ACIT, CC, AGRA, AGRA vs. HMA AGRO INDUSTRIES LIMITED,, AGRA

In the result, ground no.1 raised by the Revenue is accordingly dismissed

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

147 and the same enquiry have been referred in the case of the Md. Irfan. Though, it is very established that, this is not a case of lack of enquiry, therefore it is mere a change of opinion of the Ld. PCIT in invoking the provisions of section 263 read with Explanation 2 clause (a) and since adequate

ACIT, CC, AGRA, AGRA vs. HMA AGRO INDUSTRIES LIMITED,, AGRA

In the result, ground no.1 raised by the Revenue is accordingly dismissed

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

147 and the same enquiry have been referred in the case of the Md. Irfan. Though, it is very established that, this is not a case of lack of enquiry, therefore it is mere a change of opinion of the Ld. PCIT in invoking the provisions of section 263 read with Explanation 2 clause (a) and since adequate

ACIT, CC, AGRA, AGRA vs. HMA AGRO INDUSTRIES LIMITED,, AGRA

In the result, appeal filed by the assessee for AY 2019-20 is\nallowed and appeals filed by the Revenue in AYs 2021-22, 2022-23 and\n2023-24 are dismissed

bogus purchases from Md. Irfan. The Assessing Officer (AO) initially accepted the purchases as genuine after investigations, but the Principal Commissioner (PCIT) initiated revision proceedings u/s 263, viewing the AO's assessment as erroneous and prejudicial.", "held": "The Tribunal held that the PCIT had erred in invoking Section 263 as the AO had conducted adequate inquiries, recorded statements, and applied

ACIT, CC, AGRA, AGRA vs. HMA AGRO INDUSTRIES LIMITED, AGRA

In the result, appeal filed by the assessee for AY 2019-20 is\nallowed and appeals filed by the Revenue in AYs 2021-22, 2022-23 and\n2023-24 are dismissed

bogus purchases from one Md. Irfan. The Assessing Officer (AO) initially accepted the purchases in the original assessment and during reassessment, after recording Md. Irfan's statement. However, the Principal Commissioner of Income Tax (PCIT) initiated revision proceedings u/s 263, believing the AO had not conducted proper inquiries. The PCIT set aside the assessment order, directing fresh inquiries.", "held

MAHESH EDIBLE OIL INDUSTRIES LIMITED,DELHI vs. ASSTT. COMMISSIONER OF INCOME TAX, AGRA

purchases. The ITAT also observed that the valuation differences for investments were within the tolerance range.", "result": "Partly Allowed", "sections": [ "153A", "143(3)", "145", "142A", "37(1)", "69B", "69C", "234A", "234B", "234C", "132", "132A", "147", "148", "44AD", "69A" ], "issues": "Whether additions made under section 153A based on alleged bogus

SMT. VIDHYA AGARWAL,AGRA vs. I.T.O., WARD-4(4), AGRA

The appeal is allowed

Bench: Shri Sudhanshu Srivastava & Dr. Mitha Lal Meena

147, and that the failure to take steps under section 143(3) will not render him powerless to initiate reassessment proceedings even when intimation under section 143(1) had been issued". "In other words", according to Hon'ble Bombay High Court, "when an intimation has been issued under section 143(1), the Assessing Officer is competent to initiate reassessment proceedings

DEPUTY COMMISSIONER OF INCOME TAX, AGRA vs. MAHESH EDIBLE OIL INDUSTRIES LTD, DELHI

bogus purchases and unexplained investments, which were largely confirmed by the Commissioner of Income Tax (Appeals) [CIT(A)]. The assessee contended that no incriminating material was found during the search for these additions, rendering the AO's jurisdiction under Section 153A invalid for completed assessment years.", "held": "The Tribunal held that additions made under Section 153A require incriminating material found

M/S DEEPRAJ HOSPITAL P LTD,HATHRAS vs. ITO 3(5), HATHRAS

In the result, both the appeals are allowed

Bench: Shri A. D. Jain

section 148 as well as consequent assessment where assessment was reopened on the basis of report of DDI, who believed that transaction of capital gain shown by the assessee was bogus. The Hon'ble Bench while quashing the notice observed that "Whether Assessing Officer reopened assessee's assessment merely because DDIT (Inv) believed that transaction of capital gains shown

M/S CHARAN SINGH ICE & STORAGE P LTD,HATHRAS vs. ITO 3(5), HATHRAS

In the result, both the appeals are allowed

Bench: Shri A. D. Jain

section 148 as well as consequent assessment where assessment was reopened on the basis of report of DDI, who believed that transaction of capital gain shown by the assessee was bogus. The Hon'ble Bench while quashing the notice observed that "Whether Assessing Officer reopened assessee's assessment merely because DDIT (Inv) believed that transaction of capital gains shown

