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-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

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

M/S VERMA SERVICE STATION,FIROZABAD vs. D.C.I.T., RANGE-5, FIROZABAD

In the result, the appeal of the assessee is dismissed

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

reassessment made by AO assessee again could not explain the source of capital introduction of Rs.92,00,000/- and hence the same was again treated as unaccounted income of the assessee under section 68 and added to the total income of the assessee. In the 2nd round of assessment,the assessee again could not explain the 4. source of capital

SMT. GARIMA MEHTA,GWALIOR vs. I.T.O., WARD-1(2), GWALIOR

In the result, the appeal is partly allowed

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

reassessment of the assessees claiming deduction under section 10A, it has been decided that the claim of deduction under section 10A of the Income-tax Act, shall not be denied to STP units only on the ground that the approval/registration to such units has been granted by the Directors of Software Technology Parks. However, it has to be ensured that

BIPIN BAU AGRAWAL,MATHURA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, AGRA, AGRA

In the result, appeals ITA Nos

Bench: : Shri M. Balaganesh & Shri Sunil Kumar Singh

reassess taking into consideration the other material in respect of completed assessments/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under section 132 or requisition under 5 | P a g e ITA Nos. 377, 378, 379 & 380/Agr/2025 section 132A of the Act, 1961. However, the completed/unabated assessment

BIPIN BABU AGRAWAL,MATHURA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, AGRA, AGRA

In the result, appeals ITA Nos

Bench: : Shri M. Balaganesh & Shri Sunil Kumar Singh

reassess taking into consideration the other material in respect of completed assessments/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under section 132 or requisition under 5 | P a g e ITA Nos. 377, 378, 379 & 380/Agr/2025 section 132A of the Act, 1961. However, the completed/unabated assessment

BIPIN BABU AGRAWAL,MATHURA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, AGRA, AGRA

In the result, appeals ITA Nos

Bench: : Shri M. Balaganesh & Shri Sunil Kumar Singh

reassess taking into consideration the other material in respect of completed assessments/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under section 132 or requisition under 5 | P a g e ITA Nos. 377, 378, 379 & 380/Agr/2025 section 132A of the Act, 1961. However, the completed/unabated assessment

BIPIN BABU AGRAWAL,MATHURA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, AGRA, AGRA

In the result, appeals ITA Nos

Bench: : Shri M. Balaganesh & Shri Sunil Kumar Singh

reassess taking into consideration the other material in respect of completed assessments/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under section 132 or requisition under 5 | P a g e ITA Nos. 377, 378, 379 & 380/Agr/2025 section 132A of the Act, 1961. However, the completed/unabated assessment

ITO WARD-1(1)(2), AGRA vs. MAMTA SINGH, AGRA

Bench: : Shri A.D. Jain & Shri Dr. Mitha Lal Meenaassessment Year: 2007-08 Income Tax Officer, Vs. Smt. Mamta Singh, Ward-1(1)(2), Agra 6, Amar Lok Colony, Opposite Jalma Hospital, Agra. (Appellant) Pan :Aobps 7284 K (Respondent)

42[l), the Assessee filed objection dated 17.01.2013 challenging the validity of notice/proceedings u/s148. b. the A.O. disposed of the 'objection' dated 17.01.2013 of the assessee before completion of assessment which is in conformity with the judicial pronouncement in the case of GKN Drishaft [India] Ltd. V/s DCIT [2003] 259 [SC], hence ITA 155/Agr/2018 & 3 CO No.36/A/2018 this case relied

RAJ SINGH,MATHURA vs. ITO-3(3), MATHURA

In the result appeal is allowed

Bench: Shri Sudhanshu Srivastava & Dr. Mitha Lal Meenashri. Raj Singh, Vs.. Income Tax Officer- 3(3), Village- Kharaut Chhata, Mathura Mathura. Pan: Akvpr1777Q (Appellant) (Respondent)

42,270/- 3. Before the learned CIT(A), assessee raised various grounds regarding validity of re-opening and that the addition on merits has wrongly been made, furnished various evidences in support of its claim. However, the learned CIT(A) rejected the assessee’s appeal both on legal grounds as well on merits and confirmed the assessment order as such

MAHESH EDIBLE OIL INDUSTRIES LIMITED,DELHI vs. ASSTT. COMMISSIONER OF INCOME TAX, AGRA

The appeal of the assessee stands partly allowed

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.113/Agr/2023 (िनधा"रणवष" / Assessment Year: 2013-14) & 2. आयकरअपीलसं./ Ita No.114/Agr/2023 (िनधा"रणवष" / Assessment Year: 2014-15) & 3. आयकरअपीलसं./ Ita No.115/Agr/2023 (िनधा"रणवष" / Assessment Year: 2015-16) & 4. आयकरअपीलसं./ Ita No.116/Agr/2023 (िनधा"रणवष" / Assessment Year: 2016-17) & 5. आयकरअपीलसं./ Ita No.117/Agr/2023 (िनधा"रणवष" / Assessment Year: 2017-18) & 6. आयकरअपीलसं./ Ita No.118/Agr/2023 (िनधा"रणवष" / Assessment Year: 2018-19) & 7. आयकरअपीलसं./ Ita No.119/Agr/2023 (िनधा"रणवष" / Assessment Year: 2019-20) M/S Mahesh Edible Oil Industries Ltd. Acit-Central Circle बनाम/ 3/14-A, Jungpura-B Agra. Vs. New Delhi – 110 014. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccm-7102-J (अपीलाथ"/Appellant) : (""थ" / Respondent) & 8. आयकरअपीलसं./ Ita No.157/Agr/2023 (िनधा"रणवष" / Assessment Year: 2013-14) &

