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

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

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

Reassessment order was\npassed u/s. 144 without adhering to principles of natural justice, as no\nproper opportunity was given to theassessee. It is also claimed that\ntreatment of his return of income filed in pursuance to notice u/s. 148 as\ninvalid by the AO is bad in law. There are other several challenges on\nlegal grounds as well

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)

u/s 147 r..ws 144B of the Income Tax Act 1956 is bad in law and void ab initio as the same is not in compliance with the Provisions of the Law. 11. That the appropriate order for granting justice and relief be passed. 12. Your appellant reserves its right to add to amend to alter or to modify

HARICHARAN RATHORE,ASHOK NAGAR vs. INCOME TAX OFFICER,ASHOK NAGAR, ASHOK NAGAR

In the result, appeal filed by the assessee is allowed

Bench: Shri M. Balaganeshharicharan Rathore, Vs. Ito, 125, Path Kheda, Ashok Ashok Nagar, Nagar, Mp Mp (Appellant) (Respondent) Pan: Csqpr0999M Assessee By : Shri Rajendra Sharma, Adv Shri Manuj Sharma, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 21/01/2026

u/s 148 dated 31.03.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule of Law, which vitiates the reopening of the assessment; and further pointed out that this legal issue raised by the assessee has been answered in favor of the assessee

NARAYANI RATHORE,SHIVPURI vs. ASSESSMENT UNIT,INCOME TAX DEPARTMENT, DELHI

In the result, appeal filed by the assessee is allowed

Bench: Shri M. Balaganeshnarayani Rathore, Vs. Assessment Unit, Peeroth Shivpuri, Income Tax Shivpuri, Mp Department, National Faceless Appeal Centre, Delhi (Appellant) (Respondent) Pan: Dhgpr1886H

u/s 148 dated 31.03.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule of Law, which vitiates the reopening of the assessment; and further pointed out that this legal issue raised by the assessee has been answered in favor of the assessee

BADARIPRASAD,GUNA vs. INCOME TAX OFFICER GUNA, GUNA

In the result, appeal filed by the assessee is allowed

Bench: Shri M. Balaganeshbadriprasad, Vs. Income Tax Officer, Heerabagh Colony, Guna, Guna, Gwalior Gwalior (Appellant) (Respondent) Pan: Arapr6314B

u/s 148 dated 31.03.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule of Law, which vitiates the reopening of the assessment; and further pointed out that this legal issue raised by the assessee has been answered in favor of the assessee

ASHOK SAHU,JHANSI vs. INCOME TAX OFFICER, WARD 2(3)(1), JHANSI, JHANSI

In the result, appeal filed by the assessee is allowed

Bench: Shri M. Balaganeshashok Sahu, Vs. Income Tax Officer, Purana Bazar, Chirgaon, Ward-2(3)(1), Jhansi Jhansi (Appellant) (Respondent) Pan: Jgsps3446H Sunita, Vs. Assessment Unit, Ward No. 2, Chobyana Income Tax Talrehat Lake View Department, Camp, Lalitpur, Lalitpur, National Faceless Up Appeal Centre, Delhi (Appellant) (Respondent) Pan: Jgps3438H

u/s 148 dated 31.03.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule of Law, which vitiates the reopening of the assessment; and further pointed out that this legal issue raised by the assessee has been answered in favor of the assessee

SUNITA,SAHU vs. ASSESSMENT UNIT,INCOME TAX DEPARTMENT, DELHI

In the result, appeal filed by the assessee is allowed

Bench: Shri M. Balaganeshashok Sahu, Vs. Income Tax Officer, Purana Bazar, Chirgaon, Ward-2(3)(1), Jhansi Jhansi (Appellant) (Respondent) Pan: Jgsps3446H Sunita, Vs. Assessment Unit, Ward No. 2, Chobyana Income Tax Talrehat Lake View Department, Camp, Lalitpur, Lalitpur, National Faceless Up Appeal Centre, Delhi (Appellant) (Respondent) Pan: Jgps3438H

u/s 148 dated 31.03.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule of Law, which vitiates the reopening of the assessment; and further pointed out that this legal issue raised by the assessee has been answered in favor of the assessee

