VINOD KUMAR GUPTA,JHANSI vs. ITO, WARD-2(3)(1), JHANSI

In the result, the appeals of the assessee in ITA Nos

reassessment was completed u/s 147\nread with Section 144B of the Act on 26.03.2022 wherein, loss from house\nproperty of Rs. 52,567/- was disallowed apart from making addition on account\nof unexplained money u/s 69A in respect of credits in the bank account in the\nsum of Rs. 28,20,500 and denying deduction

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

reassessed. (4) Subject to the provisions of sub-section (6), where the source of any receipt, deposit or investment in any assessment year is claimed to be an amount added to income or deducted

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

reassessed. (4) Subject to the provisions of sub-section (6), where the source of any receipt, deposit or investment in any assessment year is claimed to be an amount added to income or deducted

GUMAN SINGH KUSHWAH,SHIVPURI vs. INCOME TAX OFFICER, ASHOKNAGAR

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

Bench: Shri M. Balaganeshgumnam Singh Kushwah, Vs. Income Tax Officer, Infront Of Collector Kothi, Ashok Nagar, Shiv Colony, Shivpuri, Mp Mp (Appellant) (Respondent) Pan: Bcjpk2729Q Assessee By : Shri Ashish Goyal, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 22/01/2026

reassessment order, the Learned AO noted that assessee had purchased plot for Rs 71 lakhs during the year under consideration from Mr. Purushottam Khandelwal. The seller had not provided his PAN to the assessee. Hence, the assessee should have deducted

M/S TOMAR & BROTHERS,ETAWAH vs. A.C.I.T., CIRCLE-5, FIROZABAD

The appeal stands allowed

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No. 348/Agr/2014 (िनधा"रणवष" / Assessment Year:2007-08) M/S. Tomar & Brothers Acit, Circle 5, बनाम/ 843-A, Moti Jheel Colony, Firozabad. Vs. Etawah (Up). "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaft-7229-D (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Anurag Sinha, Adv. – Ld. Ar " थ"कीओरसे/Respondent By : Sh. Shailender Shrivastava – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 19-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 22.04.2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2007-08 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)- Ii, Agra [Cit(A)] Dated 31-03-2014 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 143(3) R.W.S. 147 Of The Act On 29-12-2011. Both Sides Made Vehement Arguments. Having Heard Rival Submissions & Upon Perusal Of Case Records, The Appeal Is Disposed- Off As Under. The Ld. Ar Has Assailed The Validity Of Reassessment Proceedings. 2. Upon Perusal Of Assessment Order, It Could Be Seen That Assessee’S Return Of Income Was Scrutinized U/S. 143(3) On 18-11-2009. However, The Case Was Reopened Vide Notice U/S 07-01-2011 On The Allegation That The Assessee Did Not Deduct Tax At Source On Machinery Rental Payments.

reassessment proceedings. 2. Upon perusal of assessment order, it could be seen that assessee’s return of income was scrutinized u/s. 143(3) on 18-11-2009. However, the case was reopened vide notice u/s 07-01-2011 on the allegation that the assessee did not deduct

VINOD KUMAR GUPTA,JHANSI vs. ITO, WARD-2(3)(1), JHANSI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri M. Balaganesh(Through Virtual Hearing)

reassessment was completed u/s 147 read with Section 144B of the Act on 26.03.2022 wherein, loss from house property of Rs. 52,567/- was disallowed apart from making addition on account of unexplained money u/s 69A in respect of credits in the bank account in the sum of Rs. 28,20,500 and denying deduction

VINOD KUMAR GUPTA,JHANSI vs. ITO, WARD-2(3)(1), JHANSI

In the result, the appeals of the assessee in ITA Nos

reassessment was completed u/s 147\nread with Section 144B of the Act on 26.03.2022 wherein, loss from house\nproperty of Rs. 52,567/- was disallowed apart from making addition on account\nof unexplained money u/s 69A in respect of credits in the bank account in the\nsum of Rs. 28,20,500 and denying deduction

VINOD KUMAR GUPTA,JHANSI vs. ITO, WARD-2(3)(1), JHANSI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri M. Balaganesh(Through Virtual Hearing)

reassessment was completed u/s 147 read with Section 144B of the Act on 26.03.2022 wherein, loss from house property of Rs. 52,567/- was disallowed apart from making addition on account of unexplained money u/s 69A in respect of credits in the bank account in the sum of Rs. 28,20,500 and denying deduction

