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

5 | P a g e ITA No.344 & 343/Agr/2025 relevant assessment year, and therefore, the reassessment proceedings are ex facie bad in law, being initiated without satisfying the conditions stipulated in first proviso to Section 147, and are thus liable to be quashed as void ab initio. The statutory conditions under the first proviso to Section 147 are that no action

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

5 | P a g e ITA No.344 & 343/Agr/2025 relevant assessment year, and therefore, the reassessment proceedings are ex facie bad in law, being initiated without satisfying the conditions stipulated in first proviso to Section 147, and are thus liable to be quashed as void ab initio. The statutory conditions under the first proviso to Section 147 are that no action

SMT. VIDHYA AGARWAL,AGRA vs. I.T.O., WARD-4(4), AGRA

The appeal is allowed

Bench: Shri Sudhanshu Srivastava & Dr. Mitha Lal Meena

reassessment proceeding itself we see no need to deal with ground No. 3 raised by the assessee to the effect that "on the facts and in the circumstances of the case, the learned CIT(A) erred in confirming and the Assessing Officer erred in holding that the provisions of section 11(5) read with section

ANURAG MITTAL ,FIROZABAD vs. DCIT CENTRAL CIRCLE, AGRA

In the result, both the appeals of the assessee are allowed

Bench: Shri Laliet Kumar & Dr. Mitha Lal Meena

reassessment passed under clause (b) of section 153A in respect of each assessment year falling within six assessment years immediately preceding the assessment year relevant to the previous year in which search is conducted under section 132 or requisition is made under section 132A. The provision has also been made applicable to orders of assessment passed under clause

RAJESH LADHANI,FAIZABAD vs. DCIT CC , AGRA

In the result, all three appeals of the assessee are allowed

Bench: Shri Laliet Kumar & Dr. Mitha Lal Meenaita No. 106,107 & 108/Agra/2019 Assessment Year: 2008-09 & 2011-12 Vs. Dy. C.I.T. –Central Circle, Rajesh Ladhani, 259, Savera Bhawan, Ram Nagar Colony, Agra. Faizabad. Pan: Abapl5646C (Appellant) (Respondent)

reassessment passed under clause (b) of section 153A in respect of each assessment year falling within six assessment years immediately preceding the assessment year relevant to the previous year in which search is conducted under section 132 or requisition is made under section 132A. The provision has also been made applicable to orders of assessment passed under clause

SURESH CHAND GUPTA,JHANSI vs. DCIT-6, JHANSI

In the result, the assessee’s appeal is dismissed

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

5. Here again, we have to clarify that the Tribunal has wrongly assumed that reassessment was completed beyond four years from the end of the relevant assessment year and there is no failure on the part of the assessee to make full and true disclosure of material facts necessary for assessment as referred to in the first proviso

A.C.I.T.,CENTRAL CIRCLE, AGRA vs. M/S WELCOME COIR INDUSTRIES LTD.,, NEW DELHI

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

21,920/- with Union Bank of India, Gwalior 2. Unexplained deposit in account Rs.13.29,080/- Rs.90,51,000/- I.T.A No. 266 to 269/Agra/2013 5 with HDFC Bank Total Assessed Income Rs.90,51,000/- A.Y. 2004-05:- Returned Income as estimated Rs.NIL Add:- 1. Unexplained deposit in account Rs. 2,06,53,000/- with Union Bank of India, Gwalior 2. Unexplained

LAKSHYA ICE & COLD STORAGE P LTD,ALIGARH vs. ITO WARD 1(5), ALIGARH

In the result, by the assessee is allowed

Bench: Shri Sudhanshu Srivastava & Dr. Mitha Lal Meenam/S Lakshya Ice & Cold Storage Pvt. Ltd. Vs.. Income Tax Officer, Goyal Bhawan, Opp. Maheshwari Inter Ward 1(5), Aligarh College, Sasni Gate, Bye Pass Road, Aligarh (Pan: Aabcl5656R) (Respondent) (Appellant)

