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

Reassessment in such a case amount to a change of opinion, not permissible under the Act. 2.6 The Office Note of the ld. Assessing Officer to the assessment order passed under section 143(3) is reproduced as under. Office Note 1. No AIR/CIB information was available in this case. 2. The first reason for selection of the case under CASS

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

Reassessment in such a case amount to a change of opinion, not permissible under the Act. 2.6 The Office Note of the ld. Assessing Officer to the assessment order passed under section 143(3) is reproduced as under. Office Note 1. No AIR/CIB information was available in this case. 2. The first reason for selection of the case under CASS

ANURAG MITTAL ,FIROZABAD vs. DCIT CENTRAL CIRCLE, AGRA

In the result, both the appeals of the assessee are allowed

Bench: Shri Laliet Kumar & Dr. Mitha Lal Meena

reassessment order, as the case maybe, is required to be passed by the Assessing Officer with the prior approval of the Commissioner under sub-section (12) of section 144BA." 12. The Legislative intent can be gathered from the CBDT Circular No. 3 of 2008, dated 12.3.2008 which read as under: "50

RAJESH LADHANI,FAIZABAD vs. DCIT CC , AGRA

In the result, all three appeals of the assessee are allowed

Bench: Shri Laliet Kumar & Dr. Mitha Lal Meenaita No. 106,107 & 108/Agra/2019 Assessment Year: 2008-09 & 2011-12 Vs. Dy. C.I.T. –Central Circle, Rajesh Ladhani, 259, Savera Bhawan, Ram Nagar Colony, Agra. Faizabad. Pan: Abapl5646C (Appellant) (Respondent)

50. Assessment of search cases Orders of assessment and reassessment to be approved by the Joint Commissioner. 50.1 The existing provisions of making assessment and reassessment in cases where search has been conducted under section

USHA AGARWAL,AGRA vs. ITO 4(4), AGRA

In the result, the appeal is allowed

Bench: Shri A. D. Jain

50-C of the Act; that however, in the reasons recorded, nowhere the amount of escapement is quantified and it is also not mentioned that the escapement is of more than Rs.1,00,000/-; that therefore, the present case stands on a weeker footing, as in the case under consideration, besides non quantification of income, the assessee has wrongly been

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

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

50,40,273/-. The A.O. issued enquiry letter u/s 133(6) of the Act, but the deceased Assessee Late Sh. Tej Singh did not reply the same. After obtaining statutory sanction u/s 151 of the Act, a notice u/s 148 was issued by the A.O. The reasons for issuing notice dated 30/03/2016 u/s 148 of the Act reads as under

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

50,000/- in bank account during the year under consideration, the case of the Assessee was sought to be reopened under section 147 of the Act vide issuance of notice under section 148 of the Act on 28-03-2018 which was duly served on the Assessee on 31-03-2018. No return has been filed by the Assessee

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

Bench: Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

50 were seized from the search of Pushpanjali Constructions Pvt. Ltd., Pushpanjali Hospital and Research Centre Pvt. Ltd. and P.P. Buildcon Pvt. Ltd. at premises Pushpanjali Palace, Delhi Gate, Agra. 5. 20.07.2015 The case of the assessee was transferred to the DCIT, Central Circle, Agra vide order passed under section 127 of the Income

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

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

Bench: Shri M. Balaganesh(Through Virtual Hearing)

reassessment was later completed under Section 147 of the Act on 1-3-2025 determining total income of the Assessee at Rs. 8,52,110/- after making an addition of Rs. 5,50

ACIT,CC, AGRA, AGRA vs. M/S FEDERAL AGRO INDUSTRIES PVT. LTD.,, NEW DELHI

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singh

50,58,565/- has been deleted by the CIT(A). 4. The facts in brief are that the Assessing Officer has made the addition in reassessment completed u/s 147 read with section

ACIT, CC, AGRA, AGRA vs. M/S FEDERAL AGRO INDUSTRIES PVT. LTD.,, NEW DELHI

In the result, appeal filed by the revenue is dismissed

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singh

50,58,565/- has been deleted by the CIT(A). 4. The facts in brief are that the Assessing Officer has made the addition in reassessment completed u/s 147 read with section

ACIT-CC, AGRA, AGRA vs. M/S FEDERAL AGRO INDUSTRIES PVT. LTD., NEW DELHI

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singh

50,58,565/- has been deleted by the CIT(A). 4. The facts in brief are that the Assessing Officer has made the addition in reassessment completed u/s 147 read with section

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

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, notice under section 148 of the Act stood issued to the Assessee on 30-3-2021, which was duly served

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**

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. 28,20,500 and denying deduction under Chapter

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**

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. 28,20,500 and denying deduction under Chapter