VINOD KUMAR GUPTA,JHANSI vs. ITO, WARD-2(3)(1), JHANSI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri M. Balaganesh(Through Virtual Hearing)

reassessment was completed u/s 147 read with Section 144B of the Act on 26.03.2022 wherein, loss from house property of Rs. 52,567/- was disallowed apart from making addition on account of unexplained money u/s 69A in respect of credits in the bank account in the sum of Rs. 28,20,500 and denying deduction

SINGH CARRIERS,JHANSI vs. WARD 2(3)(1), JHANSI

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

Bench: Shri Sunil Kumar Singh & Shri Manish Agarwalincome Tax Officer, Singh Carriers, Ward-2(3)(1), 2716, Swamipuram Vs. Jhansi. Colony, Gwalior Road, Jhansi, Uttar Pradesh-284003. Pan-Aacfs9607B (Appellant) (Respondent)

reassessment proceedings. This view is supported by the judgment of the Co-ordinate Bench of ITAT, Hyderabad in the case of Eyegear Optics India (P.) Ltd. vs DCIT in Appeal Nos.1291 and 1347 (Hyd.) of 2024 dated 14.05.2025. “Section 37(1), read with sections 144, 147 and 251 of the Income-tax Act, 1961 - Business expenditure - Allowability of (Referral fees

SH. YUGAL KISHOR AGARWAL,AGRA vs. DCIT, CIRCLE 4(3)(1), ETAH

In the result, appeal filed by the assessee is allowed

Bench: : Shri Ramit Kocharassessment Year: 2012-13

reassessment order u/s 147 read with Section 143(3) dated 24.10.2019, the Assessing Officer made two additions – firstly, disallowance of Rs.12,15,413/- claimed by the assessee as expenditure against income from other sources by invoking provision of Section 57(iii) of the Act as the assessee could not furnish any evidences in respect of these expenses , and secondly disallowance

SHRI ATUL SRIVASTAVA,AGRA vs. PCIT-1, AGRA, AGRA

The appeals of the assessees are allowed in above terms

Bench: : Smt. Annapurna Gupta & Shri Sunil Kumar Singhassessment Year: 2012-13

reassessment proceedings. Thus the Pr. CIT has erred in imitating proceedings U/S 263. 2 | P a g e ITA No.56 & 57/Agr/2022 5. That the Asstt. Order dated 31-10-2019 is not prejudicial to the interests of the revenue.” 5. The order of the ld. PCIT in the case of Sarika Srivastava reveals that the assessee is a Doctor

SMT. SARIKA SRIVASTAVA,AGRA vs. PCIT-1, AGRA, AGRA

The appeals of the assessees are allowed in above terms

Bench: : Smt. Annapurna Gupta & Shri Sunil Kumar Singhassessment Year: 2012-13

reassessment proceedings. Thus the Pr. CIT has erred in imitating proceedings U/S 263. 2 | P a g e ITA No.56 & 57/Agr/2022 5. That the Asstt. Order dated 31-10-2019 is not prejudicial to the interests of the revenue.” 5. The order of the ld. PCIT in the case of Sarika Srivastava reveals that the assessee is a Doctor

PAWAN KUMAR CHAUHAN,MAINPURI vs. ITO- WARD 2 (5) , AGRA, AGRA

deduction claimed u/s 80 C made by the Assessing\nOfficer ignoring schedule \"A\" of the audited balance sheet (proprietor\ncapital account) in which the amount of LIP and Tution Fees Paid is\nduly accounted for.\n4. Because considering the facts of the case all the additions deserves\nto be deleted. The Ld. CIT(A) should have deleted all the additions

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) &

deducted from NAFED purchases making it 38.71% and accordingly, reverse calculations were made. The Ld. AO drew an inference that average yield could not be below 41% as against average yield of 36% as shown by the assessee in its audited books of accounts. So far as AY 2017-18 was concerned, this was year of demonetization and it would

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) &

deducted from NAFED purchases making it 38.71% and accordingly, reverse calculations were made. The Ld. AO drew an inference that average yield could not be below 41% as against average yield of 36% as shown by the assessee in its audited books of accounts. So far as AY 2017-18 was concerned, this was year of demonetization and it would

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) &

deducted from NAFED purchases making it 38.71% and accordingly, reverse calculations were made. The Ld. AO drew an inference that average yield could not be below 41% as against average yield of 36% as shown by the assessee in its audited books of accounts. So far as AY 2017-18 was concerned, this was year of demonetization and it would

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) &

deducted from NAFED purchases making it 38.71% and accordingly, reverse calculations were made. The Ld. AO drew an inference that average yield could not be below 41% as against average yield of 36% as shown by the assessee in its audited books of accounts. So far as AY 2017-18 was concerned, this was year of demonetization and it would