PANKAJ SUJORIA,MANSAROVAR COLONY vs. ITO 1(1), GWL, GWALIOR

In the result, the appeal of the Assessee is allowed

Bench: Shri M. Balaganesh(Through Virtual Hearing) Pankaj Sujoria, Vs. Ito, A-481, Mansarovar Ward-1(1), Colony, Shahpura, Gwalior Bhopal, Mp (Appellant) (Respondent) Pan: Arzps0280L Assessee By : None Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 17/11/2025 Date Of Pronouncement 26/11/2025

28-03-2018 which was duly served on the Assessee on 31-03-2018. No return has been filed by the Assessee in response to notice issued under section 148 of the Act. Ultimately, the reassessment

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

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

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\nof unexplained money u/s 69A in respect of credits in the bank account in the\nsum of Rs. 28

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

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

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\nof unexplained money u/s 69A in respect of credits in the bank account in the\nsum of Rs. 28

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

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

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\nof unexplained money u/s 69A in respect of credits in the bank account in the\nsum of Rs. 28

BHAGIRATH PAKHARIA,JHANSI vs. WARD 2 (3)(1), JHANSI

28-02-2024 which\nstood confirmed by Ld. CIT(A) in order dated 25-10-2024. The Ld. AR\nstated that the issue is of valuation only and the assessee has already\nfiled rectification application u/s 154 against the assessment order which\nis pending. The same would have material bearing on the penalty appeal.\nConsidering the same, we restore

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 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

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, 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

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

Section 151 of the Act clearly stipulates that the Commissioner of Income-tax (Appeals), who is the competent authority to authorize the reassessment notice, has to apply his mind and form an opinion. The mere appending of the expression "approved" says nothing. It is not as if the Commissioner of Income-tax (Appeals) has to record elaborate reasons for agreeing

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

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 The assessee has filed this appeal against the order of the learned Commissioner of Income-tax (Appeals)-2, Mumbai dated

NEERAJ KUMAR,AGRA vs. INCOME TAX OFFICER WARD 2(1)(3), AGRA, AGRA

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

Bench: Shri M. Balaganeshneeraj Kumar, Vs. Income Tax Officer, 18/24, Ghadi Hussaini Ward-2(1)(3), Prakash Nagar, Agra Agra (Appellant) (Respondent) Pan: Ajwpn8393C Assessee By : Shri Jitendra Garg, Adv Shri Pradumn Garg, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 03/02/2026

reassessment is void ab initio 4. Because the assessment framed ex-parte under section 147/144 is bad in law, since notices were never served at the correct address and the appellant was denied proper opportunity of being heard. 5. Because the reopening under section 147 is mechanical, without application of mind, based on no new tangible material, and in violation

SH. MANOJ GOYAL ,AGRA vs. DY CIT,CC,, AGRA

The appeals stand allowed in terms of our above order

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपील सं. / Ita No.185/Agr/2019 (िनधा"रणवष" / Assessment Year: 2011-12) & 2. आयकरअपील सं. / Ita No.186/Agr/2019 (िनधा"रणवष" / Assessment Year: 2012-13) & 3. आयकरअपील सं. / Ita No.187/Agr/2019 (िनधा"रणवष" / Assessment Year: 2011-12) & 4. आयकरअपील सं. / Ita No.188/Agr/2019 (िनधा"रणवष" / Assessment Year: 2012-13) Shri Manoj Goyal बनाम/ Dcit Central Circle 22, Nehru Nagar, Agra – 282002 Agra Vs. "थायीलेखासं./जीआइआरसं./Tan/Gir No. Abcpg-3816-F (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Anurga Sinha (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Shri Sukesh Kumar Jain (Cit) – Ld. Cit-Dr सुनवाईकीतारीख/Date Of Hearing : 21-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 28-03-2025

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the[Principal Commissioner or] Commissioner under sub-section (12) of section 144BA." 11. The Tribunal while quashing the assessment order had relied upon its earlier decision in Navin Jain and Others (supra) wherein a detailed discussion has been made

