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

12 | P a g e ITA No.344 & 343/Agr/2025 2.10 That the reasons, recorded in the present case too, are completely lacking to indicate as to what material facts were not disclosed fully and truly by the assessee so as to assume jurisdiction u/s. 147 after expiry of four years. Therefore, the jurisdictional requirement under the first proviso to Section 147

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

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

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

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

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

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

In the result, the appeal of the Assessee is allowed

12 of the Paper Book. On perusal of the\nproforma seeking approval u/s 151 of the Act dated 29-03-2024, I find that the\nLearned PCIT had merely stated that considering the reasons recorded by the\nLearned JAO and recommendations of the Range Head, it is a fit case for\nreopening. This sort of approval granted u/s

SINGH CARRIERS,JHANSI vs. WARD 2(3)(1), JHANSI

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

Bench: Shri Sunil Kumar Singh & Shri Manish Agarwalincome Tax Officer, Singh Carriers, Ward-2(3)(1), 2716, Swamipuram Vs. Jhansi. Colony, Gwalior Road, Jhansi, Uttar Pradesh-284003. Pan-Aacfs9607B (Appellant) (Respondent)

section 251(1) (a) of the Act and direct the AO to pass the assessment order afresh after considering the replies and documents filed by the assessee. However, the Ld. CIT(A) has not decided the jurisdictional issues raised by the assessee with regard to initiation of reassessment proceedings u/s 147 of the Act which was challenged before

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

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

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

section 147 of the Act in the reasons recorded for reopening of assessment. Therefore, the AO has not correctly assumed jurisdiction u/s. 147 / 148 of the IT Act. Accordingly, we set aside the orders of the authorities below and quash the reassessment proceedings. It would Page 12

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)

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 and does

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)

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 and does

VINOD KUMAR GUPTA,JHANSI vs. ITO, WARD-2(3)(1), JHANSI

In the result, the appeals of the assessee in ITA Nos

12,34,280/-. The information flagged by the Id\nDDIT/ ADIT(Investigation), Jhansi as per risk profiling on Insight Portal on\n10.03.2021 stated that source of cash/ credit entries in the bank account of the\nassessee are not explained to the extent of Rs. 28,20,500/-. Accordingly, the Id\nJurisdictional Assessing Officer (JAO) after recording reasons initiated\nproceedings u/s

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

12 | P a g e ITA No.56 & 57/Agr/2022 above. Therefore, the Assessment Order passed u/s 143(3) r.w.s. 147 dated 31.10.2019 by the Assessing Officer in your case for A.Y. 2012-13 is hereby modified (partly set aside) with the directions to the Assessing Officer to examine the issues as mentioned in Para 1 to Para 8 of Notice u/s

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

12 | P a g e ITA No.56 & 57/Agr/2022 above. Therefore, the Assessment Order passed u/s 143(3) r.w.s. 147 dated 31.10.2019 by the Assessing Officer in your case for A.Y. 2012-13 is hereby modified (partly set aside) with the directions to the Assessing Officer to examine the issues as mentioned in Para 1 to Para 8 of Notice u/s

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)

reassessment proceedings were invalid because same was initiated beyond the time limit prescribed under Section 149(1)(b), Thus whole entire assessment time-barred and unsustainable in law. 9. On the facts and circumstances of the case the Learned CIT(A)has erred in not dealing to the holding as imposition of interest under Sections 234A, 234B, and 234C without