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

loss of assessee. Therefore, for the purposes of making assessment or reassessment, the provisions of Section 144B of the Act would be applicable as no such manner for reassessment is separately provided in the Scheme. For issuing notice, the term "to the extent provided in Section 144B of the Act" is not relevant. The Scheme provides that the notice under

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

loss of assessee. Therefore, for the purposes of making assessment or reassessment, the provisions of Section 144B of the Act would be applicable as no such manner for reassessment is separately provided in the Scheme. For issuing notice, the term "to the extent provided in Section 144B of the Act" is not relevant. The Scheme provides that the notice under

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

loss of assessee. Therefore, for the purposes of making assessment or reassessment, the provisions of Section 144B of the Act would be applicable as no such manner for reassessment is separately provided in the Scheme. For issuing notice, the term "to the extent provided in Section 144B of the Act" is not relevant. The Scheme provides that the notice under

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

loss of assessee. Therefore, for the purposes of making assessment or reassessment, the provisions of Section 144B of the Act would be applicable as no such manner for reassessment is separately provided in the Scheme. For issuing notice, the term "to the extent provided in Section 144B of the Act" is not relevant. The Scheme provides that the notice under

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

loss of assessee. Therefore, for the purposes of making assessment or reassessment, the provisions of Section 144B of the Act would be applicable as no such manner for reassessment is separately provided in the Scheme. For issuing notice, the term "to the extent provided in Section 144B of the Act" is not relevant. The Scheme provides that the notice under

M/S AGRA PRODUCTS PVT.LTD.,GAUTAM BUDDHA NAGAR vs. DEPUTY C.I.T CIRCLE -2(1)(1), AGRA

The appeal stand allowed in terms of our above order

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.121/Agr/2019 (िनधा"रणवष" / Assessment Year: 2012-13) M/S Agra Products Pvt. Ltd. Dcit-Circle-2(1)(1), बनाम/ Plot No. 99, Phase-Ii, Nsez, Noida, Agra Vs. Gautum Bhuddha Nagar, U.P. "थायीलेखासं./जीआइआरसं./Pan/Gir No.Aadca-3621-R (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Pankaj Gargh (Advocate) – Ld. Ar " थ"कीओरसे/Respondent By : Shri Shailendra Shrivastava – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 10-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 22.04.2025

losses on the ground that the accumulated profits were in credit. The assessee offered same return of income as filed on 28-09-2012 and objected to the reopening. The assessee, inter-alia, contended that the initiation of reassessment proceeding was on the same set

SANJAY CHOBEY,JHANSI vs. ACIT CIRCLE-2(3)(1), JHANSI

In the result, appeal of the assessee is partly allowed

Bench: : Shri A.D. Jain & Shri Dr. Mitha Lal Meenaassessment Year: 2013-14 Vs. Acit, Circle –2(3)( 1), Dr. Sanjay Chobey, (Huf) Opp. Ware House, Shivpuri Aayakar Bhawan, Road, Nandpura, Jhansi 1090, Civil Lines, Pan : Aahhd7844 Q Jhansi (Appellant) (Respondent)

reassessment has to be annulled. The matter cannot be set aside to the AO for second chance.” 4. The sole grievance of the assessee is regarding adoption of value of property at the circle rates of the State Government as against value of sale consideration disclosed by the assessee. ITA 140/Agr/2018 3 5. During the course of assessment proceeding

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)

set aside the assessment order to the file of AO with certain directions for making fresh assessment. The ld. AR of the assessee submitted that the Ld. CIT(A) has not decided the legal issues taken by the assessee with respect to the reopening of the assessment and, therefore, he requested that the legal issues raised by the assessee deserves

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

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

set aside. 6. That the appellant craves leave to add, alter, amend, OR withdraw any of the aforesaid grounds at the time of hearing. 7. At the time of hearing, learned AR has made various legal contentions that the reopening of assessment is bad in law ab inito, being based on change of opinion; notice u/s. 148, having been issued

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

set aside. 6. That the appellant craves leave to add, alter, amend, OR withdraw any of the aforesaid grounds at the time of hearing. 7. At the time of hearing, learned AR has made various legal contentions that the reopening of assessment is bad in law ab inito, being based on change of opinion; notice u/s. 148, having been issued

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

SMT. VIDHYA AGARWAL,AGRA vs. I.T.O., WARD-4(4), AGRA

The appeal is allowed

Bench: Shri Sudhanshu Srivastava & Dr. Mitha Lal Meena

sets of facts. The sum and substance of the arguments of the Ld. Sr. DR is that the jurisdiction assumed by the Assessing Officer for the purpose of initiation of reassessment proceedings was entirely valid and it was prayed that the assessees’ appeals be dismissed by holding the assumption of jurisdiction u/s 148 of the Act to be valid

RATNESH KUMAR JAIN,SHIVPURI vs. INCOME TAX OFFICER ASHOK NAGAR, GWALIOR

In the result, appeal of the assessee is allowed for statistical\npurposes

loss account, for which no credit was given. Bank\naccount was fully explained with the books of account. The assessee\nalso contended that no notice u/s. 143(2) was issued prior to framing of\nreassessment order. It was submitted that the reassessment is bad in\nlaw as the assessment was reopened on the ground that the assessee\nhas shown lower

RAJ SINGH,MATHURA vs. ITO-3(3), MATHURA

In the result appeal is allowed

Bench: Shri Sudhanshu Srivastava & Dr. Mitha Lal Meenashri. Raj Singh, Vs.. Income Tax Officer- 3(3), Village- Kharaut Chhata, Mathura Mathura. Pan: Akvpr1777Q (Appellant) (Respondent)

loss of revenue. At the same time, we have to bear in mind that the policy of law is that there must be a point of finality in all legal proceedings, that stale issues should not be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest judicial and quasi-judicial controversies

PUSHPA,MATHURA vs. ITO-1(2)(3), MATHURA

In the result,both appeals are allowed

Bench: Shri Sudhanshu Srivastava & Dr. Mitha Lal Meenashri. Pushpendra Singh. Vs.. Income Tax Officer- 1(2)(3), M-22, Phase-I, Mahavidhya Colony. Agra. Mathura. Pan: Dldps6755P (Appellant) (Respondent) Smt. Pushpa Vs.. Income Tax Officer- 1(2)(3), M-22, Phase-I, Mahavidhya Colony. Agra. Mathura. Pan: Bcopd0484L (Appellant) (Respondent)

loss of revenue. At the same time, we have to bear in mind that the policy of law is that there must be a point of finality in all legal proceedings, that stale issues should not be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest judicial and quasi-judicial controversies