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)

bogus accommodation entries from one Sh. Md. Irfan S/o Sh. Meharban. Copy placed in the paper book as “Annexure C.”. In response to that, assessee submitted its reply on 22.03.2022 attached with this brief, wherein assessee submitted that, the assessee had only made purchases of ‘Alive animal’ from the above said party, which is accounted in audited books of accounts

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)

bogus accommodation entries from one Sh. Md. Irfan S/o Sh. Meharban. Copy placed in the paper book as “Annexure C.”. In response to that, assessee submitted its reply on 22.03.2022 attached with this brief, wherein assessee submitted that, the assessee had only made purchases of ‘Alive animal’ from the above said party, which is accounted in audited books of accounts

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

bogus purchases from one Md. Irfan. The Assessing Officer (AO) initially accepted the purchases in the original assessment and during reassessment, after recording Md. Irfan's statement. However, the Principal Commissioner of Income Tax (PCIT) initiated revision proceedings u/s 263, believing the AO had not conducted proper inquiries. The PCIT set aside the assessment order, directing fresh inquiries.", "held

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 notice based on alleged bogus purchases from Md. Irfan. The Assessing Officer (AO) initially accepted the purchases as genuine after investigations, but the Principal Commissioner (PCIT) initiated revision proceedings u/s 263, viewing the AO's assessment as erroneous and prejudicial.", "held": "The Tribunal held that the PCIT had erred in invoking Section 263 as the AO had conducted adequate

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

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

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)

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

ACIT, CC, AGRA, AGRA vs. M/S FEDERAL AGRO INDUSTRIES PVT. LTD.,, NEW DELHI

In the result, appeal filed by the revenue is dismissed

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singh

reassessment completed u/s 147 read with section 143(3) in respect of purchases of ‘Raw Boneless Meat’, which has been treated as bogus

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

SH. VIRENDRA KUMAR JAIN,UTTAR PRADESH vs. INCOME TAX OFFICER, LALITPUR

In the result, appeal is allowed for statistical purposes

Bench: : Shri M. Balaganesh & Shri Sunil Kumar Singhassessment Year: 2018-19

reassessment proceedings u/s 147 and issued notice u/s 148. Explanations/replies offered by assessee with respect to above information stood accepted by the Assessing Officer. However, it was further gathered from the said information that the assessee had shown bogus sales of Rs.1,18,52,322/- to M/s. Mahaveer Prasad Suresh Kumar, New Delhi. In response to statutory notices, the assessee

ANJU AGARWAL,AGRA vs. INCOME TAX OFFICER, WARD 2(1)(1), AGRA

In the result, the appeal of the Assessee is allowed

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh (Through Virtual Hearing) Anju Agarwal, Vs. Income Tax Officer, D-26, Kamla Nagar, Ward-2(1)(1), Agra Agra (Appellant) (Respondent) Pan: Awtpa4297L Assessee By : Shri K. K. Jain, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 16/09/2025 Date Of Pronouncement 04/12/2025

147 r.w.s. 144B of the Income-tax Act, 1961 (hereinafter referred to as „the Act‟) dated 23.03.2024 by the Assessing Officer, NFAC, Delhi (hereinafter referred to as „ld. AO‟). 2. The Assessee has raised the following grounds of appeal before us:- “1. Because the proceedings u/s 148A(b) as well as order passed u/s 148A(d) and consequential notice issued