HARICHARAN RATHORE,ASHOK NAGAR vs. INCOME TAX OFFICER,ASHOK NAGAR, ASHOK NAGAR

In the result, appeal filed by the assessee is allowed

Bench: Shri M. Balaganeshharicharan Rathore, Vs. Ito, 125, Path Kheda, Ashok Ashok Nagar, Nagar, Mp Mp (Appellant) (Respondent) Pan: Csqpr0999M Assessee By : Shri Rajendra Sharma, Adv Shri Manuj Sharma, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 21/01/2026

147 r.w.s. 144B of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 25.03.2025 by the Assessing Officer, Assessment Unit, Income Tax Department (hereinafter referred to as ‘ld. AO’). 2. Though the assessee has raised several grounds of appeal, the preliminary issue to be decided is whether the assumption of jurisdiction for reopening the assessment by Jurisdictional

BADARIPRASAD,GUNA vs. INCOME TAX OFFICER GUNA, GUNA

In the result, appeal filed by the assessee is allowed

Bench: Shri M. Balaganeshbadriprasad, Vs. Income Tax Officer, Heerabagh Colony, Guna, Guna, Gwalior Gwalior (Appellant) (Respondent) Pan: Arapr6314B

147 r.w.s 144 r.w.s. 144B of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 25.03.2023 by the Assessing Officer, Assessment Unit, Income Tax Department (hereinafter referred to as ‘ld. AO’). 2. Though the assessee has raised several grounds of appeal, the preliminary issue to be decided is whether the assumption of jurisdiction for reopening the assessment

NARAYANI RATHORE,SHIVPURI vs. ASSESSMENT UNIT,INCOME TAX DEPARTMENT, DELHI

In the result, appeal filed by the assessee is allowed

Bench: Shri M. Balaganeshnarayani Rathore, Vs. Assessment Unit, Peeroth Shivpuri, Income Tax Shivpuri, Mp Department, National Faceless Appeal Centre, Delhi (Appellant) (Respondent) Pan: Dhgpr1886H

147 r.w.s. 144B of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 28.03.2023 date of service order 28.03.2023 by the Assessing Officer, FAO, National Faceless Appeal Centre, Delhi (hereinafter referred to as ‘ld. AO’). 2. Though the assessee has raised several grounds of appeal, the preliminary issue to be decided is whether the assumption of jurisdiction

ASHOK SAHU,JHANSI vs. INCOME TAX OFFICER, WARD 2(3)(1), JHANSI, JHANSI

In the result, appeal filed by the assessee is allowed

Bench: Shri M. Balaganeshashok Sahu, Vs. Income Tax Officer, Purana Bazar, Chirgaon, Ward-2(3)(1), Jhansi Jhansi (Appellant) (Respondent) Pan: Jgsps3446H Sunita, Vs. Assessment Unit, Ward No. 2, Chobyana Income Tax Talrehat Lake View Department, Camp, Lalitpur, Lalitpur, National Faceless Up Appeal Centre, Delhi (Appellant) (Respondent) Pan: Jgps3438H

147 of the Act. Therefore, if Revenue's arguments are to be accepted, there is no purpose of framing a Scheme only for clause 3(a) which is in any event already covered under faceless assessment regime in Section 144B of the Act. The argument of respondent, therefore, renders the whole Scheme redundant. An argument which renders the whole Scheme

SUNITA,SAHU vs. ASSESSMENT UNIT,INCOME TAX DEPARTMENT, DELHI

In the result, appeal filed by the assessee is allowed

Bench: Shri M. Balaganeshashok Sahu, Vs. Income Tax Officer, Purana Bazar, Chirgaon, Ward-2(3)(1), Jhansi Jhansi (Appellant) (Respondent) Pan: Jgsps3446H Sunita, Vs. Assessment Unit, Ward No. 2, Chobyana Income Tax Talrehat Lake View Department, Camp, Lalitpur, Lalitpur, National Faceless Up Appeal Centre, Delhi (Appellant) (Respondent) Pan: Jgps3438H

147 of the Act. Therefore, if Revenue's arguments are to be accepted, there is no purpose of framing a Scheme only for clause 3(a) which is in any event already covered under faceless assessment regime in Section 144B of the Act. The argument of respondent, therefore, renders the whole Scheme redundant. An argument which renders the whole Scheme

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

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

6] [In favour of assessee]\nii).\nReliance is being placed on the judgment of CIT Vs. Nirav\nModi, 77 Taxmann.com 15 (SC), in which, it has been held as\nunder:-\n“Section 68 read with section 263, of the Income-tax Act,\n1961 - Cash credit (Gift) Assessment years 2007-08 and\n2008-09 - Assessee received certain amount as gifts from

RATNESH KUMAR JAIN,SHIVPURI vs. INCOME TAX OFFICER ASHOK NAGAR, GWALIOR

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

6. That the provisions of sec 69A are not attracted in the case of\nassessee which the NFAC has ignored while passing the order and\nalso has not disposed the specific ground no-7 taken, opposing the\ninvoking of sec 69A of Income Tax Act, the order passed by NFAC is\nbad in law liable to be set-a-side

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)

6 taken on the merits of the additions, has set aside the issue back to the file of AO in terms of the powers conferred to him under first proviso to section 251(1) (a) of the Act and direct the AO to pass the assessment order afresh after considering the replies and documents filed by the assessee. However

