MS/ BHOLE BABA MILK FOOD INDUSTRIES,AGRA vs. THE A.C.I.T.,CIRCLE-4(1), AGRA

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

2. Facts, for convenience, are being taken from ITA No. 118/Agra/2015, the assessee’s appeal for A.Y. 2008-09 against the CIT(A)’s order confirming penalty of Rs.98,000/- imposed on the assessee u/s 271(1)(c) of the IT Act. AIR information was received in respect of the assessee, as per which, cash deposits amounting to Rs.6541003

ZILA SAHKARI BANK LTD,JHANSI vs. DCIT -2(3)(1), JHANSI

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

Bench: Shri A. D. Jain & Dr. Mitha Lal Meena

2. Facts, for convenience, are being taken from ITA No. 118/Agra/2015, the assessee’s appeal for A.Y. 2008-09 against the CIT(A)’s order confirming penalty of Rs.98,000/- imposed on the assessee u/s 271(1)(c) of the IT Act. AIR information was received in respect of the assessee, as per which, cash deposits amounting to Rs.6541003

A.C.I.T.-4(1), AGRA vs. M/S ROGER INDUSTRIES LTD., AGRA

In the result, the appeal is dismissed

u/s 2(22)(e). To which the assessee replied that since the assessee company has purchased shoes from M/S Euro Safety Footwear (P) Ltd., these are commercial transactions and the provisions of Section 2(22)(e) are not attracted. The assessee believed that the reply would be convincing and did not file any other evidence at that point of time

SHIVA PRESERVATION PRIVATE LIMITED,ETAWAH vs. ITO, WARD 2(2)(5), ETAWAH

In the result, the appeal of the Assessee is allowed

Bench: Shri M. Balaganesh(Through Virtual Hearing) Shiva Preservation Pvt. Ltd, Vs. Ito, Kaist, Jawantnagar, Etawah, Ward-2(2)(5), Uttar Pradesh -206245 Etawah (Appellant) (Respondent) Pan: Aaecs3418D Assessee By : Shri Rajesh Malhotra, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 20/11/2025 Date Of Pronouncement /11/2025

u/s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as „the Act‟) dated 31.12.2016 by the Assessing Officer, Income Tax Officer, Ward-2(2)(5), Etawah (hereinafter referred to as „ld. AO‟). 2. At the outset, I find that there is a delay in filing of appeal by the Assessee before this Tribunal by 975 days. Considering

A.C.I.T.,CIRCLE-2, GWALIOR vs. M/S VANDANA JAIN & RAMA BANSAL, MORENA

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

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

19 9. That during the course of search and seizure action as aforesaid the Authorized Officers had recorded the statements of the members of the above named AOPs, under section 132(4) of the Act. 10. That in their statements, recorded under section 132(4), they had stated that the transactions relating to purchase/ acquisition and sales of the shares

A.C.I.T., CIRCLE-2,, AGRA vs. M/S SAKSHI TAIRI & CHHAYA BATTAD, MORENA

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

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

19 9. That during the course of search and seizure action as aforesaid the Authorized Officers had recorded the statements of the members of the above named AOPs, under section 132(4) of the Act. 10. That in their statements, recorded under section 132(4), they had stated that the transactions relating to purchase/ acquisition and sales of the shares

A.C.I.T., CIRCLE-2, GWALIOR vs. M/S SUNIL KUMAR MITTAL & MAMTA MITTAL, MORENA

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

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

19 9. That during the course of search and seizure action as aforesaid the Authorized Officers had recorded the statements of the members of the above named AOPs, under section 132(4) of the Act. 10. That in their statements, recorded under section 132(4), they had stated that the transactions relating to purchase/ acquisition and sales of the shares

A.C.I.T., CIRCLE-2, GWALIOR vs. M/S SHYAM SUNDER & MANISH TAORI, MORENA

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

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

19 9. That during the course of search and seizure action as aforesaid the Authorized Officers had recorded the statements of the members of the above named AOPs, under section 132(4) of the Act. 10. That in their statements, recorded under section 132(4), they had stated that the transactions relating to purchase/ acquisition and sales of the shares

A.C.I.T., CIRCLE-2, GWALIOR vs. M/S RAKESH SHIVHARE & NISHA MITTAL, MORENA

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

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

19 9. That during the course of search and seizure action as aforesaid the Authorized Officers had recorded the statements of the members of the above named AOPs, under section 132(4) of the Act. 10. That in their statements, recorded under section 132(4), they had stated that the transactions relating to purchase/ acquisition and sales of the shares