SH. MANOJ GOYAL,AGRA vs. DY CIT,CC, AGRA

The appeals stand allowed in terms of our above order

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपील सं. / Ita No.185/Agr/2019 (िनधा"रणवष" / Assessment Year: 2011-12) & 2. आयकरअपील सं. / Ita No.186/Agr/2019 (िनधा"रणवष" / Assessment Year: 2012-13) & 3. आयकरअपील सं. / Ita No.187/Agr/2019 (िनधा"रणवष" / Assessment Year: 2011-12) & 4. आयकरअपील सं. / Ita No.188/Agr/2019 (िनधा"रणवष" / Assessment Year: 2012-13) Shri Manoj Goyal बनाम/ Dcit Central Circle 22, Nehru Nagar, Agra – 282002 Agra Vs. "थायीलेखासं./जीआइआरसं./Tan/Gir No. Abcpg-3816-F (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Anurga Sinha (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Shri Sukesh Kumar Jain (Cit) – Ld. Cit-Dr सुनवाईकीतारीख/Date Of Hearing : 21-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 28-03-2025

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the[Principal Commissioner or] Commissioner under sub-section (12) of section 144BA." 11. The Tribunal while quashing the assessment order had relied upon its earlier decision in Navin Jain and Others (supra) wherein a detailed discussion has been made

SH. MANOJ GOYAL,AGRA vs. DY CIT ,CC, AGRA

The appeals stand allowed in terms of our above order

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपील सं. / Ita No.185/Agr/2019 (िनधा"रणवष" / Assessment Year: 2011-12) & 2. आयकरअपील सं. / Ita No.186/Agr/2019 (िनधा"रणवष" / Assessment Year: 2012-13) & 3. आयकरअपील सं. / Ita No.187/Agr/2019 (िनधा"रणवष" / Assessment Year: 2011-12) & 4. आयकरअपील सं. / Ita No.188/Agr/2019 (िनधा"रणवष" / Assessment Year: 2012-13) Shri Manoj Goyal बनाम/ Dcit Central Circle 22, Nehru Nagar, Agra – 282002 Agra Vs. "थायीलेखासं./जीआइआरसं./Tan/Gir No. Abcpg-3816-F (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Anurga Sinha (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Shri Sukesh Kumar Jain (Cit) – Ld. Cit-Dr सुनवाईकीतारीख/Date Of Hearing : 21-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 28-03-2025

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the[Principal Commissioner or] Commissioner under sub-section (12) of section 144BA." 11. The Tribunal while quashing the assessment order had relied upon its earlier decision in Navin Jain and Others (supra) wherein a detailed discussion has been made

SANSKAR NAGAR,JHANSI vs. ADDITIONAL COMMISSIONER OF INCOME TAX, KANPUR

Appeals stands allowed

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.351/Agr/2024 (िनधा"रणवष" / Assessment Year: 2014-15) & 2. आयकरअपीलसं./ Ita No.352/Agr/2024 (िनधा"रणवष" / Assessment Year: 2015-16) & 3. आयकरअपीलसं./ Ita No.353/Agr/2024 (िनधा"रणवष" / Assessment Year: 2016-17) & 4. आयकरअपीलसं./ Ita No.354/Agr/2024 (िनधा"रणवष" / Assessment Year: 2017-18) & 5. आयकरअपीलसं./ Ita No.349/Agr/2024 (िनधा"रणवष" / Assessment Year: 2018-19; Smc Bench) & 6. आयकरअपीलसं./ Ita No.346/Agr/2024 (िनधा"रणवष" / Assessment Year: 2016-17; Smc Bench) & 7. आयकरअपीलसं./ Ita No.347/Agr/2024 (िनधा"रणवष" / Assessment Year: 2016-17; Smc Bench) & 8. आयकरअपीलसं./ Ita No.348/Agr/2024 (िनधा"रणवष" / Assessment Year: 2017-18; Smc Bench) & 9. आयकरअपीलसं./ Ita No.350/Agr/2024

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the [Principal Commissioner or] Commissioner under sub-section (12) of section 144BA. 12. The Tribunal while quashing the assessment order had relied upon its earlier decision in Navin Jain (supra) wherein a detailed discussion has been made with regard

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

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

Bench: Shri M. Balaganesh(Through Virtual Hearing)

reassessment was completed u/s 147 read with Section 144B of the Act on 26.03.2022 wherein, loss from house property of Rs. 52,567/- was disallowed apart from making addition on account of unexplained money u/s 69A in respect of credits in the bank account in the sum of Rs. 28