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

reassessment or recomputation under Section 147; or Gauri Gaekwad 63/87 904.WP-1778-2023.doc (ii) issuance of notice under Section 148; or (iii) conducting of inquiry or issuance of show cause notice or passing of order under Section 148A; or (iv) sanction for issuance of notice under Section 151; So as to impart greater efficiency, transparency and accountability by inter alia eliminating

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

reassessment or recomputation under Section 147; or Gauri Gaekwad 63/87 904.WP-1778-2023.doc (ii) issuance of notice under Section 148; or (iii) conducting of inquiry or issuance of show cause notice or passing of order under Section 148A; or (iv) sanction for issuance of notice under Section 151; So as to impart greater efficiency, transparency and accountability by inter alia eliminating

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

reassessment or recomputation under Section 147; or Gauri Gaekwad 63/87 904.WP-1778-2023.doc (ii) issuance of notice under Section 148; or (iii) conducting of inquiry or issuance of show cause notice or passing of order under Section 148A; or (iv) sanction for issuance of notice under Section 151; So as to impart greater efficiency, transparency and accountability by inter alia eliminating

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

reassessment or recomputation under Section 147; or Gauri Gaekwad 63/87 904.WP-1778-2023.doc (ii) issuance of notice under Section 148; or ITA No. 432/AGR/2025 (iii) conducting of inquiry or issuance of show cause notice or passing of order under Section 148A; or (iv) sanction for issuance of notice under Section 151; So as to impart greater efficiency, transparency and accountability by inter

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

reassessment or recomputation under Section 147; or Gauri Gaekwad 63/87 904.WP-1778-2023.doc (ii) issuance of notice under Section 148; or ITA No. 432/AGR/2025 (iii) conducting of inquiry or issuance of show cause notice or passing of order under Section 148A; or (iv) sanction for issuance of notice under Section 151; So as to impart greater efficiency, transparency and accountability by inter

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

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

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

2 facts that reassessment proceedings initiated and consequential reassessment order passed under section 147 of the Act which are illegal and void for the reason - (a) that the Assessing Officer had no jurisdiction to issue notice under section 148 of the Act beyond the period of four years from the end of the relevant assessment year without 3 demonstrating

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

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

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

2 facts that reassessment proceedings initiated and consequential reassessment order passed under section 147 of the Act which are illegal and void for the reason - (a) that the Assessing Officer had no jurisdiction to issue notice under section 148 of the Act beyond the period of four years from the end of the relevant assessment year without 3 demonstrating

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

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

section 151, the initiation of reassessment proceedings after more than four years was clearly barred by time.” 15. The ratio decidendi of both the decisions of the Hon’ble Jurisdictional High Court evidently is that in the absence of anything in the reasons recorded to suggest that the income chargeable to tax which has escaped assessment is one lac rupees

BANARSI LAL,FIROZABAD vs. ITO 2(2)(1), FIROZABAD, FIROZABAD

In the result, the appeal of the assessee is allowed

Bench: Us Challenging The Validity Of Assumption Of Jurisdiction U/S 147 Of The Act. These Additional Grounds Go To The Root Of The Matter & The Facts Relevant For Its Adjudication Are Placed On Record. Hence, We Admit The Additional Grounds & Take Up The Same First For Adjudication.

2), Firozabad is enclosed in Page 18 of the Paper Book. On perusal of the proforma seeking approval u/s 151 of the Act, we find that the Ld. Addl CIT had merely stated that he is satisfied that this is fit case for reopening. This sort of approval granted u/s 151 of the Act was held to be approval granted

ANIL KUMAR YADAV LEGAL HEIR SMT. LONG SHREE ,MAINPURI vs. INCOME TAX OFFICER-4(2)(4), MAINPURI

2)(4)\n(L/H Smt. Long Shree)\nबनाम /\nMainpuri\nMain Bazar, Karhal\nVs.\nMainpuri 205001\nस्थायीलेखासं./जीआइआरसं./PAN/GIR No. AAAPY-8480-E\n(अपीलार्थी/Appellant)\n(प्रत्यर्थी / Respondent)\nअपीलार्थीकीओरसे / Appellant by: Shri Anurga Sinha (Advocate) – Ld. AR\nप्रत्यर्थीकीओरसे/Respondent by: Shri Shailendra Shrivastava - Ld. Sr. DR\nसुनवाईकीतारीख/Date of Hearing\n20-02-2025\nघोषणाकीतारीख / Date of Pronouncement

OM PRAKASH,HATHRAS vs. INCOME TAX OFFICER, WARD 4(3)(4), HATHRAS, HATHRAS

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh(Through Virtual Hearing) Om Prakash, Vs. Income Tax Officer, Village Baramai, Ward-4(3)(4), Sadabad, Hathras Hathras (Appellant) (Respondent) Pan: Dkbpp7713K

