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

reassessment order passed under section 147 r.w.s. 144 & 144B of the Act is bad in law, invalid and void-ab-initio. 7. BECAUSE under the facts and circumstance and in law the Assessing Officer has erred in making addition of Rs. 5,60

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

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

60,273/-’. Page 4 of 23 Tej Singh vs. ITO 4. Aggrieved by the assessment order dated 29/12/2016, the legal heirs of the assessee preferred an appeal before the CIT(A) , the Ld. CIT(A) vide order dated 20/11/2017 upheld the validity of the assessment order and directed the A.O. to allow the cost of acquisition of the property

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 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

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 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-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 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, 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

SHREE RAMRAJA HOMES PVT.LTD,JHANSI vs. DCIT,CIRCLE 2(1)(1), AGRA

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

Bench: Shri Sunil Kumar Singh & Shri Manish Agarwaldcit, Shree Ramraja Homes Circle-2(1)(1), Pvt. Ltd., Vs. Sanjay Place, Agra. 7, Om Building, New Road, Jhansi, Uttar Pradesh- 284002 Pan-Aapcs3955G (Appellant) (Respondent) Assessee By Shri Utsav Sehgal, Ca Department By Shri Shailendra Srivastava. Sr. Dr Date Of Hearing 22/05/2025 Date Of Pronouncement 24/06/2025 O R D E R [ Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac) Delhi [‘Ld. Cit(A) In Short] Dated 28.03.2024, In Appeal No. Nfac/2016-17/10165707 For Assessment Year 2017- 18 Arising Out Of The Order Passed U/S 147 R.W.S 144 Of The Income Tax Act, 1961 (The Act, Inshort) Dated 21.03.2022. 2. Brief Facts Of The Case Are That Assessee Is A Private Limited Company Engaged In The Business Of Real Estate & Filed Its Return Shree Ramraja Homes Pvt. Ltd. Vs. Dcit Of Income On 28.09.2017 Declaring Total Income At Rs.46,53,593/-. The Assessing Officer Has Information In Its Possession That Assessee Has Made Cash Deposit In Specified Bank Notes (Sbn) During The Demonetization Period Of Rs.34,00,000/-, Therefore, The Case Of The Assessee Was Reopened By Way Of Issue Of Notice U/S 148 Of The Act On 31.03.2021 After Recording The Reasons & Taking Necessary Approvals From The Competent Authority. The Assessee Has Not Filed Any Return Of Income In Response To Notice U/S 148 Nor Made Any Response To The Notices Issued By The Ao On Various Occasions Including Show Cause Notice Dated 08.03.2022. Therefore, The Ao Has Completed The Assessment U/S 144 Of The Act By Making Addition Of Rs.34,00,000/- By Treating The Same As Unexplained Money U/S 69A Of The Act & Further Invoked The Provisions Of Section 115Bbe Of The Act.

reassessment order passed by the Ld. AO since no valid satisfaction/approval under section 151 of the Act was obtained, 5(1). That on the facts and circumstances of the case, the Ld. CIT(A) was not justified in upholding the addition of Rs. 34,00,000 made under section 69A of the Act without appreciating the submissions filed and facts

VISHNU SONI,SHIVPURI vs. ITO, ASHOKNAGAR

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

Bench: Shri Sunil Kumar Singh & Shri Manish Agarwalincome Tax Officer, Mr. Vishnu Soni Ito, Ashok Nagar, Sadar Bazar, Vs. Aayakar Bawan, Shivpuri, Citiy Centre, Madhya Pradesh-473551 Gwalior, Madhya Pan-Awlps6188C Pradesh-474001 (Appellant) (Respondent)

reassessment order by making addition of Rs.58,98,125/- being 50% in amount of investment made in acquisition of the immovable property (including the stamp charges) and further made addition of Rs.1,87,500/- u/s 56(2)(vii)(b) of the Act being the difference between the sale consideration and the circle rate. Against such order, an appeal was filed

ACIT, CC, AGRA, AGRA vs. HMA AGRO INDUSTRIES LIMITED,, AGRA

In the result, ground no.1 raised by the Revenue is accordingly dismissed

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

60 taxmann.com 67 (Punjab & Haryana)/[2015] 370 ITR 732 (Punjab &Haryana)[21-07-2014] Section 69C, read with section 263, of the Income-tax Act, 1961 - Unexplained expenditure (Statements made before other authorities, relevance of) - Assessment year 2005-06 - Assessee- company was engaged in business of manufacturing of non- alloys steel ingots, trading in scrap, etc. - Subsequent to assessment, Commissioner

