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

147 of the Act. Therefore, if Revenue's arguments are to be accepted, there is no purpose of framing a Scheme only for clause 3(a) which is in any event already covered under faceless assessment regime in Section 144B of the Act. The argument of respondent, therefore, renders the whole Scheme redundant. An argument which renders the whole Scheme

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

147 of the Act. Therefore, if Revenue's arguments are to be accepted, there is no purpose of framing a Scheme only for clause 3(a) which is in any event already covered under faceless assessment regime in Section 144B of the Act. The argument of respondent, therefore, renders the whole Scheme redundant. An argument which renders the whole Scheme

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

147 of the Act. Therefore, if Revenue's arguments are to be accepted, there is no purpose of framing a Scheme only for clause 3(a) which is in any event already covered under faceless assessment regime in Section 144B of the Act. The argument of respondent, therefore, renders the whole Scheme redundant. An argument which renders the whole Scheme

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

147 of the Act. Therefore, if Revenue's arguments are to be accepted, there is no purpose of framing a Scheme only for clause 3(a) which is in any event already covered under faceless assessment regime in Section 144B of the Act. The argument of respondent, therefore, renders the whole Scheme redundant. An argument which renders the whole Scheme

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

147 of the Act. Therefore, if Revenue's arguments are to be accepted, there is no purpose of framing a Scheme only for clause 3(a) which is in any event already covered under faceless assessment regime in Section 144B of the Act. The argument of respondent, therefore, renders the whole Scheme redundant. An argument which renders the whole Scheme

PEHAL,CHHATARPUR vs. ITO (EXEMPTION), GWALIOR

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

Bench: SHRI RAMIT KOCHAR (Accountant Member)

147 of the Act on the ground that registration u/s. 12AA was granted effective from 01.04.2011, i.e., assessment year 2012-13, but the assessee has claimed exemption u/s. 11 of the Act for the impugned assessment year, i.e., 2010-11. There was no compliance by the assessee during the assessment proceedings as well as in the first appellate proceedings. Both

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 proceedings u/s 147 as well raising challenge to the additions made on merits of the issue before ld. CIT(A), wherein as many as 11 grounds of appeal were raised before ld. CIT(A). I have also observed that the CIT(Appeals) has not made any enquiry during the 10 | P a g e course of appellate proceedings

PAWAN AGRAWAL,MATHURA vs. INCOME TAX OFFICER 1(3)(1), MATHURA

In the result, the appeal of the Assessee is allowed

11. Section 151 of the Act clearly stipulates that the\nCommissioner of Income-tax (Appeals), who is the competent\nauthority to authorize the reassessment notice, has to apply his\nmind and form an opinion. The mere appending of the expression\n"approved" says nothing. It is not as if the Commissioner of\nIncome-tax (Appeals) has to record elaborate reasons

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)

11. The reassessment was completed u/s 147 r.w.s. 144 r.w.s. 144B of the Act on 30.03.2022 wherein an addition of Rs. 1,23,46,358/- being the amount of unsecured loan added u/s 68 of the Act. 12. At the outset, we find that the reasons recorded by the ld AO for reopening the assessment are very very vague

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)

11. The reassessment was completed u/s 147 r.w.s. 144 r.w.s. 144B of the Act on 30.03.2022 wherein an addition of Rs. 1,23,46,358/- being the amount of unsecured loan added u/s 68 of the Act. 12. At the outset, we find that the reasons recorded by the ld AO for reopening the assessment are very very vague

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

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

11,00,000/- in A/c No. 08280400000468 maintained with Bank of Baroda, Allahaganj, Shahjahanpur. Notice u/s 142(1) stood issued to the assessee. In pursuance to the said notice, the assessee filed return on 24.09.2019 declaring income of ₹3,53,760/- being the income offered on presumptive basis u/s 44AD of the Act along with interest income

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

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

11 of the paper book. According to section 147 of the IT Act, the essential ingredient of this section has been that “if the Assessing Officer has reason to belief that any income chargeable to tax has escaped assessment in any assessment year……..” Therefore, before invoking jurisdiction u/s. 147 of the IT Act, the Assessing Officer shall have reason

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

11,24,558/- on 'protective basis' u/s 68\nr.w.s 115BBE of the Act, with a finding that substantive addition be\nmade in the hands of beneficiary being the assessee HMA Agro\nIndustries Ltd. It was further stated in the show cause notice that the\nAO has failed to examine and establish the modus operandi of bogus\npurchases and, thus

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)

11 are general in nature, thus are not adjudicated. 5. In Ground of appeal number 2 to 4, 7 and 8, the reassessment proceedings were challenged on the basis that the notice under Section 148A was issued in the name of a dead person. Further it is challenged that the notice u/s 148A was issued without proper approval and beyond

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

147 of the Act have taken place, no proceedings u/s. 263 of the Act can happen. Reliance was placed on the order of ITAT, Ahmedabad in Hiren Kumar Lavjibhai Kanani (ITA No. 522/Ahd/2024) and of Hon’ble Allahabad High Court in Meerut Roller Flour Mills (P) Ltd. vs. CIT (2019) 110 taxmann.com 170 (Allahabad). 11. Learned DR countered by stating

SHRI ATUL 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

147 of the Act have taken place, no proceedings u/s. 263 of the Act can happen. Reliance was placed on the order of ITAT, Ahmedabad in Hiren Kumar Lavjibhai Kanani (ITA No. 522/Ahd/2024) and of Hon’ble Allahabad High Court in Meerut Roller Flour Mills (P) Ltd. vs. CIT (2019) 110 taxmann.com 170 (Allahabad). 11. Learned DR countered by stating

VIKAS CHANDRA HUF,ALIGARH vs. ITO WARD-4(1)(1), ALIGARH

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganeshvikas Chandra Huf, Vs. Cit(Appeals), D-117, Ramesh Vihar, Nfac, Delhi Ramghar Road, Aligarh Up (Appellant) (Respondent) Pan: Aakjv9476N Assessee By : Shri Pankaj Garg, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 21/01/2026

147 of the Act vide issuance of notice u/s 148 of the Act on 28.3.2024. The reasons recorded for reopening the assessment together with the approval granted by the Learned Principal Commissioner of Income Tax -1 , Agra (hereinafter referred to ld PCIT) in terms of section 151 of the Act are enclosed in pages 2 to 5 of the Paper