CHANDRA PRAKASH GOPLANI,BENGALURU vs. ITO 2(1)(1), AGRA

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

Bench: : Shri Ramit Kocharassessment Year: 2012-13

Section 147 of the 1961 Act. Thus , it was an ex-parte reassessment order passed by the AO. 6. Assessee

PAWAN AGRAWAL,MATHURA vs. INCOME TAX OFFICER 1(3)(1), MATHURA

In the result, the appeal of the Assessee is allowed

147 and 151 were\nlightly treated by the Income-tax Officer as well as by the\nCommissioner. Both of them appear to have taken the duty imposed on\nthem under those provisions as of little importance. They have\nsubstituted the form for the substance.\"\n20. This Court, while following Chhugamal Rajpal in the case of Ess Adv.\n(Mauritius

ASSTT COMMISSIONER OF INCOME TAX CIRCLE-2(1)(1) AGRA, SANJAY PLACE vs. MAMTA AGARWAL, BHAGWATI INTERNATIONAL

In the result, the appeal of the revenue is dismissed

reassessment proceedings, notice u/s 133(6) ofd the Act was issued to the Id AO to Prakash Gupta and no response was received from him. This goes to prove that the notice u/s 133(6) of the Act stood served on him but the party are chosen not to respond for which the assessee cannot be faulted. The Id NFAC

SH ABHISHEK GUPTA ,AGRA vs. ITO W2(2)(1),, FIROZABAD

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

Bench: Shri Ramit Kochar & Shri Sudhir Kumarshri Abhishek Gupta The Income Tax Officer 405, Anupam Omerean Ward 2(2)(1), Firozabad, Heights, Mughal Road, V. U.P. Kamla Nagar, Agra-282005 Uttar Pradesh "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aefpg0755D Appellant .. Respondent

147 of the Act, after obtaining necessary approval from the competent authority.Notice under Section 148 of the Act was issued by the AO to the assessee on 31.03.2019 . Copy of reasons recorded by the AO were also provided to the assessee. Statutory notices u/s 142(1) , 143(2) and 144 were issued by the AO from time to time during

SOURABH JAIN,GUNA vs. INCOME TAX OFFICER GUNA, GUNA

In the result, the appeal of the assessee is dismissed

Bench: Shri Sunil Kumar Singh & Shri Manish Agarwalincome Tax Officer, Saurabh Jain, Guna. 1, Near Sanjeevani Vs. Hospital Garha Colony, Guna, Madhaya Pradesh-473001 Pan-Bgjpj7915F (Appellant) (Respondent)

reassessment order passed under Section 147 r.w.s. 144 is void ab initio because same was framed on duplicate PAN of the appellant while appellant assessed on original PAN. Thus Ld. CIT(A) erred in not deciding to such matter required under the law. 3. On the facts and circumstances of the case, the Commissioner of Income Tax (Appeals) has erred

SARVESH KUMAR,FARRUKHABAD vs. INCOME TAX OFFICER WARD 4(2)(2) FARRUKHABAD, FARRUKHABAD

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh(Through Virtual Hearing) Sarvesh Kumar, Vs. Ito, Okharu Khanpur, Ward-4(2)(2), Farrukhabad, Fatehgarh, Farrukhabad Ho 209601 (Appellant) (Respondent) Pan: Dsqpk3348G Assessee By : Shri Swaran Singh, Ca Shri Shailesh Gupta, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 18/08/2025 Date Of Pronouncement 18/11/2025

6 ……………..……… 7 ………..…………… 8. Explanation 2(a) to section 147 of the Income-tax Act includes non-filing of return in the expression "escaped assessment. The said Explanation reads "Explanation 2: For the purposes of this section, the following shall also be deemed to be cases where income chargeable to tax has escaped assessment, namely: Sarvesh Kumar (a) where no return

RAJESH TYAGI,AMBAH vs. ITO WARD 1, MORENA, MORENA

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

Bench: : Shri S. Rifaur Rahmanassessment Year: 2020-21 Rajesh Tyagi Vs. Assessment Unit, S/O Laxmi Narayan Tyagi Gavri National Faceless Assessment Service, Gulab Ka Pura Ambah Centre, Income Tax Officer, Distt. Morena Ward-1, Morena Pan : Bmmpt3132K (Appellant) (Respondent) Assessee By Sh. Sandeep, Ca Department By Shri Anil Kumar, Sr. Dr Date Of Hearing 17.02.2026 Date Of Pronouncement 17.02.2026 Order

6. BECAUSE in the absence of valid service of notice under section 148, the reassessment order passed under section 147

TEJ SINGH,MATHURA vs. ITO 1(3)(4), MATHURA

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

6(3) did not indicate as to how capital gains arise in the case of assessee and the AO merely accepted truth in vague information in a mechanical manner and put the assessee under obligation to file reply to the same. Merely because no reply was filed, the AO acted in haste and initiated proceedings u/s. 147

CHAND KHAN,SADA SHIV NAGAR vs. ITO WARD 1(2) , CITY CENTER

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

Bench: : Shri Ramit Kocharassessment Year: 2012-13

6. Learned Sr. DR, on the other hand, relied upon the order of ld. CIT(Appeals). 7. I have considered rival contentions and perused the material on record. I have observed that based upon AIR information received from SBI, Mutual Fund, the Assessing Officer invoked provisions of section 147 read with section 148 of the Act, and notice