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, 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

section 263 of the Act. He remitted the order back to the AO\nto pass fresh order after conducting proper enquiries.\n9.\nOn careful consideration of material facts on record, we observed that Ld\nPCIT had completely ignored the other facts on record that in the case of\nIrfan, in subsequent appeal before CIT(A), the addition was deleted. Further

SH SANJAY BANSAL ,MORENA vs. A.C.I.T (CENTRAL), GWALIOR

In the result, assessee's appeal is dismissed

Bench: learned CIT(Appeals) who has very exhaustively passed the impugned order in 60 pages and considered all the submissions of the assessee in the tabulated form and otherwise, which need not to be repeated again for the sake of brevity. However, learned CIT(Appeals) partly allowed assessee's appeal confirming the addition only to the extent of Rs.71,44,045/- as against addition of Rs.91,06,669/-. 4. Assessee is in appeal before the Tribunal on the following grounds : "1.Because in any view, th

disallowed as per the provisions of section 40A(3) rw.r. 6DD of the Income-tax Rules, 1962. The appellant Submitted that following purchases have been made in cash from the Cultivators of agricultural products and therefore, these payments are allowable as per the provisions of section 40A(3A) r.w.r. 6DD(e) 7| Page produce was purchased grower producer is placed

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

section 44AD of the Income Tax Act, 1961.\n3.\nThe Ld. CIT(A)-V, Kanpur has erred in law and on facts in directing the AO to verify\nthe investment of Rs. 89,79,185/- out of total addition of Rs.99,56,944/- made u/s 69B of the\nAct on account of unexplained investment in factory building at Kota

ACIT, CIRCLE-2(1)(1),AGRA, AGRA vs. EMCO EXPORTS, AGRA

In the result, revenue’s appeal stands dismissed

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2020-21

3) are safeguards. The said provisions are of practical importance. This reasoning of ours is based on the decision of this Court in Transmission Corporation(supra) in which this Court has observed that the provision of Section 195(2) is a safeguard. From this it follows that where a person responsible for deduction is fairly certain then he can make

VECTUS INDUSTRIES LTD.,GWALIOR vs. DCIT/ACIT 1(1), GWALIOR

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh(Through Virtual Hearing)

3 days. The bonafide intention of the assessee to settle the disputes by paying due taxes thereon cannot be doubted in the instant case. Substantive provision of not preferring any further appeal and by paying due taxes had been complied with by the Assessee Company. The filing of Form No. 68 within the due date is only to intimate

VECTUS INDUSTRIES LTD.,,GWALIOR vs. DCIT/ACIT 1(1) , GWALIOR

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh(Through Virtual Hearing)

3 days. The bonafide intention of the assessee to settle the disputes by paying due taxes thereon cannot be doubted in the instant case. Substantive provision of not preferring any further appeal and by paying due taxes had been complied with by the Assessee Company. The filing of Form No. 68 within the due date is only to intimate

VECTUS INDUSTRIES LTD.,,GWALIOR vs. DCIT/ACIT 1(1), GWALIOR

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh(Through Virtual Hearing)

3 days. The bonafide intention of the assessee to settle the disputes by paying due taxes thereon cannot be doubted in the instant case. Substantive provision of not preferring any further appeal and by paying due taxes had been complied with by the Assessee Company. The filing of Form No. 68 within the due date is only to intimate

GIRDHARI LAL KEDAR NATH SINGHAL,AGRA vs. THE INCOME TAX OFFICER 1(1)(1), AGRA

In the result, the appeal filed by the assessee is allowed

Bench: Shri S.Rifaur Rahmangirdhari Lal Kedar Nath Singhal, Vs. Ito 1 (1)(1), Ff – 1, Bhagwati Complex, Agra. M.G. Road, Opp. Shah Cinema, Agra – 282 002 (Uttar Pradesh). (Pan : Aacfg5458N) (Appellant) (Respondent) Assessee By : Shri Naveen Garg, Advocate Revenue By : Shri Anil Kumar, Sr. Dr Date Of Hearing : 21.08.2025 Date Of Order : 03.09.2025

section 40A(3) of the Act as the payments exceeding Rs.10,000/- in a day had been made to these persons. Accordingly, the Ground No. 1.1 and 1.2 are dismissed.” 4. Aggrieved assessee preferred an appeal before ITAT raising various argumentative grounds of appeal, which is not as per the ITAT Rules. However, single grievance of the assessee is disallowance

