MONIKA RATHORE,GWALIOR vs. INCOME TAX OFFICER WARD -1, MORENA

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

Bench: : Shri Ramit Kochar & Shri Sudhir Kumarassessment Year: 2023-24

disallowed claim, on ground that assessee had not filed Form No. 67 along with return Assessee filed Form No. 67 before Commissioner (Appeals) Commissioner (Appeals) held that since assessee had failed to file Form No. 67 within due date specified for filing return under section 139(1

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

67 (Punjab & Haryana)/[2015] 370 ITR 732\n(Punjab & Haryana)[21-07-2014]\nSection 69C, read with section 263, of the Income-tax Act, 1961\n- Unexplained expenditure (Statements made before other\nauthorities, relevance of) - Assessment year 2005-06 - Assessee-\ncompany was engaged in business of manufacturing of non-\nalloys steel ingots, trading in scrap, etc. Subsequent to\nassessment, Commissioner

TOMAR AND BROTHERS,ETAWAH vs. INCOME TAX OFFICER, WARD-2(2)(5), ETAWAH

Appeal of the assessee is partly allowed

Bench: :Smt. Annapurna Gupta & Shri Sunil Kumar Singhassessment Year: 2014-15

67,680/-. Learned CIT(Appeals), however, restricted the same to 7.5% of the expenses resulting in disallowance being restricted to Rs.21,12,576/-. 2 | P a g e 4. The assessee is aggrieved by the same and his contention is that if this quantum of disallowance sustained by the ld. CIT(Appeals) is considered, it would result in its profit

ASSISTANT COMMISSIONER OF INCOME TAX, AGRA vs. CHITAVALSAH JUTE MILLS LIMITED, NEW DELHI

In the result the appeal of the revenue is dismissed

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh(Through Virtual Hearing) Acit, Vs. Chitavalasah Jute Mills Ltd, Range-1, 73-74, 201, Sheetala House, Faridabad Nehru Place, New Delhi (Appellant) (Respondent) Pan: Aaccc6834D Assessee By : None Revenue By: Shri Sukesh Kumar Jain, Cit Dr Date Of Hearing 15/09/2025 Date Of Pronouncement 04/12/2025

67,84,622/- d. Disallowance of other expenses:- 12,76,916/- 5. The ld CIT(A) granted partial relief to the assessee in the first round. The assessee preferred appeal before this Tribunal. The Tribunal in the first round restored the matter back to the file of the ld CIT(A). In the second round of proceedings, the assessee furnished

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

disallowable expenditure u/s 40A(3) read with Rule 6DD of the 1.T. Act in mechanical, summary & brief manner without appreciating & brushing aside the Nature of transaction in the peculiar facts & circumstances, and the evidence furnished. The addition made on merely assumptions, presumptions, surmises & unwarranted arbitrary, highly unjust, conjectures and grossly capricious, wrong, illegal, bad in facts & law. 5.2 Because

DEPUTY COMMISSIONER OF INCOME TAX, AGRA vs. ADITYA PANDEY, AGRA

In the result, both the appeals ITA No

Bench: : Shri M. Balaganesh & Shri Sunil Kumar Singh

67,207/- imposed by Assessing Officer, vide penalty order dated 19.09.2024 passed u/s. 271AAC(1) of the Act respectively. 2. Since, the penalty order passed u/s. 271AAC(1) of the Act is consequential to the assessment order, both these appeals are being disposed of by the consolidated order for the sake of convenience and brevity. The facts

DEPUTY COMMISSIONER OF INCOME TAX, AGRA vs. ADITY PANDEY, AGRA

In the result, both the appeals ITA No

Bench: : Shri M. Balaganesh & Shri Sunil Kumar Singh

67,207/- imposed by Assessing Officer, vide penalty order dated 19.09.2024 passed u/s. 271AAC(1) of the Act respectively. 2. Since, the penalty order passed u/s. 271AAC(1) of the Act is consequential to the assessment order, both these appeals are being disposed of by the consolidated order for the sake of convenience and brevity. The facts

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

67,01,2151- made u/s 37(1)of the LT. Act,\n1961, without appreciating the fact that addition on account of 10% of total purchases held\nto be bogus, was firmly based on incriminating material found during the course of search\nproceeding as well as independent investigation made by the department and credible\ninputs from external agencies.\n2.\nThe

