ACIT, CIRCLE-2(1)(1), AGRA, AGRA vs. SH. VISHWAMBHAR DAYAL AGARWAL, AGRA

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

reassessment of income of the other person would be in accordance with the provisions of section 153A and also relied upon the judgments of "Supreme Court" in the case that the block period proceedings u/s 153C of the Act has to be computed from the date of receipt of books of accounts or documents

ACIT-CIRCEL-2(1)(1), AGRA vs. MAYANK AGRAWAL, AGRA

In the result, the appeal filed by the assessee is allowed, the CO raised by the assessee and appeal filed by the Revenue are dismissed

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

reassessment of income of the other person would be in accordance with the provisions of section 153A and also relied upon the judgments of “Supreme Court” in the case that the block period proceedings u/s 153C of the Act has to be computed from the date of receipt of books of accounts or documents

SHYAMA SHYAM INFRADEVELOPERS PRIVATE LIMITED,AGRA vs. ITO 2(1)(2), AGRA

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganeshshyama Shyam Vs. Ito, Infradevelopers Pvt Ltd, Ward-2(1)(2), Khasra No. 961, Bhahistabad, Agra Sikandra, Agra (Appellant) (Respondent) Pan: Aatcs9899R Assessee By : Shri Gaurav Agarwal, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 21/01/2026 O R D E R

172 (Guj). The ld CIT(A) had laid more emphasis on provisions of Explanation 3 to Section 147 of the Act which permits the ld AO to make addition on issues that are not subject matter of reasons recorded for reopening. In our considered opinion, the said addition could be made only if the addition that was subject matter

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)

reassessment proceedings. Based on the above observations, he came to the conclusion that there is non-application of mind on the part of 18 ITA No.251/Agr/2025 and 4 ors. assessing officer in as much as the necessary verification of facts/enquiries which should have been made, have not been made, making the assessment order erroneous, prejudicial to the interest of revenue

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)

reassessment proceedings. Based on the above observations, he came to the conclusion that there is non-application of mind on the part of 18 ITA No.251/Agr/2025 and 4 ors. assessing officer in as much as the necessary verification of facts/enquiries which should have been made, have not been made, making the assessment order erroneous, prejudicial to the interest of revenue

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)

reassessment proceedings. Based on the above observations, he came to the conclusion that there is non-application of mind on the part of 18 ITA No.251/Agr/2025 and 4 ors. assessing officer in as much as the necessary verification of facts/enquiries which should have been made, have not been made, making the assessment order erroneous, prejudicial to the interest of revenue