HMA AGRO INDUSTRIES LIMITED,AGRA vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE, AGRA, AGRA

In the result, ground no.1 raised by the Revenue is accordingly dismissed

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

60 taxmann.com 67 (Punjab & Haryana)/[2015] 370 ITR 732 (Punjab &Haryana)[21-07-2014] Section 69C, read with section 263, of the Income-tax Act, 1961 - Unexplained expenditure (Statements made before other authorities, relevance of) - Assessment year 2005-06 - Assessee- company was engaged in business of manufacturing of non- alloys steel ingots, trading in scrap, etc. - Subsequent to assessment, Commissioner

ACIT, CC, AGRA, AGRA vs. HMA AGRO INDUSTRIES LIMITED,, AGRA

In the result, ground no.1 raised by the Revenue is accordingly dismissed

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

60 taxmann.com 67 (Punjab & Haryana)/[2015] 370 ITR 732 (Punjab &Haryana)[21-07-2014] Section 69C, read with section 263, of the Income-tax Act, 1961 - Unexplained expenditure (Statements made before other authorities, relevance of) - Assessment year 2005-06 - Assessee- company was engaged in business of manufacturing of non- alloys steel ingots, trading in scrap, etc. - Subsequent to assessment, Commissioner

ACIT, CC, AGRA, AGRA vs. HMA AGRO INDUSTRIES LIMITED, AGRA

In the result, appeal filed by the assessee for AY 2019-20 is\nallowed and appeals filed by the Revenue in AYs 2021-22, 2022-23 and\n2023-24 are dismissed

60\ntaxmann.com 67 (Punjab & Haryana)/[2015] 370 ITR 732\n(Punjab & Haryana)[21-07-2014]\nSection 69C, read with section 263, of the Income-tax Act, 1961\n- Unexplained expenditure (Statements made before other\nauthorities, relevance of) - Assessment year 2005-06 - Assessee-\ncompany was engaged in business of manufacturing of non-\nalloys steel ingots, trading in scrap, etc. Subsequent

ACIT, CC, AGRA, AGRA vs. HMA AGRO INDUSTRIES LIMITED,, AGRA

In the result, appeal filed by the assessee for AY 2019-20 is\nallowed and appeals filed by the Revenue in AYs 2021-22, 2022-23 and\n2023-24 are dismissed

60\ntaxmann.com 67 (Punjab & Haryana)/[2015] 370 ITR 732\n(Punjab & Haryana)[21-07-2014]\nSection 69C, read with section 263, of the Income-tax Act, 1961\n- Unexplained expenditure (Statements made before other\nauthorities, relevance of) - Assessment year 2005-06 - Assessee-\ncompany was engaged in business of manufacturing of non-\nalloys steel ingots, trading in scrap, etc. Subsequent

SMT. SARIKA SRIVASTAVA,AGRA vs. PCIT-1, AGRA, AGRA

The appeals of the assessees are allowed in above terms

Bench: : Smt. Annapurna Gupta & Shri Sunil Kumar Singhassessment Year: 2012-13

reassessment proceedings. Thus the Pr. CIT has erred in imitating proceedings U/S 263. 2 | P a g e ITA No.56 & 57/Agr/2022 5. That the Asstt. Order dated 31-10-2019 is not prejudicial to the interests of the revenue.” 5. The order of the ld. PCIT in the case of Sarika Srivastava reveals that the assessee is a Doctor

SHRI ATUL SRIVASTAVA,AGRA vs. PCIT-1, AGRA, AGRA

The appeals of the assessees are allowed in above terms

Bench: : Smt. Annapurna Gupta & Shri Sunil Kumar Singhassessment Year: 2012-13

reassessment proceedings. Thus the Pr. CIT has erred in imitating proceedings U/S 263. 2 | P a g e ITA No.56 & 57/Agr/2022 5. That the Asstt. Order dated 31-10-2019 is not prejudicial to the interests of the revenue.” 5. The order of the ld. PCIT in the case of Sarika Srivastava reveals that the assessee is a Doctor