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

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 the rejection of accounts and sustained the addition made by AO on account of low profit rate. Aggrieved, assessee preferred an appeal in ITA No.342/Agr/2025 before the ITAT, which has been partly allowed

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

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 the rejection of accounts and sustained the addition made by AO on account of low profit rate. Aggrieved, assessee preferred an appeal in ITA No.342/Agr/2025 before the ITAT, which has been partly allowed

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

PARMANAND,AGRA vs. ITO, WARD, 2(1)(2), AGRA

In the result, assessee’s appeal is allowed

disallowance u/s 40A(3) of the I.T. Act whereas in the Assessment order the addition has been made u/s 69C of the I.T. Act. This is apparently bad in law and not permissible under the Act. Reasons recorded have to be read as it is. No substitution/deletion/addition in the reasons recorded is permissible under the law. On this ground also

JAWAHAR LAL AGARWAL,AGRA vs. I.T.O., WARD-4(2), AGRA

In the result, the appeal is allowed

Bench: Shri A. D. Jain

disallowing deduction u/s 54B of the I.T. Act for making investment of Amount of Rs. 14,09,670/- in purchase of agriculture land being in the name of minor Daughter, which is grossly, arbitrarily, perverse, wrong & illegal in the Peculiar facts and circumstances of the case. I.T.A No. 336/Agra/2014 2 2. Because in any view, the proceeding u/s 147/148

DINESH KUMAR GUPTA,AGRA vs. ITO, AGRA

In the result, the appeal is allowed

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

disallowed and added back to the income of the assessee. I therefore, have reason to believe that the income chargeable to tax of Rs, 18,21,313/-has escaped assessment within the meaning of section 147 of the IT Act 1961 in the case of Shri Dinesh Chand Gupta, B-69 Trans Yamuna Colony, Agra in the assessment year

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

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

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

PEHAL,CHHATARPUR vs. ITO (EXEMPTION), GWALIOR

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

Bench: SHRI RAMIT KOCHAR (Accountant Member)

disallowed. Assessee did not comply with the notice(s), which led to denial of deduction u/s. 11 of the Act by the Assessing Officer to the tune of Rs.5,83,244/- claimed by the assessee vide re-assessment order dated 27.03.2015 framed by the Assessing Officer u/s. 144/147 of the 1961 Act. 5. Assessee filed first appeal with

SHYAMA SHYAM INFRADEVELOPERS PRIVATE LIMITED,AGRA vs. ITO 2(1)(2), AGRA

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganeshshyama Shyam Vs. Ito, Infradevelopers Pvt Ltd, Ward-2(1)(2), Khasra No. 961, Bhahistabad, Agra Sikandra, Agra (Appellant) (Respondent) Pan: Aatcs9899R Assessee By : Shri Gaurav Agarwal, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 21/01/2026 O R D E R

disallowance and completed the reassessment. Hence, it is very clear that no addition has been made by the ld Assessing Officer on the issue, which was subject matter of reopening of assessment. Accordingly, the very basis of assumption of jurisdiction u/s 147

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)

147 and the same enquiry have been referred in the case of the Md. Irfan. Though, it is very established that, this is not a case of lack of enquiry, therefore it is mere a change of opinion of the Ld. PCIT in invoking the provisions of section 263 read with Explanation 2 clause (a) and since adequate

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)

147 and the same enquiry have been referred in the case of the Md. Irfan. Though, it is very established that, this is not a case of lack of enquiry, therefore it is mere a change of opinion of the Ld. PCIT in invoking the provisions of section 263 read with Explanation 2 clause (a) and since adequate

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)

147 and the same enquiry have been referred in the case of the Md. Irfan. Though, it is very established that, this is not a case of lack of enquiry, therefore it is mere a change of opinion of the Ld. PCIT in invoking the provisions of section 263 read with Explanation 2 clause (a) and since adequate

ANIL KUMAR,ETAH vs. INCOME-TAX OFFICER, WARD-4(3)(1), ETAH

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

Bench: Shri Sunil Kumar Singh & Shri Brajesh Kumar Singh[Assessment Year: 2012-13]

u/s 147 r.w.s 143(3) treating the entire sale consideration as the income of the appellant without getting any efforts to verify the information or extracting the income which is factually incorrect. 2. That the learned Assessing Officer has erred in law and on fact in initiating the reassessment proceedings under section 147 read with section

ACIT, CIRCLE-4(1)(1), ALIGARH, ALIGARH vs. MOHD. INTZAR, ALIGARH

The appeal stand dismissed

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No.318/Agr/2024 (िनधा"रणवष" / Assessment Year: 2014-15) Acit Circle 4(1)(1) Mohd. Intzar बनाम/ Aligarh 202001 140, Sarai Mitan Vs. Delhi Gate, Aligarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aagpi-7161-N (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Dr. Arun Kumar Yadav – Ld. Cit-Dr ""थ"कीओरसे/Respondent By : Shri Deepak Singh (Advocate) – Ld. Ar सुनवाईकीतारीख/Date Of Hearing : 19-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 28-03-2025

147 r.w.s. 144B of the Act on 28-03-2022. Both sides made vehement arguments. Having heard rival submissions and upon perusal of case records, the appeal is disposed-off as under. 2. The returned income of Rs.9.28 Lacs was accepted in scrutiny assessment u/s 143(3). However, pursuant to receipt of certain information from investigation wing that the assessee

DIXIT RICE MILL ,AURAIYA vs. DCIT, BENGALURU

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

Bench: Shri Laliet Kumar & Dr. Mitha Lal Meena

u/s 143(1) being bad in law is liable to be quashed. 4. Because in any view of the matter, no opportunity was provided to the assessee, by the CPC, before making such disallowance and therefore the disallowance being made is against the principle of natural justice and bad in law and hence liable to be deleted. 5. Because

GORAV FOOTWEAR,AGRA vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE1(1)(1), AGRA/CIT(A), NFAC, DELHI, 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 आयकरअपील सं./ Ita No.503/Agr/2024 (िनधा"रणवष" / Assessment Year: 2012-13) Gorav Footwear Dcit Circle 1(1)(1) बनाम/ 6, Nath Complex, Agra Vs. Dhakran Crossing, Agra – 282 003 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aahfg-7549-R (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Deependra Mohan (Ca)- Ld.Ar " थ"कीओरसे/Respondent By : Shri Shailendra Shrivastava – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 18-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 18-02-2025

disallowance u/s 40A (3) for Rs.90.55 Lacs. In other words, no addition has been made for the issue which form the very basis of reopening the case of the assessee. Though the assessee preferred first appeal, Ld. CIT(A) confirmed the action of Ld. AO and rejected the legal grounds as well as grounds on merits. Aggrieved, the assessee