISection 201Section 206ASection 50C

reopened vide issuance of notice under section 148 of the Act on 30-3-2021. In response to the notice under section 148 of the Act, the assessee did not file any return of income nor filed any written submissions. The Learned AO issued notices under section

INCOME TAX OFFICER, ASHOKNAGAR vs. AJIT SINGH , SHIVPURI

In the result, the appeal of the revenue is allowed for statistical purposes

ITA 89/AGR/2025[2013]Status: DisposedITAT Agra04 Dec 2025

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh (Through Virtual Hearing) Income Tax Officer, Vs. Ajit Singh, Ashoknagar, Village-Haatodh, Madhya Pradesh Post-Kota, Shivpuri (Appellant) (Respondent) Pan: Ccnps7470K Assessee By : Shri Vipin Upadhyay, Adv Revenue By: Shri Sukesh Kumar Jain, Cit(Dr) Date Of Hearing 17/11/2025 Date Of Pronouncement 04/11/2025

For Appellant: Shri Vipin Upadhyay, AdvFor Respondent: Shri Sukesh Kumar Jain, CIT(DR)
Section 133(6)Section 139Section 142(1)Section 143(2)Section 143(3)Section 144Section 144BSection 147Section 148Section 148(1)

TDS return – Rs. 50,024 5. Since the aforesaid transactions were above the maximum amount not chargeable to tax, the Learned AO proceeded to reopen the assessment

MANDIR LODI MATA,SHIVPURI vs. THE ITO- ASHOK NAGAR, GWALIOR

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 552/AGR/2025[2020-21]Status: DisposedITAT Agra19 Feb 2026AY 2020-21

Bench: : Shri S. Rifaur Rahmanassessment Year: 2020-21 Mandir Lodi Mata Vs. Income Tax Officer, Narwar Karera Ashok Nagar Shivpuri, Madhya Pradesh Pan : Aaetm2888E (Appellant) (Respondent) Assessee By Shri Naveen Gargh, Adv. Department By Shri Anil Kumar, Sr. Dr Date Of Hearing 19.02.2026 Date Of Pronouncement 19.02.2026 Order

Section 147Section 148Section 148ASection 69A

Assessing Officer. 6. Considered the rival submissions and material placed on record. I observe that the case of the assessee was reopened on the basis of TDS

MEERA YADAV,JHANSI vs. DCIT, CIRCLE2(1)(1), AGRA

In the result, ITA No. 359, 394 and 360/Agr/2025 are allowed for

ITA 359/AGR/2025[2013-14]Status: DisposedITAT Agra26 Nov 2025AY 2013-14

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 142(1)Section 143(1)Section 144Section 147Section 148Section 250Section 37

TDS as per its profit and loss account. Assessing Officer was of the view that any interest on dues is a penalty and not acceptable as expenses under the Act. Hence, case was reopened

MEERA YADAV,JHANSI vs. DCIT, CIRCLE 2(1)(1), AGRA

In the result, ITA No. 359, 394 and 360/Agr/2025 are allowed for

ITA 360/AGR/2025[2018-19]Status: DisposedITAT Agra26 Nov 2025AY 2018-19

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 142(1)Section 143(1)Section 144Section 147Section 148Section 250Section 37

TDS as per its profit and loss account. Assessing Officer was of the view that any interest on dues is a penalty and not acceptable as expenses under the Act. Hence, case was reopened

MEERA YADAV,JHANSI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 2(1)(1), AGRA

In the result, ITA No. 359, 394 and 360/Agr/2025 are allowed for

ITA 394/AGR/2025[2017-2018]Status: DisposedITAT Agra26 Nov 2025AY 2017-2018

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 142(1)Section 143(1)Section 144Section 147Section 148Section 250Section 37

TDS as per its profit and loss account. Assessing Officer was of the view that any interest on dues is a penalty and not acceptable as expenses under the Act. Hence, case was reopened

