HARDAYAL MILK PRODUCTS PRIVATE LIMITED,SHIKOHABAD vs. DCIT, CIRCLE-2(2)(1), FIROZABAD, FIROZABAD

In the result, both the appeals filed by assessee are allowed

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

disallowance of depreciation claimed on fixed assets. In first appeal preferred against the above said assessment order dated 31.03.2016, learned CIT(A) vide order dated 25.06.2025 affirmed the rejection of accounts and sustained the addition made by AO on account of low profit rate. Aggrieved, assessee preferred an appeal in ITA No.342/Agr/2025 before the ITAT, which has been partly allowed

HARDAYAL MILK PRODUCTS PRIVATE LIMITED,SHIKOHABAD vs. DCIT, CIRCLE-2(2)(1), FIROZABAD, FIROZABAD

In the result, both the appeals filed by assessee are allowed

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

disallowance of depreciation claimed on fixed assets. In first appeal preferred against the above said assessment order dated 31.03.2016, learned CIT(A) vide order dated 25.06.2025 affirmed the rejection of accounts and sustained the addition made by AO on account of low profit rate. Aggrieved, assessee preferred an appeal in ITA No.342/Agr/2025 before the ITAT, which has been partly allowed

ACIT CIRCLE-2, GWALIOR vs. SHARMA & ASSOCIATES FIRETECH PVT LTD, GWALIOR

In the result, we do not find any error as the assessee has failed to establish the

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meenaassessment Year: 2010-11

disallowance made by the assessing officer for than amount of Rs.131,91,325/-. 17. Further from the perusal of the order of the assessing officer it is amply clear that the notices issued under section 133(6

SMT. BINA WADHWA,AGRA vs. ITO WARD 1(1)(1), AGRA

In the result, the appeal is allowed for statistical purposes

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meenaassessment Year: 2010-11

133(6), evident from the Assessing Order, and no approval has been taken for issue of notice under section 148 of the Income Tax Act, hence reopening of case without valid approval of Joint Commissioner is bad in law. 2- Because as per sub section (2) of section 151 no notice shall be issued under section 148 by Assessing officer

HARI OM AGARWAL,KOLARAS vs. ITO SHIVPURI, ASHOK NAGAR

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

Bench: : Shri Ramit Kocharassessment Year: 2017-18

6) of Section 250 of the Income Tax Act. 8. That the AO has erred on facts and in law while making the addition by disallowing of the expenses(by estimate) out of the expenses claimed under the Head ‘general administration and selling expenses’ , claimed as per provisions of Section 37 of the Income Tax Act, no disallowance is called

ACIT CIRCLE-4, AGRA vs. JHANSI DEVELOPMENT AUTHORITY, JHANSI

In the result the appeal of the assessee is allowed and the appeal

Bench: Shri Laliet Kumar,And Dr. Mitha Lal Meenajhansi Development Authority Vs..Dcit Circle-4, Commissionerycompus, Agra. Jhansi. (Now The Dy. Cit Panno.Aaalj0068K (Exemption) Ghaziabad. (Assessee) (Revenue) Acit, 4(1), Vs..Jhansi Development Agra. Authority (Now The Dy. Cit Commissionerycompus, Jhansi. (Exemption) Ghaziabad. Panno.Aaalj0068K (Revenue) (Assessee)

disallowance is again in utter disregard to the authoritative judicial pronouncements. The exemption u/s 11 of the I.T. Act, being in accordance with report in 10B, may kindly be directed to be granted. 6. Because the Ld. CIT(A) erred, both in law and on facts, in sustaining the addition of Rs 6,31,13,830/- being the receipts shown