ACIT,CC, AGRA, AGRA vs. M/S FEDERAL AGRO INDUSTRIES PVT. LTD.,, NEW DELHI

In the result, appeal filed by the revenue is dismissed

purchases of\n'Raw Boneless Meat' amounting to Rs. 2,50,58,565/- has been deleted by the\nCIT(A).\n4. The facts in brief are that the Assessing Officer has made the addition in\nreassessment completed u/s 147 read with section 143(3) in respect of\npurchases of 'Raw Boneless Meat', which has been treated as bogus

SAPNA CHAUHAN,ETAWAH vs. ITO, ETAWAH

In the result,both the appeals in ITA No

Bench: Shri Sudhanshu Srivastava & Dr. Mitha Lal Meena

purchase of property. In view of the above facts, I have reasons to believe that the income chargeable to tax has escaped assessment. Issue notice under section 148 of the Income Tax Act, 1961.” 21. The Hon’ble ITAT quashed Notice under section 148 by observing that: “From the reading of the reasons, it is quite evident that

ACIT-CC, AGRA, AGRA vs. M/S FEDERAL AGRO INDUSTRIES PVT. LTD., NEW DELHI

In the result, appeal filed by the revenue is dismissed

purchases of\n'Raw Boneless Meat' amounting to Rs. 2,50,58,565/- has been deleted by the\nCIT(A).\n4. The facts in brief are that the Assessing Officer has made the addition in\nreassessment completed u/s 147 read with section 143(3) in respect of\npurchases of 'Raw Boneless Meat', which has been treated as bogus

ACIT, CC, AGRA, AGRA vs. M/S FEDERAL AGRO INDUSTRIES PVT. LTD.,, NEW DELHI

In the result, appeal filed by the revenue is dismissed

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singh

147 read with section 143(3) in respect of purchases of ‘Raw Boneless Meat’, which has been treated as bogus

SAGAR DWELLINGS P LTD,NEAR SUN TEMPLE GWALIOR vs. ACIT, FACELESS

In the result, assessee’s appeal is dismissed

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

purchases to be bogus and added Rs.1,03,89,106/- to the total income of the assessee, vide reassessment order dated 21.03.2022 passed u/s. 147 r.w.s. 144B of the Act. 3. Aggrieved, assessee preferred first appeal before the Ld. CIT(Appeals), who dismissed assessee’s appeal and confirmed the impugned addition. 4 | P a g e 4. Present second appeal

TEJ SINGH,MATHURA vs. ITO 1(3)(4), MATHURA

In the result, the Appeal of the assessee is partly allowed

purchased shares and subsequently sold these shares at a much higher value. For the assessment year 1997- 98, the assessees disclosed long-term capital gains arising from the transaction. On the basis of the information received by the Deputy Director (Investigation), the Assessing Officer issued notice under section 148. The files were then put up before the Commissioner

SARIF,JALESAR ETAH vs. ASSESSING OFFICER, WARD-4(3)(1) , ETAH

In the result, both the appeals ITA Nos

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

bogus purchases, vide assessment order dated 22.05.2023 passed u/s. 147 r.w.s. 144B of the Act. 4. Aggrieved, assessee preferred first appeal before learned CIT(Appeals), who dismissed the same upon rejection of assessee’s prayer for condonation of delay. 5. This second appeal has been preferred mainly on the ground that the ld. CIT(Appeals) has erred in rejecting assessee

SARIF,JALESAR, ETAH vs. ASSESSIN OFFICER, WARD-4(3)(1), DINESH NAGAR ETAH

In the result, both the appeals ITA Nos

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

bogus purchases, vide assessment order dated 22.05.2023 passed u/s. 147 r.w.s. 144B of the Act. 4. Aggrieved, assessee preferred first appeal before learned CIT(Appeals), who dismissed the same upon rejection of assessee’s prayer for condonation of delay. 5. This second appeal has been preferred mainly on the ground that the ld. CIT(Appeals) has erred in rejecting assessee

MANOJ KUMAR JAIN,AGRA vs. ITO-1(2), AGRA

In the result, the appeal is allowed

Bench: : Shri A.D. Jainassessment Year: 2002-03

section 147/148 of the Income Tax Act, 1961, despite the fact that there existed "No material" on his record (at the time of recording reasons) for his reason to believe that the income of the "appellant" has escaped assessment. 2. BECAUSE the learned CIT(A) has failed to appreciate that the reassessment proceedings as initiated are wholly unsustainable

ANJU AGARWAL,AGRA vs. INCOME TAX OFFICER, WARD 2(1)(1), AGRA

In the result, the appeal of the Assessee is allowed

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh (Through Virtual Hearing) Anju Agarwal, Vs. Income Tax Officer, D-26, Kamla Nagar, Ward-2(1)(1), Agra Agra (Appellant) (Respondent) Pan: Awtpa4297L Assessee By : Shri K. K. Jain, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 16/09/2025 Date Of Pronouncement 04/12/2025

Section 147 r.w.s. 144B of the Act on 23-3- 2024 determining total income of the Assessee at Rs. 56,35,106/- after making an addition of Rs. 49,98,136/-, which stood upheld by the Learned NFAC. Anju Agarwal 4. At the outset, we find that the identical issue had been adjudicated by this Tribunal in Assessee