42,68,751 68,22,031 5,43,77,066 54,58,13,054 36,17,16,578 108,13,44,591 Purchases It was observed by Ld. AO that the bogus purchases in respect to first two parties was compiled from the bank statements of the two concerns as the assessee did not produce the ledger of these

DEPUTY COMMISSIONER OF INCOME TAX, AGRA vs. MAHESH EDIBLE OIL INDUSTRIES LTD, DELHI

The appeal of the assessee stands partly allowed

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.113/Agr/2023 (िनधा"रणवष" / Assessment Year: 2013-14) & 2. आयकरअपीलसं./ Ita No.114/Agr/2023 (िनधा"रणवष" / Assessment Year: 2014-15) & 3. आयकरअपीलसं./ Ita No.115/Agr/2023 (िनधा"रणवष" / Assessment Year: 2015-16) & 4. आयकरअपीलसं./ Ita No.116/Agr/2023 (िनधा"रणवष" / Assessment Year: 2016-17) & 5. आयकरअपीलसं./ Ita No.117/Agr/2023 (िनधा"रणवष" / Assessment Year: 2017-18) & 6. आयकरअपीलसं./ Ita No.118/Agr/2023 (िनधा"रणवष" / Assessment Year: 2018-19) & 7. आयकरअपीलसं./ Ita No.119/Agr/2023 (िनधा"रणवष" / Assessment Year: 2019-20) M/S Mahesh Edible Oil Industries Ltd. Acit-Central Circle बनाम/ 3/14-A, Jungpura-B Agra. Vs. New Delhi – 110 014. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccm-7102-J (अपीलाथ"/Appellant) : (""थ" / Respondent) & 8. आयकरअपीलसं./ Ita No.157/Agr/2023 (िनधा"रणवष" / Assessment Year: 2013-14) &

42,68,751 68,22,031 5,43,77,066 54,58,13,054 36,17,16,578 108,13,44,591 Purchases It was observed by Ld. AO that the bogus purchases in respect to first two parties was compiled from the bank statements of the two concerns as the assessee did not produce the ledger of these

MAHESH EDIBLE OIL INDUSTRIES LIMITED,DELHI vs. ASSTT. COMMISSIONER OF INCOME TAX, AGRA

The appeal of the assessee stands partly allowed

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.113/Agr/2023 (िनधा"रणवष" / Assessment Year: 2013-14) & 2. आयकरअपीलसं./ Ita No.114/Agr/2023 (िनधा"रणवष" / Assessment Year: 2014-15) & 3. आयकरअपीलसं./ Ita No.115/Agr/2023 (िनधा"रणवष" / Assessment Year: 2015-16) & 4. आयकरअपीलसं./ Ita No.116/Agr/2023 (िनधा"रणवष" / Assessment Year: 2016-17) & 5. आयकरअपीलसं./ Ita No.117/Agr/2023 (िनधा"रणवष" / Assessment Year: 2017-18) & 6. आयकरअपीलसं./ Ita No.118/Agr/2023 (िनधा"रणवष" / Assessment Year: 2018-19) & 7. आयकरअपीलसं./ Ita No.119/Agr/2023 (िनधा"रणवष" / Assessment Year: 2019-20) M/S Mahesh Edible Oil Industries Ltd. Acit-Central Circle बनाम/ 3/14-A, Jungpura-B Agra. Vs. New Delhi – 110 014. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccm-7102-J (अपीलाथ"/Appellant) : (""थ" / Respondent) & 8. आयकरअपीलसं./ Ita No.157/Agr/2023 (िनधा"रणवष" / Assessment Year: 2013-14) &

42,68,751 68,22,031 5,43,77,066 54,58,13,054 36,17,16,578 108,13,44,591 Purchases It was observed by Ld. AO that the bogus purchases in respect to first two parties was compiled from the bank statements of the two concerns as the assessee did not produce the ledger of these

MAHESH EDIBLE OIL INDUSTRIES LIMITED,DELHI vs. ASSTT. COMMISSIONER OF INCOME TAX, AGRA

The appeal of the assessee stands partly allowed

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.113/Agr/2023 (िनधा"रणवष" / Assessment Year: 2013-14) & 2. आयकरअपीलसं./ Ita No.114/Agr/2023 (िनधा"रणवष" / Assessment Year: 2014-15) & 3. आयकरअपीलसं./ Ita No.115/Agr/2023 (िनधा"रणवष" / Assessment Year: 2015-16) & 4. आयकरअपीलसं./ Ita No.116/Agr/2023 (िनधा"रणवष" / Assessment Year: 2016-17) & 5. आयकरअपीलसं./ Ita No.117/Agr/2023 (िनधा"रणवष" / Assessment Year: 2017-18) & 6. आयकरअपीलसं./ Ita No.118/Agr/2023 (िनधा"रणवष" / Assessment Year: 2018-19) & 7. आयकरअपीलसं./ Ita No.119/Agr/2023 (िनधा"रणवष" / Assessment Year: 2019-20) M/S Mahesh Edible Oil Industries Ltd. Acit-Central Circle बनाम/ 3/14-A, Jungpura-B Agra. Vs. New Delhi – 110 014. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccm-7102-J (अपीलाथ"/Appellant) : (""थ" / Respondent) & 8. आयकरअपीलसं./ Ita No.157/Agr/2023 (िनधा"रणवष" / Assessment Year: 2013-14) &

42,68,751 68,22,031 5,43,77,066 54,58,13,054 36,17,16,578 108,13,44,591 Purchases It was observed by Ld. AO that the bogus purchases in respect to first two parties was compiled from the bank statements of the two concerns as the assessee did not produce the ledger of these