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, show cause notice, dated 09.04.2024 was issued u/s 263, wherein the PCIT stated that Md. Irfan had entered into huge sale transactions with the assessee and the amount as remitted by HMA Agro Industries Ltd. to Sh. Md. Irfan was immediately withdrawn in cash from his account and in some cases, the funds were transferred to other accounts

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, show cause notice, dated 09.04.2024 was issued u/s 263, wherein the PCIT stated that Md. Irfan had entered into huge sale transactions with the assessee and the amount as remitted by HMA Agro Industries Ltd. to Sh. Md. Irfan was immediately withdrawn in cash from his account and in some cases, the funds were transferred to other accounts

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

reassessment, after recording Md. Irfan's statement. However, the Principal Commissioner of Income Tax (PCIT) initiated revision proceedings u/s 263, believing the AO had not conducted proper inquiries. The PCIT set aside the assessment order, directing fresh inquiries.", "held": "The Tribunal held that the PCIT erred in invoking Section

M/S UMA GLASS WORKS ,FIROZABAD vs. PR.CIT.-1, AGRA

In the result, both the appeals of the assessee for AYs 2014-15 and

Bench: Shri Anil Chaturvedi & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A Nos.17 & 18/Agra/2021 िनधा"रणवष"/Assessment Years:2014-15 & 2015-16 बनाम M/S Uma Glass Works Pcit, 22, Near Industrial Estate, Vs. Agra-1, Firozabad - 283203 Uttar Pradesh.

Section 263 of the Act was wholly erroneous. 24. As noticed above, the Assessing Officer while completing the reassessment proceedings

M/S UMA GLASS WORKS,AGRA vs. PR.CIT.-1, AGRA

In the result, both the appeals of the assessee for AYs 2014-15 and

Bench: Shri Anil Chaturvedi & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A Nos.17 & 18/Agra/2021 िनधा"रणवष"/Assessment Years:2014-15 & 2015-16 बनाम M/S Uma Glass Works Pcit, 22, Near Industrial Estate, Vs. Agra-1, Firozabad - 283203 Uttar Pradesh.

Section 263 of the Act was wholly erroneous. 24. As noticed above, the Assessing Officer while completing the reassessment proceedings

M/S RADHARANI JEWELLERS LIMITED,DELHI vs. DCIT, CENTRAL CIRCLE, AGRA

In the result, both the appeals of the assessee are allowed for statistical purposes

Bench: Shri M. Balaganesh

263 of the Income Tax Act, 1961 [hereinafter referred to as the ‘Act’] dated 31-3-2023 for the Assessment Year 2017-18. 1.1. The appeal in ITA No. 7/Agr/2026 is against the order of the Learned Commissioner of Income Tax (Appeals) , Kanpur-4 [hereinafter referred to as the Learned CITA] in Appeal No. CIT(A)-IV/KNP/11138/2017-18 dated

M/S RADHARANI JEWELLERS LIMITED,DELHI vs. DCIT, CENTRAL CIRCLE, AGRA

In the result, both the appeals of the assessee are allowed for statistical purposes

Bench: Shri M. Balaganesh

263 of the Income Tax Act, 1961 [hereinafter referred to as the ‘Act’] dated 31-3-2023 for the Assessment Year 2017-18. 1.1. The appeal in ITA No. 7/Agr/2026 is against the order of the Learned Commissioner of Income Tax (Appeals) , Kanpur-4 [hereinafter referred to as the Learned CITA] in Appeal No. CIT(A)-IV/KNP/11138/2017-18 dated

SMT. SARIKA SRIVASTAVA,AGRA vs. PCIT-1, AGRA, AGRA

The appeals of the assessees are allowed in above terms

Bench: : Smt. Annapurna Gupta & Shri Sunil Kumar Singhassessment Year: 2012-13

section 263 of the Act. He further contended that there is no bar on the Assessing Officer for exploring other issues in reassessment

SHRI ATUL SRIVASTAVA,AGRA vs. PCIT-1, AGRA, AGRA

The appeals of the assessees are allowed in above terms

Bench: : Smt. Annapurna Gupta & Shri Sunil Kumar Singhassessment Year: 2012-13

section 263 of the Act. He further contended that there is no bar on the Assessing Officer for exploring other issues in reassessment

AJIT SINGH,SHIVPURI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, GWALIOR

In the result, assessee’s appeal ITA No 263/Agr/2025 is allowed

reassessment order before ld CIT(A) who allowed assessee’s appeal vide order dated 18.03.2024. Meantime, this tribunal, vide order dated 20.09.2023, passed in ITA No 43/Agr/2020 (A.Y. 2010-11), set aside the original revisional order dated 26.03.2020 passed u/s. 263 of the Act and remitted the matter back to the file of ld PCIT for passing order a fresh

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

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

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

In the result, the assessee’s appeal is allowed

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

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 shall be passed by an Assessing Officer below the rank of Joint Commissioner in respect of each assessment year referred to in clause (b) of [subsection (1) of] section 153A or the assessment year referred to in clause (b) of sub-section (1) of section 153B, except with the prior approval of the Joint Commissioner]." The above provisions

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 shall be passed by an Assessing Officer below the rank of Joint Commissioner in respect of each assessment year referred to in clause (b) of [subsection (1) of] section 153A or the assessment year referred to in clause (b) of sub-section (1) of section 153B, except with the prior approval of the Joint Commissioner]." The above provisions

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 shall be passed by an Assessing Officer below the rank of Joint Commissioner in respect of each assessment year referred to in clause (b) of [subsection (1) of] section 153A or the assessment year referred to in clause (b) of sub-section (1) of section 153B, except with the prior approval of the Joint Commissioner]." The above provisions

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 shall be passed by an Assessing Officer below the rank of Joint Commissioner in respect of each assessment year referred to in clause (b) of [subsection (1) of] section 153A or the assessment year referred to in clause (b) of sub-section (1) of section 153B, except with the prior approval of the Joint Commissioner]." The above provisions

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 shall be passed by an Assessing Officer below the rank of Joint Commissioner in respect of each assessment year referred to in clause (b) of [subsection (1) of] section 153A or the assessment year referred to in clause (b) of sub-section (1) of section 153B, except with the prior approval of the Joint Commissioner]." The above provisions