BADARIPRASAD,GUNA vs. INCOME TAX OFFICER GUNA, GUNA

In the result, appeal filed by the assessee is allowed

Bench: Shri M. Balaganeshbadriprasad, Vs. Income Tax Officer, Heerabagh Colony, Guna, Guna, Gwalior Gwalior (Appellant) (Respondent) Pan: Arapr6314B

reassessment then the same would equally apply for issuance of notice under Section 148 of the Act. (iii) The conclusion at the bottom of page 2 in paragraph 3 of the Office Memorandum that "Therefore, as provided in the scheme the notice under section 148 of the Act is issued on automated allocation of cases to the Assessing Officer based

NARAYANI RATHORE,SHIVPURI vs. ASSESSMENT UNIT,INCOME TAX DEPARTMENT, DELHI

In the result, appeal filed by the assessee is allowed

Bench: Shri M. Balaganeshnarayani Rathore, Vs. Assessment Unit, Peeroth Shivpuri, Income Tax Shivpuri, Mp Department, National Faceless Appeal Centre, Delhi (Appellant) (Respondent) Pan: Dhgpr1886H

reassessment then the same would equally apply for issuance of notice under Section 148 of the Act. (iii) The conclusion at the bottom of page 2 in paragraph 3 of the Office Memorandum that "Therefore, as provided in the scheme the notice under section 148 of the Act is issued on automated allocation of cases to the Assessing Officer based

ASHOK SAHU,JHANSI vs. INCOME TAX OFFICER, WARD 2(3)(1), JHANSI, JHANSI

In the result, appeal filed by the assessee is allowed

Bench: Shri M. Balaganeshashok Sahu, Vs. Income Tax Officer, Purana Bazar, Chirgaon, Ward-2(3)(1), Jhansi Jhansi (Appellant) (Respondent) Pan: Jgsps3446H Sunita, Vs. Assessment Unit, Ward No. 2, Chobyana Income Tax Talrehat Lake View Department, Camp, Lalitpur, Lalitpur, National Faceless Up Appeal Centre, Delhi (Appellant) (Respondent) Pan: Jgps3438H

reassessment then the same would equally ITA No. 432/AGR/2025 apply for issuance of notice under Section 148 of the Act. (iii) The conclusion at the bottom of page 2 in paragraph 3 of the Office Memorandum that "Therefore, as provided in the scheme the notice under section 148 of the Act is issued on automated allocation of cases

SUNITA,SAHU vs. ASSESSMENT UNIT,INCOME TAX DEPARTMENT, DELHI

In the result, appeal filed by the assessee is allowed

Bench: Shri M. Balaganeshashok Sahu, Vs. Income Tax Officer, Purana Bazar, Chirgaon, Ward-2(3)(1), Jhansi Jhansi (Appellant) (Respondent) Pan: Jgsps3446H Sunita, Vs. Assessment Unit, Ward No. 2, Chobyana Income Tax Talrehat Lake View Department, Camp, Lalitpur, Lalitpur, National Faceless Up Appeal Centre, Delhi (Appellant) (Respondent) Pan: Jgps3438H

reassessment then the same would equally ITA No. 432/AGR/2025 apply for issuance of notice under Section 148 of the Act. (iii) The conclusion at the bottom of page 2 in paragraph 3 of the Office Memorandum that "Therefore, as provided in the scheme the notice under section 148 of the Act is issued on automated allocation of cases

MR. TASAVVER HUSAIN,FARRUKHABAD vs. ACIT, FARRUKHABAD

In the result, appeal filed by the assessee is allowed

Bench: :Smt. Annapurna Gupta & Shri Sunil Kumar Singh

5 | P a g e ITA No.95& 96/Agr/2023 where no return of income has been furnished or where return has been furnished for the first time under section 148; (f) the amount of deemed total income reassessed

MR. TASAVVER HUSAIN,FARRUKHABAD vs. ACIT , FARRUKHABAD

In the result, appeal filed by the assessee is allowed

Bench: :Smt. Annapurna Gupta & Shri Sunil Kumar Singh

5 | P a g e ITA No.95& 96/Agr/2023 where no return of income has been furnished or where return has been furnished for the first time under section 148; (f) the amount of deemed total income reassessed

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

Sections 147/143(3) of the Act. 5. Aggrievedby the above said order, the assessee preferred appeal before the learned CIT(A), where the assessee filed detailed submissions both on validity of reassessment

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

Sections 147/143(3) of the Act. 5. Aggrievedby the above said order, the assessee preferred appeal before the learned CIT(A), where the assessee filed detailed submissions both on validity of reassessment