M/S VERMA SERVICE STATION,FIROZABAD vs. D.C.I.T., RANGE-5, FIROZABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar,And Dr. Mitha Lal Meena

2. In this case, return of income for the A.Y. 2009-10 was filed on 29.09.2009 declaring total income of Rs. 4,86,270/-. Subsequently, the case was taken up for I.T.A No. 349/Agra/2018 3 & S.A. No.06/Agra/2018 (in I.T.A No. 349/Agra/2018) scrutiny under CASS and the assessment was completed at a total income of Rs.1

SARIF,JALESAR, ETAH vs. ASSESSIN OFFICER, WARD-4(3)(1), DINESH NAGAR ETAH

In the result, both the appeals ITA Nos

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

19,698/- , which did not match with the return filed by the assessee and the declared sales of Rs.51,01,31,327/-. Based on the aforesaid information, proceedings u/s. 147 of the Act were initiated by issuing notice u/s. 148 dated 30.07.2022, in response to 2 | P a g e ITA No.463 & 464/Agr/2025 which the assessee filed return of income

SARIF,JALESAR ETAH vs. ASSESSING OFFICER, WARD-4(3)(1) , ETAH

In the result, both the appeals ITA Nos

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

19,698/- , which did not match with the return filed by the assessee and the declared sales of Rs.51,01,31,327/-. Based on the aforesaid information, proceedings u/s. 147 of the Act were initiated by issuing notice u/s. 148 dated 30.07.2022, in response to 2 | P a g e ITA No.463 & 464/Agr/2025 which the assessee filed return of income

SH. MANOJ AGRAWAL,GWALIOR vs. I.T.O.-2(2), GWALIOR

In the result the appeal of the assessee is required to be failed and accordingly we dismiss both the appeals

271(1)(b) were also issued to the assessee. 4. Thereafter, a Notice under section 142(1) along with a detailed Questionnaire was issued to the assessee fixing compliance on 28.11.2011. In response to Assessee along with his Chartered Accountant appeared before the AO on 12.12.2011, filed written reply along with Audit Report offering a sum of Rs14

ACIT CENTRAL CIRCLE, AGRA vs. D.S. INDIA JEWELMART P LTD, MATHURA

In the result, the appeals of the assessee are allowed and those of Revenue are

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

penalty was held as procedurally defective. The provisions laid down u/s. 153D of the Act under consideration in the present case before us, are different as here the prior approval of Joint Commissioner is not required merely for direction for payment of the due amount of tax but overall approval of the assessment framed by the I.T.O. Thus, the cited

DCIT CENTRAL CIRCLE, AGRA vs. LT. SHRI MRADUL GARG, MATHURA

In the result, the appeals of the assessee are allowed and those of Revenue are

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

penalty was held as procedurally defective. The provisions laid down u/s. 153D of the Act under consideration in the present case before us, are different as here the prior approval of Joint Commissioner is not required merely for direction for payment of the due amount of tax but overall approval of the assessment framed by the I.T.O. Thus, the cited

ASHOK KUMAR AGARWAL,MATHURA vs. DCIT CENTRAL CIRCLE, AGRA

In the result, the appeals of the assessee are allowed and those of Revenue are

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

penalty was held as procedurally defective. The provisions laid down u/s. 153D of the Act under consideration in the present case before us, are different as here the prior approval of Joint Commissioner is not required merely for direction for payment of the due amount of tax but overall approval of the assessment framed by the I.T.O. Thus, the cited

D.S. INDIA JEWELMART P LTD,MATHURA vs. ACIT CENTRAL CIRCLE, AGRA

In the result, the appeals of the assessee are allowed and those of Revenue are

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

penalty was held as procedurally defective. The provisions laid down u/s. 153D of the Act under consideration in the present case before us, are different as here the prior approval of Joint Commissioner is not required merely for direction for payment of the due amount of tax but overall approval of the assessment framed by the I.T.O. Thus, the cited

SAURABH AGARWAL,MATHURA vs. DCIT CENTRAL CIRCLE, AGRA

In the result, the appeals of the assessee are allowed and those of Revenue are

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

penalty was held as procedurally defective. The provisions laid down u/s. 153D of the Act under consideration in the present case before us, are different as here the prior approval of Joint Commissioner is not required merely for direction for payment of the due amount of tax but overall approval of the assessment framed by the I.T.O. Thus, the cited