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

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

natural justice. 9. Because, the ‘appellant’ craves leave to add, delete, modify or substitute grounds of appeal. ” 3. Brief facts of the case as mentioned in the order of the CIT(A) are that ‘in this case, assessment has been completed u/s 147/144 vide the impugned order dated 29.12.2016 determining the assessed income at Rs. 51,60,273/-. No return

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

147 of the Act. 3. Aggrieved, the assessee preferred first appeal before ld. CIT(Appeals), who dismissed the same vide impugned order. 4. The assessee has filed this appeal before the tribunal on the following grounds : “1. That under the facts and circumstances of the case the learned Authorities below have erred both on facts and in law with prima

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

LALIT MOHAN DIXIT,FIROZABAD vs. ITO 2(2)(2), FIROZABAD

In the result, the appeal is allowed for statistical purposes

Bench: : Smt. Annapurna Gupta & Shri Sunil Kumar Singhassessment Year: 2012-13

reassessment proceedings u/s. 147 of the Act by issuing a notice u/s. 148 of the Act. The assessee did not file any return of income in pursuance of this notice. Statutory notices were issued which too remained un-responded. Therefore, the Assessing Officer made addition of the aforesaid cash deposit amounting to Rs.26,17,600/- in the hands of assessee

NEETESH KUMAR GUPTA,SHAMSHABAD, AGRA vs. INCOME TAX OFFICER WD 2(1)(3), AGRA, AGRA

In the result, the appeal is allowed for statistical purposes

Bench: : Shri Sunil Kumar Singh & Shri Brajesh Kumar Singhassessment Year: 2012-13

reassessment proceedings u/s. 147 of the Act by issuing a notice u/s. 148 of the Act on 31.03.2019, which stood un-responded on behalf of the assessee. Statutory notices were issued, which too were not complied with. Therefore, the Assessing Officer made addition of aforesaid cash deposit amounting to Rs.10,67,965/- to the income of the assessee, assessing total

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

KRIPA RAM VYAS,GWALIOR vs. ITO, GWALIOR

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

Bench: Shri M. Balaganesh(Through Virtual Hearing) Kripa Ram Vyas, Vs. Ito, Pgv College, Jiwaji Gwalior Ganj, Lashkar Ho, Gird, Gwalior -474001 Pan: Abupv2129C Assessee By : None Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 20/08/2025 Date Of Pronouncement 12/09/2025

natural justice by not affording sufficient opportunity. None appeared on behalf of the assessee before me. I find that the assessee is a retired pensioner and a senior citizen. The case of the assessee was sought to be reopened u/s 147 of the Act and assessment Kripa Ram Vyas was framed ex parte u/s 144 read with Section 147

SARVESH DEVI (LEGAL HEIR OF LATE MADAN LAL TOMAR),AGRA vs. ITO, WARD 2(1)(1), AGRA, AGRA

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh(Through Virtual Hearing) Sarvesh Devi (Legal Heir Vs. Income Tax Officer, Of Late Madan Lal Tomar), Ward-4(3)(1), 51, Keshavkunj Pratap Hathras Nagar, Agra (Appellant) (Respondent) Pan: Eshpd4540M Assessee By : Shri Rajesh Malhotra, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 18/08/2025 Date Of Pronouncement 13/11/2025

reassessment framed u/s 144/ 147 of the Act on 30.01.2015. 4. The ld AR before us challenged the validity of framing of assessment in the name of deceased by placing reliance on the decision of the Hon'ble Supreme Court in the case of PCIT Vs. Maruti Suzuki India Ltd reported in 416 ITR 613 wherein it was observed

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

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

natural justice which are inherent in income tax proceedings as also keeping in view provisions of Section 282 of the 1961 Act and Rule 127 of the 1962 Rules. When technicalities are pitted against advancement of substantial justice, then the Court will lean towards advancement of justice unless malice or negligence is at writ large. The assessee is not likely