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

200/-. Assessee stated to be the proprietor of M/s. Bharat Veg. Oils Trade Co. It was also stressed that the assessee operated account No. 9028201000000170 in Bank of India in the name of M/s. G.S. Trading Co., proprietor of which was stated to be the assessee. Aforesaid account and its receipts were not mentioned by the assessee in his return

TAHIR KHAN,JHANSI vs. INCOME TAX OFFICER-2(3)(1), JHANSI

In the result, assessee’s appeal is allowed

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2014-15

disallowances cannot invite penalty under section 271(1)(c) of the 'Act' as per settled judicial position. 4 | P a g e 10. BECAUSE, the learned CIT(A) erred in confirming levy of penalty at 200

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)

200. It is pertinent to note that Explanation-2 of section 263(1) would help the ld. Commissioner to take cognizance under section 263 of the Act, if no inquiry was conducted by the AO before finalizing the assessment order. No doubt the assessment orders are very brief, and did not have elaborate discussion on these issues

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)

200. It is pertinent to note that Explanation-2 of section 263(1) would help the ld. Commissioner to take cognizance under section 263 of the Act, if no inquiry was conducted by the AO before finalizing the assessment order. No doubt the assessment orders are very brief, and did not have elaborate discussion on these issues

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)

200. It is pertinent to note that Explanation-2 of section 263(1) would help the ld. Commissioner to take cognizance under section 263 of the Act, if no inquiry was conducted by the AO before finalizing the assessment order. No doubt the assessment orders are very brief, and did not have elaborate discussion on these issues

MR. TASAVVER HUSAIN,FARRUKHABAD vs. ACIT , FARRUKHABAD

In the result, appeal filed by the assessee is allowed

Bench: :Smt. Annapurna Gupta & Shri Sunil Kumar Singh

200% of the tax payable on such income.While subsection (1) to (7) of section 270A deal with underreporting of income, sub section (8) & (9) deal with underreporting as a consequence of misreporting.This is evident from a bare perusal of the provisions of section 270A of the Act, reproduced hereunder: “270A. (1) The Assessing Officer or 95[the Joint Commissioner (Appeals

MR. TASAVVER HUSAIN,FARRUKHABAD vs. ACIT, FARRUKHABAD

In the result, appeal filed by the assessee is allowed

Bench: :Smt. Annapurna Gupta & Shri Sunil Kumar Singh

200% of the tax payable on such income.While subsection (1) to (7) of section 270A deal with underreporting of income, sub section (8) & (9) deal with underreporting as a consequence of misreporting.This is evident from a bare perusal of the provisions of section 270A of the Act, reproduced hereunder: “270A. (1) The Assessing Officer or 95[the Joint Commissioner (Appeals

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

200. It is\npertinent to note that Explanation-2 of section 263(1)\nwould help the ld. Commissioner to take cognizance\nunder section 263 of the Act, if no inquiry was conducted\nby the AO before finalizing the assessment order. No\ndoubt the assessment orders are very brief, and did not\nhave elaborate discussion on these issues

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

200. It is\npertinent to note that Explanation-2 of section 263(1)\nwould help the ld. Commissioner to take cognizance\nunder section 263 of the Act, if no inquiry was conducted\nby the AO before finalizing the assessment order. No\ndoubt the assessment orders are very brief, and did not\nhave elaborate discussion on these issues

BLUE LOTUS DEVELOPERS,GWALIOR vs. DCIT 1(1) GWALIOR, GWALIOR

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

Bench: Shri M. Balaganeshblue Lotus Developers, Vs. Dcit, 101, The Empire 33 City Circle-1(1), Centre, Thalipur, Gwalior Gwalior (Appellant) (Respondent) Pan: Aaifb4692D Assessee By : Shri Rajendra Sharma, Adv Shri Manuj Sharma, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026

200/-. It is not in dispute before us that the satisfaction note for initiating proceedings under Section 153C of the Act stood initiated on the Assessee during the assessment year 2012-13. Hence the date of search qua the Assessee falls in assessment year 2012-13 for which only assessment under section 143(3) of the Act should be framed