5, it 13. was held that where information was received from investigation wing and the assessee was beneficiary of accommodation entries but no further inquiry was under taken by AO, said information could not be said to be tangible material as per se and, thus, reassessment on said basis was not justified. Finally, the Ld. AR submitted that the impugned

GOVIND SHARMA,MATHURA vs. ITO, WARD 1(3)(1), MATHURA

In the result, the assessee’s appeal is allowed

21. The salient aspect which emerges out of the foregoing discussion is that the satisfaction arrived at by the prescribed authority under section 151 of the Act must be clearly discernible from the expression used at the time of affixing its signature while according approval for reassessment under section 148 of the Act. The said approval cannot be granted

VIKAS CHANDRA HUF,ALIGARH vs. ITO WARD-4(1)(1), ALIGARH

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganeshvikas Chandra Huf, Vs. Cit(Appeals), D-117, Ramesh Vihar, Nfac, Delhi Ramghar Road, Aligarh Up (Appellant) (Respondent) Pan: Aakjv9476N Assessee By : Shri Pankaj Garg, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 21/01/2026

21. The salient aspect which emerges out of the foregoing discussion is that the satisfaction arrived at by the prescribed authority under section 151 of the Act must be clearly discernible from the expression used at the time of affixing its signature while according approval for reassessment under section 148 of the Act. The said approval cannot be granted

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

21,646/-. The notices u/s 148 of the Act was issued and served on the assessee after recording reasons and obtained proper approval from competent authority. In compliance to the notice, assessee filed his return of income on 07.05.2019 declared income of Rs. 30,92,800/-. Subsequently, notice u/s 143(2) and 142(1) of the Act were issued

LT. SHRI MRADUL GARG,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

reassessment Director, as the case may be, in respect of order, as the case may be, is required to be passed search initiated under section 132 or books by the Assessing Officer with the prior approval the 53[Principal of Commissioner or] of account, other documents or any assets Commissioner under sub-section (12) of section requisitioned under section 132A

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

reassessment Director, as the case may be, in respect of order, as the case may be, is required to be passed search initiated under section 132 or books by the Assessing Officer with the prior approval the 53[Principal of Commissioner or] of account, other documents or any assets Commissioner under sub-section (12) of section requisitioned under section 132A

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

reassessment Director, as the case may be, in respect of order, as the case may be, is required to be passed search initiated under section 132 or books by the Assessing Officer with the prior approval the 53[Principal of Commissioner or] of account, other documents or any assets Commissioner under sub-section (12) of section requisitioned under section 132A

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

reassessment Director, as the case may be, in respect of order, as the case may be, is required to be passed search initiated under section 132 or books by the Assessing Officer with the prior approval the 53[Principal of Commissioner or] of account, other documents or any assets Commissioner under sub-section (12) of section requisitioned under section 132A

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

reassessment Director, as the case may be, in respect of order, as the case may be, is required to be passed search initiated under section 132 or books by the Assessing Officer with the prior approval the 53[Principal of Commissioner or] of account, other documents or any assets Commissioner under sub-section (12) of section requisitioned under section 132A

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

reassessment Director, as the case may be, in respect of order, as the case may be, is required to be passed search initiated under section 132 or books by the Assessing Officer with the prior approval the 53[Principal of Commissioner or] of account, other documents or any assets Commissioner under sub-section (12) of section requisitioned under section 132A

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

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

5. Asstt.CIT Vs. Rajesh Jhavri, [2007] 291 ITR 500/161 Taxman 316 (SC). I.T.A No. 29/Agra/2015 12 Page 17 of 23 Tej Singh vs. ITO 6. Chief Commissioner (Admn.) (U.P.) V. Kanhaiya Lal Kapoor, [2005] 147 Taxman, 12 (All). 7. Pooran Mal Vs. Director of Inspection, [1974) 93 ITR 505 (SC) 8. Deep Chand Daga