BHAGIRATH PAKHARIA,JHANSI vs. WARD 2 (3)(1), JHANSI

unexplained money.", "held": "The Tribunal held that the reassessment proceedings were initiated without independent application of mind by the AO, based

DEEPAK KUMAR AGRAWAL S/O SHRI LATE RATAN LAL AGRAWAL,TIKAMGARH vs. ITO, TIKAMGARH

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

Bench: Shri M. Balaganesh(Through Virtual Hearing) Deepak Kumar Agrawal, Vs. Ito, Ward No. 12, Purani Tikamgarh Tehsil, New Housing Board, Mp (Appellant) (Respondent) Pan: Axapa3069L Assessee By : None Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 18/11/2025 Date Of Pronouncement 26/11/2025

unexplained money under Section 69A of the Act. No response was filed by the Assessee thereon and accordingly, the learned AO completed the reassessment

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.

unexplained money u/s 69A of the Act and further invoked the provisions of section 115BBE of the Act. 3. Against such order, the assessee preferred an appeal before the Ld. CIT(A) wherein it was claimed by the assessee that the cash was deposited out of the withdrawal made from time to time from its regular bank account

VINOD KUMAR GUPTA,JHANSI vs. ITO, WARD-2(3)(1), JHANSI

In the result, the appeals of the assessee in ITA Nos

reassessment proceedings were initiated under section 148 due to alleged unexplained cash/credit entries in the bank account. Additions were made for disallowance of loss from house property, unexplained money

VINOD KUMAR GUPTA,JHANSI vs. ITO, WARD-2(3)(1), JHANSI

In the result, the appeals of the assessee in ITA Nos

reassessment was completed u/s 147\nread with Section 144B of the Act on 26.03.2022 wherein, loss from house\nproperty of Rs. 52,567/- was disallowed apart from making addition on account\nof unexplained money

CHAND KHAN,SADA SHIV NAGAR vs. ITO WARD 1(2) , CITY CENTER

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

Bench: : Shri Ramit Kocharassessment Year: 2012-13

reassessment proceedings, but the same remained un-complied with. Assessing Officer passed the best judgment assessment by making addition to the tune of Rs.15,90,000/- u/s. 69 of the Income Tax Act with respect to source of investment made in mutual funds which sources as per AO remained unexplained with respect to purchase of mutual funds to the tune

CHANDRA PRAKASH GOPLANI,BENGALURU vs. ITO 2(1)(1), AGRA

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

Bench: : Shri Ramit Kocharassessment Year: 2012-13

reassessment order dated29.11.2019passed by Assessing Officer u/s.144 r.w.s. 147 of the Income-tax Act, 1961. 2. Grounds of appeal raised by the assessee in the memo of appeal filed with the Income Tax Appellate Tribunal, Agra Bench, Agra reads as under : “1- BECAUSE the proceedings initiated u/s 147 and the notice issued u/s 148 is invalid, wrong, illegal, arbitrary, against

VINOD KUMAR GUPTA,JHANSI vs. ITO, WARD-2(3)(1), JHANSI

In the result, the appeals of the assessee in ITA Nos

reassessment was completed u/s 147\nread with Section 144B of the Act on 26.03.2022 wherein, loss from house\nproperty of Rs. 52,567/- was disallowed apart from making addition on account\nof unexplained money

NATTHI SINGH,DEHTORA vs. INCOME TAX OFFICER, WARD

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

Bench: Shri M. Balaganesh(Through Virtual Hearing) Natthi Singh, Vs. Ito, Mohhamadpur, Dehtora, Up Ward (Appellant) (Respondent) Pan: Jfqps8274N Assessee By : None Revenue By: Shri Shailendra Srivastava, Sr. Dr Date Of Hearing 03/02/2025 Date Of Pronouncement 03/02/2025

reassessment in the hands of the assessee for the year under consideration by treating the cash deposit of Rs 40 lakhs made in the bank account as unexplained money

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(Through Virtual Hearing)

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

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(Through Virtual Hearing)

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

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(Through Virtual Hearing)