DINESH CHAND KAUSHIK,ALIGARH vs. ITO, DELHI

In the result, assessee’s appeal is allowed for statistical purposes

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2021-22

disallowance of various expenses claimed by assessee. The Assessing Officer imposed penalty of Rs.3,63,46,544/- @ 200% of the amount of tax payable on the aforesaid two additions, vide penalty order dated 26.06.2023. 3. Aggrieved, assessee preferred first appeal before learned CIT(A), who confirmed the penalty and dismissed assessee’s first appeal. 4. This second appeal has been

GRAM VIKAS KALYAN SANSTHAN,MATHURA vs. I.T.O. (TDS), AGRA

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

Bench: Shri S.Rifaur Rahman & Shri Sunil Kumar Singhgram Vikas Kalyan Sansthan, Vs. Income Tax Officer (Tds), Nagla Aklha, Sonkh – Goverdhan Road, Agra. Mathura – 281 123 (Uttar Pradesh). (Pan : Aaatg3272E) (Appellant) (Respondent) Assessee By : Shri Rajan Gupta, Ca Revenue By : Shri Shalenndra Shrivastava, Sr. Dr Date Of Hearing : 13.10.2025 Date Of Order : 28.10.2025

section 201/201(1A) of the Act. In case, the payee declares the abovesaid income in their return of income and pays the due tax, the liability of the assessee is discharged and before making the disallowance, the Assessing Officer has to determine whether the assessee is in default or not u/s 201/201(1A). In 7 case, it is found that

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

200/- on account of alleged bogus\npurchases u/s 37(1), is bad in law and against the facts and circumstances of the case.\n7.\nThat having regards to the facts and circumstances of the case, Ld. CIT(A) has erred\nin law and on facts in not deleting the addition of Rs.99,56,944/- fully as made

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

200/- on account of alleged bogus\npurchases u/s 37(1), is bad in law and against the facts and circumstances of the case.\n7.\nThat having regards to the facts and circumstances of the case, Ld. CIT(A) has erred\nin law and on facts in not deleting the addition of Rs.99,56,944/- fully as made

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

The appeal of the assessee stands partly allowed

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.113/Agr/2023 (िनधा"रणवष" / Assessment Year: 2013-14) & 2. आयकरअपीलसं./ Ita No.114/Agr/2023 (िनधा"रणवष" / Assessment Year: 2014-15) & 3. आयकरअपीलसं./ Ita No.115/Agr/2023 (िनधा"रणवष" / Assessment Year: 2015-16) & 4. आयकरअपीलसं./ Ita No.116/Agr/2023 (िनधा"रणवष" / Assessment Year: 2016-17) & 5. आयकरअपीलसं./ Ita No.117/Agr/2023 (िनधा"रणवष" / Assessment Year: 2017-18) & 6. आयकरअपीलसं./ Ita No.118/Agr/2023 (िनधा"रणवष" / Assessment Year: 2018-19) & 7. आयकरअपीलसं./ Ita No.119/Agr/2023 (िनधा"रणवष" / Assessment Year: 2019-20) M/S Mahesh Edible Oil Industries Ltd. Acit-Central Circle बनाम/ 3/14-A, Jungpura-B Agra. Vs. New Delhi – 110 014. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccm-7102-J (अपीलाथ"/Appellant) : (""थ" / Respondent) & 8. आयकरअपीलसं./ Ita No.157/Agr/2023 (िनधा"रणवष" / Assessment Year: 2013-14) &

200/- on account of alleged bogus purchases u/s 37(1), is bad in law and against the facts and circumstances of the case. 7. That having regards to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in not deleting the addition of Rs.99,56,944/- fully as made