2,000/- was found thereon. Whereas in the reasons recorded, the Learned AO had stated that assessee had deposited Rs. 28,26,470/- in the bank account. In the assessment order, the Learned AO had stated that assessee had deposited a different sum of Rs. 38,56,470/- and out of that had made an addition

PRAMOD KUMAR GARG,AGRA vs. DCIT,CIRCLE 2(1)(1), AGRA

In the result, assessee’s appeal is allowed

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2015-16

2 | P a g e 4. Assessee has preferred this second appeal mainly on the ground that learned CIT(A) has erred in confirming the substantial amount of addition made by the Assessing Officer, ignoring the invalid notice dated 30.07.2022 issued u/s. 148 of the Act, which is contrary to the order dated 03.10.2024 passed by Hon’ble Apex Court

SUDHINDRA PAL SINGH,ETAH vs. INCOME TAX OFFICER WARD-3(2), ETAH, ETAH

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh(Through Virtual Hearing) Sudhindra Pal Singh, Vs. Income Tax Officer, Bara Bhondela, At Bara Ward-3(2), Bhondela, Awagarh, Etah Etah- 207 301, Etah (Appellant) (Respondent) Pan: Ekyps0396P

2. The Ground No. 1 raised by the assessee pertains to challenging the validity of assumption of jurisdiction under section 147 of the Act. I find that the assessee has also raised additional ground of appeal stating that Sudhindra Pal, Singh the approval granted under section 151 of the Act by the learned PCIT for reopening the assessment is mechanical

YOGENDRA SHARMA,DELHI vs. INCOME TAX OFFICER, ETAH

In the result, the appeal preferred by assessee is allowed

Bench: : Shri S. Rifaur Rahmanassessment Year: 2012-13 Yogendra Sharma, I-4695, 2Nd Vs. Income-Tax Officer, Floor, Gali No. 4-B, Balbir Nagar Ward 3(2), Etah. Extension, Shahdara, Delhi. Pan :Cgkps6492J (Appellant) (Respondent)

reassessment is further vitiated as the mandatory previous sanction under section 151 was not supplied to the appellant despite request, and in any case appears to have been obtained mechanically without due application of mind; absence of a valid sanction renders the notice and consequent assessment void. 5. Because having regard to the facts and circumstances to the case there

RAVENDRA SINGH,AGRA vs. ACIT, CIRCLE 1(2)(1), AGRA

In the result, appeal filed by the assessee is allowed for statistical purposes and direct the ld

Bench: : Shri S. Rifaur Rahmanassessment Year: 2012-13 Ravendra Singh Vs. Acit, 28, Tota Ka Taal Circle 1(2)(1), Loha Mandi, Uttar Pradesh Agra Pan : Abyps5329K (Appellant) (Respondent) Assessee By Shri Shashank Agarwal, Adv. Department By Shri Anil Kumar, Sr. Dr Date Of Hearing 16.02.2026 Date Of Pronouncement 16.02.2026 Order

2 | P a g e Although hearing notices may have been sent through the e-filing portal or e-mail, the assessee, a 79-year-old senior citizen and inadvertently missed noticing such communications. The non-appearance was therefore bona fide and not deliberate. 3. The learned CIT(A) erred in summarily dismissing the appeal instead of deciding the same

ANJU AGARWAL,AGRA vs. INCOME TAX OFFICER, WARD 2(1)(1), AGRA

In the result, the appeal of the Assessee is allowed

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh (Through Virtual Hearing) Anju Agarwal, Vs. Income Tax Officer, D-26, Kamla Nagar, Ward-2(1)(1), Agra Agra (Appellant) (Respondent) Pan: Awtpa4297L Assessee By : Shri K. K. Jain, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 16/09/2025 Date Of Pronouncement 04/12/2025

151 of the Act from the competent authority. The reassessment stood completed under Section 147 r.w.s. 144B of the Act on 23-3- 2024 determining total income of the Assessee at Rs. 56,35,106/- after making an addition of Rs. 49,98,136/-, which stood upheld by the Learned NFAC. Anju Agarwal 4. At the outset, we find that

SAGAR DWELLINGS P LTD,NEAR SUN TEMPLE GWALIOR vs. ACIT, FACELESS

In the result, assessee’s appeal is dismissed

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

reassessment order dated 21.03.2022 passed u/s. 147 r.w.s. 144B of the Act. 3. Aggrieved, assessee preferred first appeal before the Ld. CIT(Appeals), who dismissed assessee’s appeal and confirmed the impugned addition. 4 | P a g e 4. Present second appeal has been filed on the following grounds : “1. BECAUSE, upon due consideration of facts and in the overall

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

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

151 of the Act. The assessee filed his\nreturn on 20.04.2021 declaring the same income as was originally declared, in\nresponse to notice u/s 148 of the Act. The 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