HARI MOHAN ,GUJRAT vs. DCIT-3, MATHURA

The appeals stand partly allowed

ITA 362/AGR/2018[2012-13]Status: DisposedITAT Agra22 Apr 2025AY 2012-13

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No. 362/Agr/2018 (िनधा"रणवष" / Assessment Year:2012-13) & 2. आयकरअपीलसं./ Ita No. 363/Agr/2018 (िनधा"रणवष" / Assessment Year:2012-13) Shri Hari Mohan Dcit-3, बनाम/ 82, Chitrakut Apartments, Mathura. Near Bapu Dargah, Gorwa, Vs. Vadodara, Gujrat. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Ahppm-5638-N (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Anurag Sinha, Adv. – Ld. Ar " थ"कीओरसे/Respondent By : Sh. Shailender Shrivastava – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 20-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 22.04.2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeals By Assessee For Assessment Year (Ay) 2012-13 Arises Out Of Separate Orders Of First Appellate Authority. First, We Take Up Appeal Ita No.363/Agr/2018 Which Arises Out Of An Order Passed By Learned Commissioner Of Income Tax (Appeals), Agra [Cit(A)] On 28-02- 2018 In The Matter Of An Assessment Framed By Ld. Ao U/S 144 On 04-03- 2015. Having Heard Rival Submissions, Our Adjudication Would Be As Under. 2. From Case Records, It Emerges That The Assessee Is A Civil Contractor & It Filed Returned Income Of Rs.16.52 Lacs. The Assessee

For Appellant: Sh. Anurag Sinha, Adv. – Ld. ARFor Respondent: Sh. Shailender Shrivastava – Ld. DR
Section 144

assessment against which the assessee is in further appeal before us. 3. Subsequently, the case of the assessee was reopened by Ld. AO on the ground that actual contractual receipts were Rs.540.32 Lacs. The assessee stated that receipts include closing work-in-progress whereas contractor had shown this amount as work done and deducted TDS

HARI MOHAN ,GUJRAT vs. DCIT-3, MATHURA

The appeals stand partly allowed

ITA 363/AGR/2018[2012-13]Status: DisposedITAT Agra22 Apr 2025AY 2012-13

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No. 362/Agr/2018 (िनधा"रणवष" / Assessment Year:2012-13) & 2. आयकरअपीलसं./ Ita No. 363/Agr/2018 (िनधा"रणवष" / Assessment Year:2012-13) Shri Hari Mohan Dcit-3, बनाम/ 82, Chitrakut Apartments, Mathura. Near Bapu Dargah, Gorwa, Vs. Vadodara, Gujrat. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Ahppm-5638-N (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Anurag Sinha, Adv. – Ld. Ar " थ"कीओरसे/Respondent By : Sh. Shailender Shrivastava – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 20-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 22.04.2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeals By Assessee For Assessment Year (Ay) 2012-13 Arises Out Of Separate Orders Of First Appellate Authority. First, We Take Up Appeal Ita No.363/Agr/2018 Which Arises Out Of An Order Passed By Learned Commissioner Of Income Tax (Appeals), Agra [Cit(A)] On 28-02- 2018 In The Matter Of An Assessment Framed By Ld. Ao U/S 144 On 04-03- 2015. Having Heard Rival Submissions, Our Adjudication Would Be As Under. 2. From Case Records, It Emerges That The Assessee Is A Civil Contractor & It Filed Returned Income Of Rs.16.52 Lacs. The Assessee

For Appellant: Sh. Anurag Sinha, Adv. – Ld. ARFor Respondent: Sh. Shailender Shrivastava – Ld. DR
Section 144

assessment against which the assessee is in further appeal before us. 3. Subsequently, the case of the assessee was reopened by Ld. AO on the ground that actual contractual receipts were Rs.540.32 Lacs. The assessee stated that receipts include closing work-in-progress whereas contractor had shown this amount as work done and deducted TDS

MAMTA AGARWAL,ALIGARH vs. PCIT AGRA-1, AGRA

In the result, both the appeals of the assessee are allowed

ITA 204/AGR/2025[2016-17]Status: DisposedITAT Agra13 Oct 2025AY 2016-17

Bench: Shri Sunil Kumar Singh & Shri Brajesh Kumar Singh

Section 142(1)Section 147Section 147oSection 148Section 263Section 50Section 50CSection 50C(1)Section 56(2)Section 56(2)(viib)

Assessing Officer (‘AO’, for short) on 23.06.2022 and 30.05.2022 respectively under Section 147 of the Act, in the case of Ms. Mamta Agarwal and Shri Rakesh Agarwal by the ACIT, Circle 4(1)(1), Aligarh. Since identical issues are involved in both the appeals, these are disposed of by this consolidated order for the sake of convenience and brevity