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

The appeal of the assessee stands partly allowed

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.113/Agr/2023 (िनधा"रणवष" / Assessment Year: 2013-14) & 2. आयकरअपीलसं./ Ita No.114/Agr/2023 (िनधा"रणवष" / Assessment Year: 2014-15) & 3. आयकरअपीलसं./ Ita No.115/Agr/2023 (िनधा"रणवष" / Assessment Year: 2015-16) & 4. आयकरअपीलसं./ Ita No.116/Agr/2023 (िनधा"रणवष" / Assessment Year: 2016-17) & 5. आयकरअपीलसं./ Ita No.117/Agr/2023 (िनधा"रणवष" / Assessment Year: 2017-18) & 6. आयकरअपीलसं./ Ita No.118/Agr/2023 (िनधा"रणवष" / Assessment Year: 2018-19) & 7. आयकरअपीलसं./ Ita No.119/Agr/2023 (िनधा"रणवष" / Assessment Year: 2019-20) M/S Mahesh Edible Oil Industries Ltd. Acit-Central Circle बनाम/ 3/14-A, Jungpura-B Agra. Vs. New Delhi – 110 014. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccm-7102-J (अपीलाथ"/Appellant) : (""थ" / Respondent) & 8. आयकरअपीलसं./ Ita No.157/Agr/2023 (िनधा"रणवष" / Assessment Year: 2013-14) &

200/- on account of alleged bogus purchases u/s 37(1), is bad in law and against the facts and circumstances of the case. 7. That having regards to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in not deleting the addition of Rs.99,56,944/- fully as made

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

The appeal of the assessee stands partly allowed

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.113/Agr/2023 (िनधा"रणवष" / Assessment Year: 2013-14) & 2. आयकरअपीलसं./ Ita No.114/Agr/2023 (िनधा"रणवष" / Assessment Year: 2014-15) & 3. आयकरअपीलसं./ Ita No.115/Agr/2023 (िनधा"रणवष" / Assessment Year: 2015-16) & 4. आयकरअपीलसं./ Ita No.116/Agr/2023 (िनधा"रणवष" / Assessment Year: 2016-17) & 5. आयकरअपीलसं./ Ita No.117/Agr/2023 (िनधा"रणवष" / Assessment Year: 2017-18) & 6. आयकरअपीलसं./ Ita No.118/Agr/2023 (िनधा"रणवष" / Assessment Year: 2018-19) & 7. आयकरअपीलसं./ Ita No.119/Agr/2023 (िनधा"रणवष" / Assessment Year: 2019-20) M/S Mahesh Edible Oil Industries Ltd. Acit-Central Circle बनाम/ 3/14-A, Jungpura-B Agra. Vs. New Delhi – 110 014. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccm-7102-J (अपीलाथ"/Appellant) : (""थ" / Respondent) & 8. आयकरअपीलसं./ Ita No.157/Agr/2023 (िनधा"रणवष" / Assessment Year: 2013-14) &

200/- on account of alleged bogus purchases u/s 37(1), is bad in law and against the facts and circumstances of the case. 7. That having regards to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in not deleting the addition of Rs.99,56,944/- fully as made

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

The appeal of the assessee stands partly allowed

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.113/Agr/2023 (िनधा"रणवष" / Assessment Year: 2013-14) & 2. आयकरअपीलसं./ Ita No.114/Agr/2023 (िनधा"रणवष" / Assessment Year: 2014-15) & 3. आयकरअपीलसं./ Ita No.115/Agr/2023 (िनधा"रणवष" / Assessment Year: 2015-16) & 4. आयकरअपीलसं./ Ita No.116/Agr/2023 (िनधा"रणवष" / Assessment Year: 2016-17) & 5. आयकरअपीलसं./ Ita No.117/Agr/2023 (िनधा"रणवष" / Assessment Year: 2017-18) & 6. आयकरअपीलसं./ Ita No.118/Agr/2023 (िनधा"रणवष" / Assessment Year: 2018-19) & 7. आयकरअपीलसं./ Ita No.119/Agr/2023 (िनधा"रणवष" / Assessment Year: 2019-20) M/S Mahesh Edible Oil Industries Ltd. Acit-Central Circle बनाम/ 3/14-A, Jungpura-B Agra. Vs. New Delhi – 110 014. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccm-7102-J (अपीलाथ"/Appellant) : (""थ" / Respondent) & 8. आयकरअपीलसं./ Ita No.157/Agr/2023 (िनधा"रणवष" / Assessment Year: 2013-14) &

200/- on account of alleged bogus purchases u/s 37(1), is bad in law and against the facts and circumstances of the case. 7. That having regards to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in not deleting the addition of Rs.99,56,944/- fully as made