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

67,01,2151- made u/s 37(1)of the LT. Act,\n1961, without appreciating the fact that addition on account of 10% of total purchases held\nto be bogus, was firmly based on incriminating material found during the course of search\nproceeding as well as independent investigation made by the department and credible\ninputs from external agencies.\n2.\nThe

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)

67 (Punjab & Haryana)/[2015] 370 ITR 732 (Punjab &Haryana)[21-07-2014] Section 69C, read with section 263, of the Income-tax Act, 1961 - Unexplained expenditure (Statements made before other authorities, relevance of) - Assessment year 2005-06 - Assessee- company was engaged in business of manufacturing of non- alloys steel ingots, trading in scrap, etc. - Subsequent to assessment, Commissioner invoked jurisdiction

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)

67 (Punjab & Haryana)/[2015] 370 ITR 732 (Punjab &Haryana)[21-07-2014] Section 69C, read with section 263, of the Income-tax Act, 1961 - Unexplained expenditure (Statements made before other authorities, relevance of) - Assessment year 2005-06 - Assessee- company was engaged in business of manufacturing of non- alloys steel ingots, trading in scrap, etc. - Subsequent to assessment, Commissioner invoked jurisdiction

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)

67 (Punjab & Haryana)/[2015] 370 ITR 732 (Punjab &Haryana)[21-07-2014] Section 69C, read with section 263, of the Income-tax Act, 1961 - Unexplained expenditure (Statements made before other authorities, relevance of) - Assessment year 2005-06 - Assessee- company was engaged in business of manufacturing of non- alloys steel ingots, trading in scrap, etc. - Subsequent to assessment, Commissioner invoked jurisdiction

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

67 (Punjab & Haryana)/[2015] 370 ITR 732\n(Punjab & Haryana)[21-07-2014]\nSection 69C, read with section 263, of the Income-tax Act, 1961\n- Unexplained expenditure (Statements made before other\nauthorities, relevance of) - Assessment year 2005-06 - Assessee-\ncompany was engaged in business of manufacturing of non-\nalloys steel ingots, trading in scrap, etc. Subsequent to\nassessment, Commissioner

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

In the result, the appeal preferred by the assessee is partly

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2013-14

67 Month wise Consumption of Raw Milk & Other Ingredients 68 Month wise Production of Dairy Products 69 Month wise detail of Sales of various products 452 – 456 Copy of Annual VAT Return filed for the Financial Year 2012-13 457 – 463 Month wise detail of Sales to various parties 464 – 466 List of Trade Receivables in excess of Rs. 1

SUBODH GUPTA,AGRA vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT, AGRA

In the result, the appeal filed by the assessee is allowed for statistical purpose

Bench: : Shri S. Rifaur Rahmanassessment Year: 2022-23 Subodh Gupta Vs. Ito, 71, Saket Colony Shahganj Agra Ward 1(1)(2), Agra Agra Pan : Adqfs4617N (Appellant) (Respondent) Assessee By Shri Prarthna Jalaan, Ca Department By Shri Anil Kumar, Sr. Dr Date Of Hearing 17.02.2026 Date Of Pronouncement 17.02.2026 Order

1. That the Commissioner of Income-tax (Appeals), Income Tax Department has erred in law and on facts in sustaining the addition of Rs. 4,20,000/-by disallowing the remuneration pad to partners and another addition of Rs.9,67,806/-by charging notional interest on loans advanced. 2. That the learned authorities below have erred in law as well

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) &

67,01,2151- made u/s 37(1)of the LT. Act, 1961 , without appreciating the fact that addition on account of 10% of total purchases held to be bogus, was firmly based on incriminating material found during the course of search proceeding as well as independent investigation made by the department and credible inputs from external agencies

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) &

67,01,2151- made u/s 37(1)of the LT. Act, 1961 , without appreciating the fact that addition on account of 10% of total purchases held to be bogus, was firmly based on incriminating material found during the course of search proceeding as well as independent investigation made by the department and credible inputs from external agencies

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) &

67,01,2151- made u/s 37(1)of the LT. Act, 1961 , without appreciating the fact that addition on account of 10% of total purchases held to be bogus, was firmly based on incriminating material found during the course of search proceeding as well as independent investigation made by the department and credible inputs from external agencies