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

addition for any other Income does not stand as Point 3 of the Reasons recorded u/s 148 of the Income Tax Act, 1961 clearly mentions that the Assessee had Cash Deposits to be explained, which was entirely left to be inquired into during the course of assessment proceedings. The Hon'ble Supreme Court in Rampyari Devi Saraogi

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

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

addition of Rs.1,28,13,500/- to the income\nof the assesseedeemed as unexplained money u/s. 69A of the Act. The\nAO further held that as the assessee did not filed his return of income in\nresponse to the notice u/s 148 of the Income-tax Act, 1961 dated\n30.03.2021 within time prescribed, and the assessee vide letter dated\n21.12.2021

VEERENDRA SINGH ,JALAUN vs. ITO,W 2(1)(5),ORAI, JALAUN

The appeal of the assessee is allowed in the manner as indicated above

Bench: Shri Ramit Kocharveerendra Singh, Income-Tax Officer, Vill. Dakor Mohana, Orai, Ward 2(1)(5), Orai, Distt. Jalaun (Up)-285001. V. Distt. Jalaun (Up) "थायीलेखासं./जीआइआरसं./Pan/Gir No: Bbjps 3108 J Appellant .. Respondent

147 were initiated against the assessee. The Assessing Officer issued questionnaire to the assessee. The AO has recorded in the assessment order that the assessee filed his return of income on 16.7.2018 in response to notice u/s 148 of the Act as is emerging from the reassessment order passed by the Assessing Officer. So far as merits of the additions

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

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

income of assessee at Rs.2,59,89,010/- after rejecting assessee’s books of account u/s. 145(3) of the IT Act, 1961 and making additions on account of low net profit and disallowance of depreciation claimed on fixed assets. In first appeal preferred against the above said assessment order dated 31.03.2016, learned CIT(A) vide order dated 25.06.2025 affirmed

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

income of assessee at Rs.2,59,89,010/- after rejecting assessee’s books of account u/s. 145(3) of the IT Act, 1961 and making additions on account of low net profit and disallowance of depreciation claimed on fixed assets. In first appeal preferred against the above said assessment order dated 31.03.2016, learned CIT(A) vide order dated 25.06.2025 affirmed

MAHESH EDIBLE OIL INDUSTRIES LIMITED,DELHI vs. ASSTT. COMMISSIONER OF INCOME TAX, AGRA

reassess taking into consideration the other material in respect of completed\nassessments/unabated assessments. Meaning thereby, in respect of completed/unabated\nassessments, no addition can be made by the AO in absence of any incriminating material\nfound during the course of search under Section 132 or requisition under Section 132A of\nthe Act, 1961. However, the completed/unabated assessments can be re-opened

SAGAR DWELLINGS P LTD,NEAR SUN TEMPLE GWALIOR vs. ACIT, FACELESS

In the result, assessee’s appeal is dismissed

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

addition was made during the assessment proceedings concluded u/s. 143(3) of the Act. The Assessing Officer, not being satisfied with the explanation and evidences, held the said purchases to be bogus and added Rs.1,03,89,106/- to the total income of the assessee, vide reassessment order dated 21.03.2022 passed u/s. 147

DEPUTY COMMISSIONER OF INCOME TAX, AGRA vs. MAHESH EDIBLE OIL INDUSTRIES LTD, DELHI

reassess taking into consideration the other material in respect of completed\nassessments/unabated assessments. Meaning thereby, in respect of completed/unabated\nassessments, no addition can be made by the AO in absence of any incriminating material\nfound during the course of search under Section 132 or requisition under Section 132A of\nthe Act, 1961. However, the completed/unabated assessments can be re-opened

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

reassessment proceedings, the AO made an\nenquiry from the Md. Irfan vide summons issued dated 26.03.2023\nforming part of Supplementary paper Book at page 1,and the statement\nof Md. Irfan recorded on oath, wherein he had admitted that, he is\nengaged in trading of Alive animals and also confirmed that, he had made\nsales to assessee and also

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)

reassessment proceedings, the AO made an enquiry from the Md. Irfan vide summons issued dated 26.03.2023 forming part of Supplementary paper Book at page 1,and the statement of Md. Irfan recorded on oath, wherein he had admitted that, he is engaged in trading of Alive animals and also confirmed that, he had made sales to assessee and also

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)

reassessment proceedings, the AO made an enquiry from the Md. Irfan vide summons issued dated 26.03.2023 forming part of Supplementary paper Book at page 1,and the statement of Md. Irfan recorded on oath, wherein he had admitted that, he is engaged in trading of Alive animals and also confirmed that, he had made sales to assessee and also

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)

reassessment proceedings, the AO made an enquiry from the Md. Irfan vide summons issued dated 26.03.2023 forming part of Supplementary paper Book at page 1,and the statement of Md. Irfan recorded on oath, wherein he had admitted that, he is engaged in trading of Alive animals and also confirmed that, he had made sales to assessee and also

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

reassessment proceedings, the AO made an\nenquiry from the Md. Irfan vide summons issued dated 26.03.2023\nforming part of Supplementary paper Book at page 1,and the statement\nof Md. Irfan recorded on oath, wherein he had admitted that, he is\nengaged in trading of Alive animals and also confirmed that, he had made\nsales to assessee and also

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

addition of ₹13,30,000/- was made u/s 69A read with section 115BBE of the Act on account of cash deposits made during demonetization period in specified bank notes for want of non- compliance to the show cause notice issued u/s 142(1) of the Act by the ld AO. 4. The following facts are not in dispute. Notice u/s

MANOJ KUMAR AGARWAL,FARUKHABAD vs. ASSESSING OFFICER, FARRUKHABAD

In the result, appeal of the assessee is allowed for AY 2017-18 and appeal of the assessee for AY 2015-16 is partly allowed

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh(Through Virtual Hearing)

income chargeable to tax has escaped assessment.” 10. The ld AO had sought approval from the ld Addl. CIT being the competent authority u/s 151 of the Act in the prescribed proforma which is reproduced herein:- ITA Nos. 54 & 76/AGR/2025 Manoj Kumar Agarwal 11. The reassessment was completed u/s 147 r.w.s. 144 r.w.s. 144B of the Act on 30.03.2022 wherein

MANOJ KUMAR AGARWAL,FARRUKHABAD vs. DCIT CIRCLE-4(2)(1) FARRUKHABAD, FARRUKHABAD

In the result, appeal of the assessee is allowed for AY 2017-18 and appeal of the assessee for AY 2015-16 is partly allowed

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh(Through Virtual Hearing)

income chargeable to tax has escaped assessment.” 10. The ld AO had sought approval from the ld Addl. CIT being the competent authority u/s 151 of the Act in the prescribed proforma which is reproduced herein:- ITA Nos. 54 & 76/AGR/2025 Manoj Kumar Agarwal 11. The reassessment was completed u/s 147 r.w.s. 144 r.w.s. 144B of the Act on 30.03.2022 wherein

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

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

u/s. 147 of the IT Act without recording satisfaction for initiation of proceedings in the matter. Hon’ble Supreme Court in the case of Sheo Nath Singh vs. Appellate Asst. Commissioner of Income-tax, 82 ITR 147 held – “The words “reason to believe” suggest that the belief must be that of an honest and reasonable person based upon reasonable grounds