HYDRISE FOODS PRIVATE LIMITED,NOIDA, UTTAR PRADESH, INDIA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, AGRA, AGRA, UTTAR PRADESH, INDIA

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

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh(Through Virtual Hearing)

17. Further, Hon'ble Delhi High Court in the case of PCIT Vs. Shiv Kumar Nayyar – [2024] 163 taxmann.com 9 (Delhi) and PCIT(Central-2) Vs. Anuj Bansal – [2024] 165 taxmann.com 2(Delhi), has considered the identical issue wherein it was emphasized that approval was granted without examining the assessment records or the searched material and, Hon‟ble High Court

HYDRISE FOODS PRIVATE LIMITED,UTTAR PRADESH, INDIA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, AGRA, AGRA, UTTAR PRADESH, INDIA

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

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh(Through Virtual Hearing)

17. Further, Hon'ble Delhi High Court in the case of PCIT Vs. Shiv Kumar Nayyar – [2024] 163 taxmann.com 9 (Delhi) and PCIT(Central-2) Vs. Anuj Bansal – [2024] 165 taxmann.com 2(Delhi), has considered the identical issue wherein it was emphasized that approval was granted without examining the assessment records or the searched material and, Hon‟ble High Court

DY C.I.T.-3, MATHURA vs. M/S KOSHDA BUILDCON PVT. LTD., MATHURA

In the result, this appeal filed by the Revenue stands allowed for

Bench: Shri Shamim Yahya & Shri Anubhav Sharma[Assessment Year: 2014-15]

section 143(3) of the IT Act, 1961 is as per law and addition of Rs.5,17,61,420/-made by applying the Percentage Completion method is justified. 4. That the appellant craves leaves to add or delete or alter or modify any one or more ground (s) of appeal during the appellate proceedings. 5. That the order

GOVIND AGARWAL, GWALIOR,GWALIOR vs. DCIT- CIRCLE 2(1), GWALIOR, GWALIOR

In the result, the appeal of the assessee is allowed

Bench: SHRI SUNIL KUMAR SINGH (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

17. Concludingly, we are of the considered opinion that the Assessing Officer should not have resorted to the provisions contained under Section 143(1)(a) of the Act of 1961 and instead could have resorted to the provisions under Section 143(3) of the Act of 1961, as on the date of issuance of intimation order dated

SHYAMA SHYAM INFRADEVELOPERS PRIVATE LIMITED,AGRA vs. ITO 2(1)(2), AGRA

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganeshshyama Shyam Vs. Ito, Infradevelopers Pvt Ltd, Ward-2(1)(2), Khasra No. 961, Bhahistabad, Agra Sikandra, Agra (Appellant) (Respondent) Pan: Aatcs9899R Assessee By : Shri Gaurav Agarwal, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 21/01/2026 O R D E R

17-01-2023 Acknowledgement, Reply to notice, ITR, Computation of Total Income, sale deeds, Audit Report, P&L account, Balance sheet. 2. 22-04-2023 Acknowledgement, Reply to notice, Construction contract Agreement 3 07.05.2023 Acknowledgement, Reply to notice, ITRs, computations of income of the land owners.. 4. 11.05.2023 Acknowledgement, Reply to notice, Audit report for A.Y.s

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

section 263 of the Act. He remitted the order back to the AO\nto pass fresh order after conducting proper enquiries.\n9. On careful consideration of material facts on record, we observed that Ld\nPCIT had completely ignored the other facts on record that in the case of\nIrfan, in subsequent appeal before CIT(A), the addition was deleted. Further

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

section 36(1)(iii) of the Income-Tax Act, 1961 since the unsecured loans were utilized for making investment in the partnership firm from where income in the form of interest and remuneration was earned and offered for tax in the income-tax return. 4. That on the facts and in the circumstances of the case

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)

3) was passed after approval of Addl. CIT, Central Range, Kanpur and under such circumstances, the PCIT cannot exercise his power u/s 263 and reference is being made to the judgments quoted from page 5 onwards and other judgments about the application of mind. M. The assessee is response to the SCN notice u/s 263 filed his reply dated

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)

3) was passed after approval of Addl. CIT, Central Range, Kanpur and under such circumstances, the PCIT cannot exercise his power u/s 263 and reference is being made to the judgments quoted from page 5 onwards and other judgments about the application of mind. M. The assessee is response to the SCN notice u/s 263 filed his reply dated