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

BIKESH KUMAR,FIROZABAD vs. INCOME TAX OFFICER 2(2)(1) , FIROZABAD

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

Bench: Shri M. Balaganeshbikesh Kumar, Vs. Income Tax Officer, Nagla Bhoop Nasirpur, Ward-2(2)(1), Shikhabad Firozabad, Firozabad Firozabad (Appellant) (Respondent) Pan: Bglpk0327A Assessee By : Shri Rajendra Sharma, Adv Shri Manuj Sharma, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 23/01/2026 Date Of Pronouncement 03/02/2026

reassessment under section 147 r.w.s 144 r.w.s 144B of the Act on 21-3-2022 by adding the differential sum of cash deposits and income returned by the assessee in the total sum Rs 24,18,701 as unexplained money

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

NEERAJ KUMAR,AGRA vs. INCOME TAX OFFICER WARD 2(1)(3), AGRA, AGRA

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

Bench: Shri M. Balaganeshneeraj Kumar, Vs. Income Tax Officer, 18/24, Ghadi Hussaini Ward-2(1)(3), Prakash Nagar, Agra Agra (Appellant) (Respondent) Pan: Ajwpn8393C Assessee By : Shri Jitendra Garg, Adv Shri Pradumn Garg, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 03/02/2026

reassessment is void ab initio 4. Because the assessment framed ex-parte under section 147/144 is bad in law, since notices were never served at the correct address and the appellant was denied proper opportunity of being heard. 5. Because the reopening under section 147 is mechanical, without application of mind, based on no new tangible material, and in violation

JAY SINGH,MORENA vs. ITO-1, MORENA

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

Bench: Shri M. Balaganesh(Through Virtual Hearing) Jay Singh, Vs. Ito, Gram Khaneta, Maharajpur, Ward-1, Morena, Madhya Pradesh Morena (Appellant) (Respondent) Pan: Cfwps1529H

reassessment proceedings, notice under section 142(1) of the Act stood issued to the assessee. Assessee, being an uneducated person and having no knowledge of operating the computer and income tax portal could not make compliance to the notices issued by the learned AO, which ultimately culminated in framing of assessment under section 144 read with section

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)

unexplained money. In first appeal, the Ld. CIT(A) while dealing with ground of appeal No.1 to 6 taken on the merits of the additions, has set aside the issue back to the file of AO in terms of the powers conferred to him under first proviso to section 251(1) (a) of the Act and direct

BHAGIRATH PAKHARIA,JHANSI vs. WARD 2 (3)(1), JHANSI

Appeal stand allowed for statistical purposes

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपील सं. / Ita No.565/Agr/2024 (िनधा"रणवष" / Assessment Year: 2013-14) & 2. आयकरअपील सं. / Ita No.566/Agr/2024 (िनधा"रणवष" / Assessment Year: 2013-14) & 3. आयकरअपील सं. / Ita No. 567/Agr/2024 (िनधा"रणवष" / Assessment Year: 2014-15) & 4. आयकरअपील सं. / Ita No. 568/Agr/2024 (िनधा"रणवष" / Assessment Year: 2014-15) & 5. आयकरअपील सं. / Ita No. 569/Agr/2024 (िनधा"रणवष" / Assessment Year: 2015-16) & 6. आयकरअपील सं. / Ita No. 570/Agr/2024 (िनधा"रणवष" / Assessment Year: 2017-18) & 7. आयकरअपील सं. / Ita No. 571/Agr/2024 (िनधा"रणवष" / Assessment Year: 2018-19) Shri Bhagirath Pakharia Income-Tax Officer, बनाम/ 124, Nanak Ganj, Sipri Bazar, Ward 2(3)(1), Jhansi. Vs. Jhansi (Up) "थायीलेखासं./जीआइआरसं./Pan/Gir No. Amdpp-6709-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Ms. Prarthana Jalan, Ca – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Shailender Shrivastava – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 21-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 23-04-2025

money u/s 69A and framed the assessment. 3. During first appeal, the assessee disputed the valuation and stated that Ld. AO invoked the provisions of Sec.50C without reference to valuation officer. However, Ld. CIT(A) rejected legal grounds and confirmed the assessment against which the assessee is in further appeal before us. 4. From the facts, it clearly emerges that