JHASI DEVELOPMENT AUTHORITY,JHANSI vs. DY. C.I.T., CIRCLE-4, AGRA

In the result the appeal of the assessee is allowed and the appeal

Bench: Shri Laliet Kumar,And Dr. Mitha Lal Meenajhansi Development Authority Vs..Dcit Circle-4, Commissionerycompus, Agra. Jhansi. (Now The Dy. Cit Panno.Aaalj0068K (Exemption) Ghaziabad. (Assessee) (Revenue) Acit, 4(1), Vs..Jhansi Development Agra. Authority (Now The Dy. Cit Commissionerycompus, Jhansi. (Exemption) Ghaziabad. Panno.Aaalj0068K (Revenue) (Assessee)

disallowance is again in utter disregard to the authoritative judicial pronouncements. The exemption u/s 11 of the I.T. Act, being in accordance with report in 10B, may kindly be directed to be granted. 6. Because the Ld. CIT(A) erred, both in law and on facts, in sustaining the addition of Rs 6,31,13,830/- being the receipts shown

JHANSI DEVELOPMENT AUTHORITY,JHANSI vs. ACIT CIRCLE-4, AGRA

In the result the appeal of the assessee is allowed and the appeal

Bench: Shri Laliet Kumar,And Dr. Mitha Lal Meenajhansi Development Authority Vs..Dcit Circle-4, Commissionerycompus, Agra. Jhansi. (Now The Dy. Cit Panno.Aaalj0068K (Exemption) Ghaziabad. (Assessee) (Revenue) Acit, 4(1), Vs..Jhansi Development Agra. Authority (Now The Dy. Cit Commissionerycompus, Jhansi. (Exemption) Ghaziabad. Panno.Aaalj0068K (Revenue) (Assessee)

disallowance is again in utter disregard to the authoritative judicial pronouncements. The exemption u/s 11 of the I.T. Act, being in accordance with report in 10B, may kindly be directed to be granted. 6. Because the Ld. CIT(A) erred, both in law and on facts, in sustaining the addition of Rs 6,31,13,830/- being the receipts shown

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)

133(6) to M/s Elahi Trading Co., which reply has been reproduced by 31 ITA No.251/Agr/2025 and 4 ors. the AO at pages 6 to 7 of the assessment order, in which, he has stated he has supplied ‘live buffaloes’ and had not sold any boneless meat to HMA Agro Industries Limited. The assessee had relied upon his reply

HMA AGRO INDUSTRIES LIMITED,AGRA vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE, AGRA, 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)

133(6) to M/s Elahi Trading Co., which reply has been reproduced by 31 ITA No.251/Agr/2025 and 4 ors. the AO at pages 6 to 7 of the assessment order, in which, he has stated he has supplied ‘live buffaloes’ and had not sold any boneless meat to HMA Agro Industries Limited. The assessee had relied upon his reply

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)

133(6) to M/s Elahi Trading Co., which reply has been reproduced by 31 ITA No.251/Agr/2025 and 4 ors. the AO at pages 6 to 7 of the assessment order, in which, he has stated he has supplied ‘live buffaloes’ and had not sold any boneless meat to HMA Agro Industries Limited. The assessee had relied upon his reply

SH. YUGAL KISHOR AGARWAL,AGRA vs. DCIT, CIRCLE 4(3)(1), ETAH

In the result, appeal filed by the assessee is allowed

Bench: : Shri Ramit Kocharassessment Year: 2012-13

133(6)(PB /Page 3) seeking information/evidences about the sources of transactions towards purchase of shares to the tune of Rs. 1,37,45,896/- alongwith bank statement and copy of ITR along with all annexures viz. P&L Account, Balance Sheet , Audit Report etc. It was submitted that the assessee duly explained before the AO vide reply dated

VIMAL KUMAR,MAINPURI vs. INCOEM TAX OFFICER, WARD-4(2)(4), MAINPURI

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

Bench: Shri M. Balaganeshvimal Kumar, Vs. Income Tax Officer, Ramnagar, Halpur, Ward-4(2)(2), Agra, Up Agra (Appellant) (Respondent) Pan: Assessee By : Shri Harsh Agarwal, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 17/03/2026 Date Of Pronouncement 17/03/2026

section 133(6) of the Act by the Learned AO. From the replies furnished by the farmers, the Learned AO tabulated as under:- Sl No. Name of Farmers in the Gross value of Gross payments Difference in amounts list provided by the purchased and made through actually paid to the assessee as well as same amount paid to the bearers