RADHIKA GARG,HATHRAS vs. INCOME TAX OFFICER, WARD-2(1)(3), AGRA

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh(Through Virtual Hearing) Radhika Garg, Vs. Income Tax Officer, 14/100, Kambhu Tola Ward-2(1)(3), Hospital Road, Hathras, Up Agra (Appellant) (Respondent) Pan:Afepg2999H Assessee By : Shri Anurag Sinha, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 17/09/2025 Date Of Pronouncement 19/11/2025

section seeks to cure and it is not intended to cure complete absence of notice itself. 5. In the instant case, even though the assessee had filed the return just 7 days before the completion of reassessment

RAJESH TYAGI,AMBAH vs. ITO WARD 1, MORENA, MORENA

In the result, appeal filed by the assessee is allowed for statistical purpose

Bench: : Shri S. Rifaur Rahmanassessment Year: 2020-21 Rajesh Tyagi Vs. Assessment Unit, S/O Laxmi Narayan Tyagi Gavri National Faceless Assessment Service, Gulab Ka Pura Ambah Centre, Income Tax Officer, Distt. Morena Ward-1, Morena Pan : Bmmpt3132K (Appellant) (Respondent) Assessee By Sh. Sandeep, Ca Department By Shri Anil Kumar, Sr. Dr Date Of Hearing 17.02.2026 Date Of Pronouncement 17.02.2026 Order

5. BECAUSE the proceedings under section 147 have neither been validly initiated nor concluded in accordance with the provisions of law and the assessment order passed in pursuance thereof is liable to be declared void-ab- initio. 6. BECAUSE in the absence of valid service of notice under section 148, the reassessment

SH. YUGAL KISHOR AGARWAL,AGRA vs. DCIT, CIRCLE 4(3)(1), ETAH

In the result, appeal filed by the assessee is allowed

Bench: : Shri Ramit Kocharassessment Year: 2012-13

reassessment order u/s 147 read with Section 143(3) dated 24.10.2019, the Assessing Officer made two additions – firstly, disallowance of Rs.12,15,413/- claimed by the assessee as expenditure against income from other sources by invoking provision of Section 57(iii) of the Act as the assessee could not furnish any evidences in respect of these expenses , and secondly disallowance

JAY SINGH,MORENA vs. ITO-1, MORENA

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

Bench: Shri M. Balaganesh(Through Virtual Hearing) Jay Singh, Vs. Ito, Gram Khaneta, Maharajpur, Ward-1, Morena, Madhya Pradesh Morena (Appellant) (Respondent) Pan: Cfwps1529H

section 148 of the Act on 29-3-2017, which stood served upon the assessee on 5-4-2017. In the reassessment

SARVESH KUMAR,FARRUKHABAD vs. INCOME TAX OFFICER WARD 4(2)(2) FARRUKHABAD, FARRUKHABAD

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh(Through Virtual Hearing) Sarvesh Kumar, Vs. Ito, Okharu Khanpur, Ward-4(2)(2), Farrukhabad, Fatehgarh, Farrukhabad Ho 209601 (Appellant) (Respondent) Pan: Dsqpk3348G Assessee By : Shri Swaran Singh, Ca Shri Shailesh Gupta, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 18/08/2025 Date Of Pronouncement 18/11/2025

section 148 is a must.” 5. Since in the instant case, the assessment has been framed u/s 144 of the Act on 28.11.2019 based on unsigned notice u/s 142(1) notice dated Sarvesh Kumar 29.03.2018, and no reassessment

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)

reassessment order passed under Section 147 r.w.s. 144 is void ab initio because same was framed on duplicate PAN of the appellant while appellant assessed on original PAN. Thus Ld. CIT(A) erred in not deciding to such matter required under the law. 3. On the facts and circumstances of the case, the Commissioner of Income Tax (Appeals) has erred

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

In the result, the appeal of the Assessee is allowed

section 147 of the Income-tax Act based on shared information regarding a payment of Rs. 5,50,000/- made in unaccounted cash to Omaxe Group for a project. The reassessment

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

5. --- Further the report submitted by him under Section 151(2) does not mention any reason for coming to the conclusion that it is a fit case for the issue of a notice under section 148. We are also of the opinion that the Commissioner has mechanically accorded permission. He did not himself record that he was satisfied that this

NEETA AGARWAL,AGRA vs. INCOME TAX OFFICER, 2(1)(2), AGRA, AGRA

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

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh(Through Virtual Hearing) Neeta Agarwal, Vs. Income Tax Officer, E-23, New Agra, Agra Ward-2(1)(2), Agra (Appellant) (Respondent) Pan: Aaxpa0936E Assessee By : Shri Amit Goyal, Adv Shri Nitin Goyal, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 16/09/2025 Date Of Pronouncement 04/12/2025

Section 69C of the Act in the reassessment proceedings. Since there was no appearance made by the Assessee before the Learned NFAC, the appeal filed by the Assessee was dismissed ex parte by upholding the findings of the Learned AO. 5

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

reassessment proceedings initiated under sections 147 to 151 were invalid and void ab initio as the mandatory pre-conditions were not fulfilled and no valid approval under section 151 was obtained. 5

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