MR. PRAMOD KUMAR KHANDELWAL,AGRA vs. DY.C.I.T.-1, AGRA

The appeals of the assessee are allowed in the terms indicated

Bench: Shri Laliet Kumar & Dr. Mitha Lal Meena

172 (SC), the Apex Court has held that interest from bank deposits could only be taxed as income under the head "Income from Other Sources" under section 56 of the Income Tax Act. In the context of export profits, it is held in the case of Nanji Topanbhai and Co. vs. ACIT, 243 ITR 192 (Ker)(2000) that interest being

A.C.I.T.-2, AGRA vs. SMT. NEETA SHARMA PROP., AGRA

In the result, appeal of the Revenue is dismissed and the appeal of the assessee is partly allowed

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meenaassessment Year: 2007-08

disallowable interest amount by taking the rate of interest @ 3%, without appreciating the facts that the relatives or family members of the assessee ITA No.299 & 286 /Agr/2013 3 are claiming 15% rate of interest while unrelated parties are charging @8% to 6% . 3. That the Ld. CIT(A)-I, Agra has erred in law and on facts by restricting

SMT. NEETA SHARMA,AGRA vs. A.C.I.T., CIRCLE-2, AGRA

In the result, appeal of the Revenue is dismissed and the appeal of the assessee is partly allowed

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meenaassessment Year: 2007-08

disallowable interest amount by taking the rate of interest @ 3%, without appreciating the facts that the relatives or family members of the assessee ITA No.299 & 286 /Agr/2013 3 are claiming 15% rate of interest while unrelated parties are charging @8% to 6% . 3. That the Ld. CIT(A)-I, Agra has erred in law and on facts by restricting

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)

3) has to be quashed, thus ordered accordingly. The ground raised by the Assessee is accordingly allowed.” 18. On the other hand, learned CIT-DR relied upon the decision of Hon'ble Supreme Court in the case of Spacewood Furnishers (P) Ltd. – [2015] 374 ITR 595 (SC) and Mumbai ITAT decision in the case of Pratibha Pipes and Structural

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)

3) has to be quashed, thus ordered accordingly. The ground raised by the Assessee is accordingly allowed.” 18. On the other hand, learned CIT-DR relied upon the decision of Hon'ble Supreme Court in the case of Spacewood Furnishers (P) Ltd. – [2015] 374 ITR 595 (SC) and Mumbai ITAT decision in the case of Pratibha Pipes and Structural

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

172 (Guj). The ld CIT(A) had laid more emphasis on provisions of Explanation 3 to Section 147 of the Act which permits the ld AO to make addition on issues that are not subject matter of reasons recorded for reopening. In our considered opinion, the said addition could be made only if the addition that was subject matter

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

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)

section 263 of the Act. He remitted the order back to the AO to pass fresh order after conducting proper enquiries. 9. On careful consideration of material facts on record, we observed that Ld PCIT had completely ignored the other facts on record that in the case of Irfan, in subsequent appeal before CIT(A), the addition was deleted. Further

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)

section 263 of the Act. He remitted the order back to the AO to pass fresh order after conducting proper enquiries. 9. On careful consideration of material facts on record, we observed that Ld PCIT had completely ignored the other facts on record that in the case of Irfan, in subsequent appeal before CIT(A), the addition was deleted. Further

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)

section 263 of the Act. He remitted the order back to the AO to pass fresh order after conducting proper enquiries. 9. On careful consideration of material facts on record, we observed that Ld PCIT had completely ignored the other facts on record that in the case of Irfan, in subsequent appeal before CIT(A), the addition was deleted. Further