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

cash deposits in the saving bank account maintained by assessee with ICICI Bank, Sanjay Place, Agra, which was treated by the Assessing Officer as an unexplained income of the assessee.The said reassessment order was passed by the AO u/s 144 read with Section 147

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

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

u/s 147 that Reopening was done on the ground of\nsuppression of turnover while the additions have been made with respect\nto entire cash deposits in the bank account and hence, additions were\nmade on different ground than on which the provisions of section 147\nwere invoked. The re-assessment being framed without issuing notice\nu/s

ANIL KUMAR AGARWAL,AGRA vs. DCIT 2(1)(1), AGRA, AGRA

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh(Through Virtual Hearing) Anil Kumar Agarwal, Vs. Dy. Cit, 44, R. S. Residency, Circle-2(1)(1), Dayal Bagh, Agra, Up Agra (Appellant) (Respondent) Pan: Aampa3335J Assessee By : Shri Rajni Kant Verma, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 17/09/2025 Date Of Pronouncement 19/11/2025

u/s 143(3) r.w.s. 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated by the Assessing Officer, DCIT, Circle-2(1)(1), Agra (hereinafter referred to as ‘ld. AO’). 2. The only issue to be decided on merits in this appeal is as to whether the Learned JCIT(Appeals) was justified in confirming the addition

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 of the Act for reassessment of the concluded assessment, with the approval of the competent authority. A notice u/s 148, dated 23.03.2018, was issued by the Assessing Officer to the assessee, requiring the assessee to file return of income in pursuance to notice u/s 148. The assessee sought adjournments from time to time. The case of the assessee

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)

reassessment order dated 21.03.2022 passed u/s. 147 r.w.s. 144B of the Act. 3. Aggrieved, assessee preferred first appeal before the Ld. CIT(Appeals), who dismissed assessee’s appeal and confirmed the impugned addition. 4 | P a g e 4. Present second appeal has been filed on the following grounds : “1. BECAUSE, upon due consideration of facts and in the overall

SARMAN RAI,JHANSI vs. INCOME TAX OFFICER, WARD - 2(3)(3), JHANSI, JHANSI

In the result, the appeal is allowed for statistical purposes

Bench: : Shri Sunil Kumar Singh & Shri Manish Agarwalassessment Year: 2012-13

deposited cash of Rs.13,90,000/- in his bank account maintained with PNB, Baruasagar, Jhansi. The Assessing Officer, therefore, initiated reassessment proceedings u/s. 147

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

cash deposits were noticed. j. The CBDT has been issuing directions from time to time in respect of adoption of non-adversarial tax regime. The instruction no-17/2015 has been issued with intent to discourage/curb tendency to frame high- pitched/unreasonable assessments. The relevant portion of this instruction is as under: "Board has consistently been advising the field authorities

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

cash deposits were noticed. j. The CBDT has been issuing directions from time to time in respect of adoption of non-adversarial tax regime. The instruction no-17/2015 has been issued with intent to discourage/curb tendency to frame high- pitched/unreasonable assessments. The relevant portion of this instruction is as under: "Board has consistently been advising the field authorities

SAROJ,MAINPURI vs. I.T.O WARD 2(5), MAINPURI

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

Bench: : Shri Ramit Kochar & Shri Sudhir Kumarassessment Year: 2012-13

deposited Rs.16 lakhs in cash in her bank account on 23.03.2012 in Saving Bank Account No. 32252355696 with State Bank of India during the year under consideration. Based on the information gathered by the Assessing Officer, proceedings u/s. 147 were initiated by the AO for reopening of the concluded assessment, and notice dated 25.03.2019 u/s

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.

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 and was redeposited when

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

u/s 143(3) r.w.s. 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 25.12.2018 by the Assessing Officer, ITO, Ward, Tikamgarh (hereinafter referred to as ‘ld. AO’). 2. At the outset, I find that there is a delay in filing of appeal by the Assessee before this Tribunal by 297 days. Considering the reasons adduced

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

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 142(1) of the Act originally stood issued to the assessee on 29.03.2018 which is unsigned. The said notice

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)

147 r.w.s. 144 of the Act dated 09.03.2024. 2. Brief facts of the case are that the AO has information that assessee has made large cash deposit into the bank accounts amounting to ₹64,90,000 and no return of income was filed. He therefore, proceeded to re-open the assessment and issued notice u/s 148A(a) in the name

YOGENDRA SHARMA,DELHI vs. INCOME TAX OFFICER, ETAH

In the result, the appeal preferred by assessee is allowed

Bench: : Shri S. Rifaur Rahmanassessment Year: 2012-13 Yogendra Sharma, I-4695, 2Nd Vs. Income-Tax Officer, Floor, Gali No. 4-B, Balbir Nagar Ward 3(2), Etah. Extension, Shahdara, Delhi. Pan :Cgkps6492J (Appellant) (Respondent)

u/s. 143(2) and 142(1) of the Act were issued and served on the assessee. 3. During the assessment proceedings, the Assessing Officer observed that the assessee has declared income from salary of Rs.1,74,000/- and income from business of Rs.1,38,500/- against gross receipts of Rs.4,50,000/-. Besides above, the assessee has declared nil income

BHAGWAN SWAROOP,ALIGARH vs. THE I.T.O. WARD 4(1)(1), ALIGARH , ALIGARH

In the result, the appeal is allowed for statistical purposes

Bench: : Shri Sunil Kumar Singh & Shri Brajesh Kumar Singhassessment Year: 2018-19

u/s. 147 r.w.s. sections 144 and 144B of the Income Tax Act, 1961, vide order dated 10.03.2023, making an addition of Rs.1,06,45,000/- on account of unexplained cash deposits in the bank account of the assessee. The assessee filed first appeal on 18.08.2023 against this assessment order dated 10.03.2023. As per assessee, the first appeal was filed within

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

cash deposits, withdrawals, and TDS/TCS data, the Assessing Officer initiated reassessment proceedings u/s 147 and issued notice u/s 148. Explanations/replies

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

147 read with section 148 of the Act to reopen concluded assessment, and notice u/s. 148 dated 29.03.2019 was issued to the assessee. But there was no response of the assessee. Statutory notices u/s. 142(1)were also issued by the AO to the assessee during the course of reassessment proceedings, but the same remained un-complied with. Assessing Officer

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

147 r.w.s. 144 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 27.11.2017 by the Assessing Officer, ITO-1, Morena (hereinafter referred to as ‘ld. AO’). 2. The only issue to be decided in this appeal is as to whether the learned NFAC was justified in confirming the addition made