VISHWAMBHAR DAYAL AGARWAL,AGRA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE2(1)(1), AGRA, 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 shall be made by an Assessment Officer below the rank of Joint Commissioner in respect of each assessment year referred to in Clause (b) of Sub Section (1) of Section 153A of the Act or the assessment year referred to in Clause (b) of Sub Section 153B of the Act except the prior approval of the Joint Commissioner

ACIT-CIRCLE-2(1)(1), AGRA vs. PUNEET AGARWAL, 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 shall be made by an Assessment Officer below the rank of Joint Commissioner in respect of each assessment year referred to in Clause (b) of Sub Section (1) of Section 153A of the Act or the assessment year referred to in Clause (b) of Sub Section 153B of the Act except the prior approval of the Joint Commissioner

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 shall be made by an Assessment Officer below the rank of Joint Commissioner in respect of each assessment year referred to in Clause (b) of Sub Section (1) of Section 153A of the Act or the assessment year referred to in Clause (b) of Sub Section 153B of the Act except the prior approval of the Joint Commissioner

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

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

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

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

24. Since no reasons were recorded that the escaped income is likely to be Rs.1 lac or more so that the Chief Commissioner or Commissioner may record his satisfaction under 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

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

1,08,00,000/- was made on\naccount 'excess salary' paid to two employees u/s 40A(2b) of the Act.\nThe said assessment was then subject matter of reassessment u/s 148\nbased on the reason to believe of the AO that the assessee had taken\nbogus purchase thro accommodation entries from one Sh. Md. Irfan.\nDuring reassessment proceedings

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

reassessment under section 148 of the Act. The said approval cannot be granted in a mechanical manner as it acts as a linkage between the facts considered and conclusion reached. In the instant case, merely appending the phrase "Yes" does not appropriately align with the mandate of Section 151 of the Act as it fails to set out any degree

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

In the result, the appeal of the Assessee is allowed

reassessment under section 148 of\nthe Act. The said approval cannot be granted in a mechanical manner as it acts\nas a linkage between the facts considered and conclusion reached. In the\ninstant case, merely appending the phrase \"Yes\" does not appropriately align\nwith the mandate of Section 151 of the Act as it fails to set out any degree

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)

24,83,15,217/- under Section 69A on account of cash deposits in the bank accounts which were duly recorded in the books of accounts and supported by an audit report, making the invocation of Section 69A unwarranted. 4. On the facts and circumstances of the case, the Commissioner of Income Tax (Appeals) has erred not dealt to the ground

BIKESH KUMAR,FIROZABAD vs. INCOME TAX OFFICER 2(2)(1) , FIROZABAD

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

Bench: Shri M. Balaganeshbikesh Kumar, Vs. Income Tax Officer, Nagla Bhoop Nasirpur, Ward-2(2)(1), Shikhabad Firozabad, Firozabad Firozabad (Appellant) (Respondent) Pan: Bglpk0327A Assessee By : Shri Rajendra Sharma, Adv Shri Manuj Sharma, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 23/01/2026 Date Of Pronouncement 03/02/2026

1) of the Act were issued on 14-12-2021, 2-2-2022 followed by final showcause notice dated 10-2-2022 for completion of assessment ex parte. Even for this, there was no response from the side of the assessee. This non-cooperative attitude of the assessee forced the Learned AO to complete the reassessment under section 147 r.w.s

INCOME TAX OFFICER, ASHOKNAGAR vs. AJIT SINGH , SHIVPURI

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

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh (Through Virtual Hearing) Income Tax Officer, Vs. Ajit Singh, Ashoknagar, Village-Haatodh, Madhya Pradesh Post-Kota, Shivpuri (Appellant) (Respondent) Pan: Ccnps7470K Assessee By : Shri Vipin Upadhyay, Adv Revenue By: Shri Sukesh Kumar Jain, Cit(Dr) Date Of Hearing 17/11/2025 Date Of Pronouncement 04/11/2025

1,71,97,600/- d) Income from lottery / crossword puzzle in terms of section 194B based on the TDS return – Rs. 50,024 5. Since the aforesaid transactions were above the maximum amount not chargeable to tax, the Learned AO proceeded to reopen the assessment under section 147 of the Act after obtaining necessary approval of the competent authority. Accordingly

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

24-12-2014 declaring total income of Rs. Gumnam Singh Kushwah 2,16,260. The assessment was originally completed under section 143(3) of the Act on 19-12-2016 determining total income at Rs. 9,86,530. The Learned AO noted in the assessment order that as per information available, the assessee had purchased residential plot

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)

1,08,00,000/- was made on account ‘excess salary’ paid to two employees u/s 40A(2b) of the Act. The said assessment was then subject matter of reassessment u/s 148 based on the reason to believe of the AO that the assessee had taken bogus purchase thro accommodation entries from one Sh. Md. Irfan. During reassessment proceedings

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)

1,08,00,000/- was made on account ‘excess salary’ paid to two employees u/s 40A(2b) of the Act. The said assessment was then subject matter of reassessment u/s 148 based on the reason to believe of the AO that the assessee had taken bogus purchase thro accommodation entries from one Sh. Md. Irfan. During reassessment proceedings

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)

1,08,00,000/- was made on account ‘excess salary’ paid to two employees u/s 40A(2b) of the Act. The said assessment was then subject matter of reassessment u/s 148 based on the reason to believe of the AO that the assessee had taken bogus purchase thro accommodation entries from one Sh. Md. Irfan. During reassessment proceedings

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

1,08,00,000/- was made on\naccount 'excess salary' paid to two employees u/s 40A(2b) of the Act.\nThe said assessment was then subject matter of reassessment u/s 148\nbased on the reason to believe of the AO that the assessee had taken\nbogus purchase thro accommodation entries from one Sh. Md. Irfan.\nDuring reassessment proceedings

ANIL KUMAR AGARWAL,AGRA vs. DCIT 2(1)(1), AGRA, AGRA

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh(Through Virtual Hearing) Anil Kumar Agarwal, Vs. Dy. Cit, 44, R. S. Residency, Circle-2(1)(1), Dayal Bagh, Agra, Up Agra (Appellant) (Respondent) Pan: Aampa3335J Assessee By : Shri Rajni Kant Verma, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 17/09/2025 Date Of Pronouncement 19/11/2025

Section 68 of the Act and completed the assessment on 24-12-2018. 4. The Learned JCIT(A) on perusal of the bank statement of the assessee and the explanations offered by the assessee with regard to receipt of cash on sale of property in the sum of Rs. 2 lakhs reproduced the availability of Anil Kumar Agarwal cash funds

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

reassessment notice u/s. 149 operate 3 | P a g e retrospectively for three years for all situation and six years in case the escaped assessment amounts to or is likely to amount to more than Rs.50 lacs. In the instant case, it is not disputed that consequent upon the directions issued by Hon’ble Supreme Court in Union of India