MANISH MAHESHWARI,GWALIOR vs. JCIT RANGE-2, GWALIOR

In the result, appeal of the assessee is partly allowed

Bench: Him Though Specific Request Was Made To Admit The Same. Ground No. 2 (I) Because The Ld. Cit(A) Has Wrongly, Illegally & Arbitrarily Confirmed Theaddition Of Rs. 67,530/- Made By The Assessing Officer U/S 40A(3) Of The Income Tax Act. (Ii) Because The Ld. Cit(A) Has Legally Erred In Rejecting The Appellant'Sspecificsubmissionand The Unavoidable Circumstances Under Which The Payment Wasmade. Ground No. 3 (I) Because The Ld. Cit(A) Has Wrongly, Illegally & Arbitrarily Confirmed An Addition Of Rs. 1,11,038/- Made By The Assessing Officer By Disallowing The Claim Of Interest Paid Holding The Same To Be Not Allowable U/S 57(Iii) Of The Income Tax Act.”

133 (6) of the Act was issued to Shri Kaushal Kishore Shrivastava vide this office letter F.No. JCIT/GWL/Range-2/2012-13/869 dated 15.02,2013 tor 22.02.2013, asking him to furnish the confirmed copy of account of the assessee in its books of account alongwith a copy of his return of income as well as the bank statement of his bank account through which

SUMIT KUMAR,AGRA vs. ITO 1(1)(2), AGRA

In the result, the appeal of the Assessee is allowed

Bench: Shri M. Balaganesh(Through Virtual Hearing) Sumit Kumar, Vs. Ito, Village Rampura, Ward-1(1)(2), Gwalior Road, Agra Agra (Appellant) (Respondent) Pan: Buqpk7461L Assessee By : Shri Gaurav Agarwal, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 20/11/2025 Date Of Pronouncement 26/11/2025

section 133(6) of the Act. The Assessee had also submitted that those parties were not having taxable Sumit Kumar income and hence had not filed their income tax returns. Despite all these explanations and documentary evidences, the Learned AO proceeded to disallow

SATISH PRAKASH AGARWAL,AGRA vs. THE ACIT, CIRCLE 1(2)(1), AGRA, AGRA

In the result, appeal of the assessee is allowed

Bench: : Shri Ramit Kocharassessment Year: 2016-17

133(6) to 11 lenders out of which only 5 lenders responded to the enquiries made by the AO. The AO based on the analysis of the enquiry observed that the creditworthiness of the lender and genuineness of the interest could not be proved. The observations of the AO are recorded in the assessment order. The assessee even

ANUPAM MITTAL,AGRA vs. ITO WARD 2(1)(1), AGRA, AGRA

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

Bench: Shri Sunil Kumar Singh & Shri Brajesh Kumar Singh[Assessment Year: 2018-19]

section 68 of the I.T. Act, 1961 is hereby confirmed and the ground no. 1,2 and 6 are decided in negative and against the appellant.” 4.1. Similarly, the ld. CIT(A) also confirmed the disallowance of interest of Rs.2,40,000/- on the loan of Rs.71,08,000/- by observing in para no.5.1 and 5.2 as under

D.C.I.T., CIRCLE-2, GWALIOR vs. M/S PREM MOTORS PVT LTD., GWALIOR

The appeals of the department are dismissed

133 ITD 1 and decision of various courts as under, have been cited by the appellant - CIT VsAnkitechPvt Ltd and others 340 ITR 14 (Del) CIT Vs AR Magnetics (P) Ltd (2014) 220 Taxman 209 (Del. HC) CIT Vs Daisy Packers (P) Ltd. (2014) 220 Taxman 331 (Guj. HC) CIT VsSuram Holdings (P) Ltd. (2014) 220 Taxman