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

Section 148 and the entire reassessment proceedings initiated pursuant thereto are liable to be quashed as void ab initio. 3.1 Reliance may be placed on the following decisions: (a) S. Goyanka Lime and Chemicals Ltd., (2015) 56

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

Section 148 and the entire reassessment proceedings initiated pursuant thereto are liable to be quashed as void ab initio. 3.1 Reliance may be placed on the following decisions: (a) S. Goyanka Lime and Chemicals Ltd., (2015) 56

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

56,407/- The appellant craves leave to add, alter or vary the grounds of appeal before or at the time of hearing.” 3. Brief facts of the case are that the assessee filed return of income on 11.07.2012, declaring total income of Rs.8,16,230/-. Case of the assessee was reopened by the Revenue for framing reassessment by invoking provisions

SMT. BINA WADHWA,AGRA vs. ITO WARD 1(1)(1), AGRA

In the result, the appeal is allowed for statistical purposes

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meenaassessment Year: 2010-11

section, cannot be used for the purpose of initiating reassessment proceedings, in my opinion, is not correct.” We do not find any error in the decision of the ld. CIT(A) and accordingly, grounds Nos. 1.1 to 1.4 are dismissed. 7. Grounds Nos. 2.1 to 2.3 are on merits. The assessee, Smt. Bina Wadhva filed the return of income declaring

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

In the result, the appeal of the Assessee is allowed

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh (Through Virtual Hearing) Anju Agarwal, Vs. Income Tax Officer, D-26, Kamla Nagar, Ward-2(1)(1), Agra Agra (Appellant) (Respondent) Pan: Awtpa4297L Assessee By : Shri K. K. Jain, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 16/09/2025 Date Of Pronouncement 04/12/2025

reassessment stood completed under Section 147 r.w.s. 144B of the Act on 23-3- 2024 determining total income of the Assessee at Rs. 56

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

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

reassessment of income of the other person would be in accordance with the provisions of section 153A and also relied upon the judgments of "Supreme Court" in the case that the block period proceedings u/s 153C of the Act has to be computed from the date of receipt of books of accounts or documents

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

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

56 taxmann.com 390 (MP HC). The Special Leave Petition (SLP) filed by the revenue against this decision was dismissed by the Hon'ble Supreme Court reported in 64 taxmann.com 313. Further, I find that the Hon‟ble Delhi High court in the case of PCIT Vs. NC Cables Ltd reported in 391 ITR 11 (Del) had also held the same

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

In the result, the assessee’s appeal is allowed

reassessment proceedings deserve to be quashed.” 3. The additional ground as preliminary issue raised by the appellant assessee, challenging the validity of assumption of jurisdiction u/s. 147 of the Act by the ld A.O. being passed on mechanical approval u/s. 151 of the Act, goes to the root of the matter. We deem it fit to address the same first

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

In the result, the appeal is allowed

Bench: Shri A. D. Jain

section 151, the initiation of reassessment proceedings after more than four years was clearly barred by time.” The ratio decidendi of both the decisions of the Hon’ble Jurisdictional High 23. Court evidently is that in the absence of anything in the reasons recorded to suggest that the income chargeable to tax which has escaped assessment is one lac rupees

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. 5,50,000/- on account of alleged unaccounted cash payments made to Omaxe Group by the Assessee during the year under consideration. This action of the Learned

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

reassessment proceedings, the Assessee explained that the jewellery belonged to the company and had been sent for repolishing / job work to M/s Vijay Enterprises, Rajkot. The transaction was duly recorded in the books of accounts and supported by documentary evidences. However, the Learned AO rejected the explanation mainly on the ground that Form - 403 was generated after interception and concluded

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

reassessment proceedings, the Assessee explained that the jewellery belonged to the company and had been sent for repolishing / job work to M/s Vijay Enterprises, Rajkot. The transaction was duly recorded in the books of accounts and supported by documentary evidences. However, the Learned AO rejected the explanation mainly on the ground that Form - 403 was generated after interception and concluded

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

reassessment completed u/s 147 read with section 143(3) in respect of purchases of ‘Raw Boneless Meat’, which has been treated as bogus. The assessee contended before the Assessing Officer that no purchases of ‘Raw Boneless Meat’ have been made and, in fact, certain purchases have been made by the “HMA Agro Industries Ltd.”, which is a separate assessee

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

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singh

reassessment completed u/s 147 read with section 143(3) in respect of purchases of 'Raw Boneless Meat', which has been treated as bogus. The assessee contended before the Assessing Officer that no purchases of 'Raw Boneless Meat' have been made and, in fact, certain purchases have been made by the "HMA Agro Industries Ltd.", which is a separate assessee

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

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singh

reassessment completed u/s 147 read with section 143(3) in respect of purchases of 'Raw Boneless Meat', which has been treated as bogus. The assessee contended before the Assessing Officer that no purchases of 'Raw Boneless Meat' have been made and, in fact, certain purchases have been made by the "HMA Agro Industries Ltd.", which is a separate assessee