HARICHARAN RATHORE,ASHOK NAGAR vs. INCOME TAX OFFICER,ASHOK NAGAR, ASHOK NAGAR

In the result, appeal filed by the assessee is allowed

Bench: Shri M. Balaganeshharicharan Rathore, Vs. Ito, 125, Path Kheda, Ashok Ashok Nagar, Nagar, Mp Mp (Appellant) (Respondent) Pan: Csqpr0999M Assessee By : Shri Rajendra Sharma, Adv Shri Manuj Sharma, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 21/01/2026

reassessment. The phrase "to the extent provided in Section 144B of the Act" would mean that the restriction provided in Section 144B of the Act, such as keeping the International Tax Jurisdiction or Central Circle Jurisdiction out of the ambit of Section 144B of the Act would also apply under the Scheme. Further the exceptions provided in sub-section

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. The phrase "to the extent provided in Section 144B of the Act" would mean that the restriction provided in Section 144B of the Act, such as keeping the International Tax Jurisdiction or Central Circle Jurisdiction out of the ambit of Section 144B of the Act would also apply under the Scheme. Further the exceptions provided in sub-section

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. The phrase "to the extent provided in Section 144B of the Act" would mean that the restriction provided in Section 144B of the Act, such as keeping the International Tax Jurisdiction or Central Circle Jurisdiction out of the ambit of Section 144B of the Act would also apply under the Scheme. Further the exceptions provided in sub- section

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. The phrase "to the extent provided in Section 144B of the Act" would mean that the restriction provided in Section 144B of the Act, such as keeping the International Tax Jurisdiction or Central Circle Jurisdiction out of the ambit of Section 144B of the Act would also apply under the Scheme. Further the exceptions provided in sub- section

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. The phrase "to the extent provided in Section 144B of the Act" would mean that the restriction provided in Section 144B of the Act, such as keeping the International Tax Jurisdiction or Central Circle Jurisdiction out of the ambit of Section 144B of the Act would also apply under the Scheme. Further the exceptions provided in sub- section

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 proceedings are ex facie bad in law, being initiated without satisfying the conditions stipulated in first proviso to Section 147, and are thus liable to be quashed as void ab initio. The statutory conditions under the first proviso to Section 147 are that no action for reopening can be taken beyond four years unless there is a failure

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 proceedings are ex facie bad in law, being initiated without satisfying the conditions stipulated in first proviso to Section 147, and are thus liable to be quashed as void ab initio. The statutory conditions under the first proviso to Section 147 are that no action for reopening can be taken beyond four years unless there is a failure

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

reassessment was framed by the Learned JAO. 6. The Assessee filed detailed submissions before the Learned CITA, both on law as well as on facts. The Learned CITA obtained a remand report from the Learned AO. The Learned CITA, after due consideration of the remand report and rejoinder to the remand report, quashed the assessment as non-est by observing

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 7 | P a g e Asst Year: 2012-13 Yugal Kishor Agarwal proceedings. The assessee is drawing income from salary, income from house property , Remuneration and Interest from Partnership, and income from other sources. I have observed that the case of the assessee was reopened by Revenue by invoking provisions of Section 147 on the belief that income

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

section 151 was obtained. 5. The learned CIT(A) failed to consider that the Assessing Officer did not furnish the reasons recorded for reopening despite request, thereby vitiating the reassessment. 6. The learned CIT(A) erred in upholding the addition of Rs. 8

SINGH CARRIERS,JHANSI vs. WARD 2(3)(1), JHANSI

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

Bench: Shri Sunil Kumar Singh & Shri Manish Agarwalincome Tax Officer, Singh Carriers, Ward-2(3)(1), 2716, Swamipuram Vs. Jhansi. Colony, Gwalior Road, Jhansi, Uttar Pradesh-284003. Pan-Aacfs9607B (Appellant) (Respondent)

section 251(1) (a) of the Act and direct the AO to pass the assessment order afresh after considering the replies and documents filed by the assessee. However, the Ld. CIT(A) has not decided the jurisdictional issues raised by the assessee with regard to initiation of reassessment proceedings u/s 147 of the Act which was challenged before

SONU JAIN THROUGH LEGAL HEIR AND FATHER OF LATE SONU JAIN SHRI RAJENDRA JAIN ,GUNA vs. INCOME TAX OFFICER GUNA, GUNA

In the result, the appeal is partly allowed

Bench: SHRI SUNIL KUMAR SINGH (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

reassessment proceedings were invalid because the notice under Section 148A was issued without obtaining proper approval from the competent authority, which is a jurisdictional defect. 8

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)

Section 271AAC(1), which were imposed without any factual or legal basis. 8. On the facts and circumstances of the case, the Commissioner of Income Tax (Appeals) has erred in not dealt for quashing the reassessment

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

In the result, the appeal of the Assessee is allowed

Section 151 of the Act clearly stipulates that the CIT (A), who is the\ncompetent authority to authorize the reassessment notice, has to apply his\nmind and form an opinion. The mere appending of the expression 'approved'\nsays nothing. It is not as if the CIT (A) has to record elaborate reasons for\nagreeing with the noting

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

Section 151 of the Act clearly stipulates that the CIT (A), who is the competent authority to authorize the reassessment notice, has to apply his mind and form an opinion. The mere appending of the expression 'approved' says nothing. It is not as if the CIT (A) has to record elaborate reasons for agreeing with the noting

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. 5,60,000/-on account of unexplained money for cash deposit in bank under section 69A r.w.s. 115BBE

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

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

8 of 23 Tej Singh vs. ITO assessee earned any capital gains out of the sale transaction of land in question. There was no material with the AO to prima facie prove that the assessee earned capital gain because he wanted the assessee to intimate as to how capital gain arises out of the transaction. Since no reply was submitted

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

8. Explanation 2(a) to section 147 of the Income-tax Act includes non-filing of return in the expression "escaped assessment. The said Explanation reads "Explanation 2: For the purposes of this section, the following shall also be deemed to be cases where income chargeable to tax has escaped assessment, namely: Sarvesh Kumar (a) where no return of income