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 147 r.w.s. 144B of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 25.03.2025 by the Assessing Officer, Assessment Unit, Income Tax Department (hereinafter referred to as ‘ld. AO’). 2. Though the assessee has raised several grounds of appeal, the preliminary issue to be decided is whether the assumption of jurisdiction for reopening the assessment

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 147 r.w.s. 144B of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 28.03.2023 date of service order 28.03.2023 by the Assessing Officer, FAO, National Faceless Appeal Centre, Delhi (hereinafter referred to as ‘ld. AO’). 2. Though the assessee has raised several grounds of appeal, the preliminary issue to be decided is whether the assumption

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 147 r.w.s. 144B of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated ITA No. 432/AGR/2025 24.03.2023 and 01.03.2023 by the Assessing Officer, Assessing Officer, National Faceless Appeal Centre, Delhi (hereinafter referred to as ‘ld. AO’). 2. Both the appeals involve identical issues and hence they are taken up together and disposed of by this common

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 147 r.w.s. 144B of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated ITA No. 432/AGR/2025 24.03.2023 and 01.03.2023 by the Assessing Officer, Assessing Officer, National Faceless Appeal Centre, Delhi (hereinafter referred to as ‘ld. AO’). 2. Both the appeals involve identical issues and hence they are taken up together and disposed of by this common

SH. YUGAL KISHOR AGARWAL,AGRA vs. DCIT, CIRCLE 4(3)(1), ETAH

In the result, appeal filed by the assessee is allowed

Bench: : Shri Ramit Kocharassessment Year: 2012-13

reassessment by invoking provisions of section 147. Notice u/s. 148 dated 26.03.2019 was issued by the Assessing Officer to the assessee. The assessee submitted that return of income originally filed be treated as return of income filed in response to notice u/s. 148 of the Act. Statutory notices u/s. 143(2

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

2 facts that reassessment proceedings initiated and consequential reassessment order passed under section 147 of the Act which are illegal and void for the reason - (a) that the Assessing Officer had no jurisdiction to issue notice under section 148 of the Act beyond the period of four years from the end of the relevant assessment year without 3 demonstrating

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

2 facts that reassessment proceedings initiated and consequential reassessment order passed under section 147 of the Act which are illegal and void for the reason - (a) that the Assessing Officer had no jurisdiction to issue notice under section 148 of the Act beyond the period of four years from the end of the relevant assessment year without 3 demonstrating

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

In the result, the appeal of the Assessee is allowed

2) does not\nmention any reason for coming to the conclusion that it is a fit case for\nthe issue of a notice under section 148. We are also of the opinion that\nthe Commissioner has mechanically accorded permission. He did not\nhimself record that he was satisfied that this was a fit case for the issue\nof a notice

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

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

2 of the assessee is devoid of merit. 7. We have heard both the parties and perused the material available on record. The present case, the assessee had not filed return u/s 139(1) of the Act or response to the notice u/s 148 of the Act. An information was received by the A.O. during the year under consideration, that

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

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

section 147\nwere invoked. The re-assessment being framed without issuing notice\nu/s 143(2). The Id. CIT(A) did not adjudicated the legal grounds raised by\nthe assessee. On merits, it is claimed that additions are made of\nRs.1,28,13,500/- without proper examination of facts and without\napplication of mind. It is also claimed that Reassessment order

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

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

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

section 147 of the Act, and proceedings u/s 147 were initiated against the assessee. The Assessing Officer issued questionnaire to the assessee. The AO has recorded in the assessment order that the assessee filed his return of income on 16.7.2018 in response to notice u/s 148 of the Act as is emerging from the reassessment order passed by the Assessing

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

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

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

2(a) of Section 147 of the Act kicks in. Accordingly, in order to frame any assessment, the ld AO should have issued notice u/s 148 of the Act on the assessee in the manner known to law, then proceed to frame the reassessment

PEHAL,CHHATARPUR vs. ITO (EXEMPTION), GWALIOR

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

Bench: SHRI RAMIT KOCHAR (Accountant Member)

148 is to be issued.” 4. During the course of assessment proceedings, the Assessing Officer issued statutory notices u/s. 142(1) as well as show cause notice u/s. 144 of the Act, show causing to the assessee that why deduction u/s. 11 may not be denied to the assessee as registration u/s. 12AA was granted vide order dated 14.09.2011 w.e.f

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)

148 of the Act. Statutory notice u/s. 143(2) and notice u/s. 142(1) of the Act were issued and served upon the assessee. The assessee raised objections against the reasons for reopening, which were disposed of on 18.02.2022. Further, assessee submitted his reply dated 04.02.2022. During the reassessment proceedings, the assessee contended that it had purchased steel and building

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, and notice u/s. 148 dated 29.03.2019 was issued by the AO to the assessee seeking to reopen the concluded assessment. There was no response from the assessee to the notice u/s. 148. Further, statutory notice u/s. 143(2) and 142(1) were also issued to the assessee in the reassessment

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

reassessment proceedings. Thus the Pr. CIT has erred in imitating proceedings U/S 263. 2 | P a g e ITA No.56 & 57/Agr/2022 5. That the Asstt. Order dated 31-10-2019 is not prejudicial to the interests of the revenue.” 5. The order of the ld. PCIT in the case of Sarika Srivastava reveals that the assessee is a Doctor