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

GOVIND SHARMA,MATHURA vs. ITO, WARD 1(3)(1), MATHURA

In the result, the assessee’s appeal is allowed

reassessment proceedings deserve to be quashed.” 3. The additional ground as preliminary issue raised by the appellant assessee, challenging the validity of assumption of jurisdiction u/s. 147 of the Act by the ld A.O. being passed on mechanical approval u/s. 151 of the Act, goes to the root of the matter. We deem it fit to address the same first

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

151; So as to impart greater efficiency, transparency and accountability by inter alia eliminating the interface between the Income Tax Authorities and assessee. Sub-section 3 of Section 151A of the Act also provides that every notification issued under sub- Haricharan Rathore section (1) and (2) of Section 151A of the Act shall be laid before each House of Parliament

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

151; So as to impart greater efficiency, transparency and accountability by inter alia eliminating the interface between the Income Tax Authorities and assessee. Sub-section 3 of Section 151A of the Act also provides that every notification issued under sub-section (1) and (2) of Section 151A of the Act shall be laid before each House of Parliament. Badriprasad

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

151; So as to impart greater efficiency, transparency and accountability by inter alia eliminating the interface between the Income Tax Authorities and assessee. Sub-section 3 of Section 151A of the Act also provides that every notification issued under sub-section (1) and (2) of Section 151A of the Act shall be laid before each House of Parliament. In exercise

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

151; So as to impart greater efficiency, transparency and accountability by inter alia eliminating the interface between the Income Tax Authorities and assessee. Sub-section 3 of Section 151A of the Act also provides that every notification issued under sub-section (1) and (2) of Section 151A of the Act shall be laid before each House of Parliament. In exercise

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

151; So as to impart greater efficiency, transparency and accountability by inter alia eliminating the interface between the Income Tax Authorities and assessee. Sub-section 3 of Section 151A of the Act also provides that every notification issued under sub-section (1) and (2) of Section 151A of the Act shall be laid before each House of Parliament. In exercise

GHANSHYAM ,MATHURA vs. ITO 3(2), MATHURA

In the result, both the appeals are allowed

Bench: Shri A. D. Jain

147 of the Act. It is further I.T.A No. 238/Agra/2018 6 & I.T.A No. 129/Agra/2018 noted that the approval granted by the competent authority is a mechanical approval and action has been taken mechanically because on perusing the reasons recorded, it demonstrates that Joint CIT has written “Yes, in view of reasons recorded by the AO, I am satisfied that this

GHANSHYAM ,MATHURA vs. ITO 3(2), MATHURA

In the result, both the appeals are allowed

Bench: Shri A. D. Jain

147 of the Act. It is further I.T.A No. 238/Agra/2018 6 & I.T.A No. 129/Agra/2018 noted that the approval granted by the competent authority is a mechanical approval and action has been taken mechanically because on perusing the reasons recorded, it demonstrates that Joint CIT has written “Yes, in view of reasons recorded by the AO, I am satisfied that this

BIJENDRA KUMAR,MATHURA vs. ITO-1(3)(1), MATHURA

In the result, both the appeals are allowed

Bench: Shri A. D. Jain

147 of the Act. It is further noted that the approval granted by the competent authority is a mechanical approval and action has been taken mechanically because on perusing the I.T.A Nos.409 & 419/Agra/2017 7 reasons recorded, it demonstrates that Joint CIT has written “Yes, in view of reasons recorded by the AO, I am satisfied that this is fit case

ANITA YADAV,MATHURA vs. ITO -1(3)(1), MATHURA

The appeal is allowed

Bench: Shri A. D. Jain

147 of the Act. It is further noted that the approval granted by the competent authority is a mechanical approval and action has been taken mechanically because on perusing the reasons recorded, it demonstrates that Joint CIT has written “Yes, in view of reasons recorded by the AO, I am satisfied that this is fit case for issue of notice

AVNINDRA MISHRA,MATHURA vs. ITO-1(3)(1), MATHURA

The appeal is allowed

Bench: Shri A. D. Jain

147 of the Act. It is further noted that the approval granted by the competent authority is a mechanical approval and action has been taken mechanically because on perusing the reasons recorded, it demonstrates that Joint CIT has written “Yes, in view of reasons recorded by the AO, I am satisfied that this is fit case for issue of notice

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)

151 of the Act in the prescribed proforma which is reproduced herein:- ITA Nos. 54 & 76/AGR/2025 Manoj Kumar Agarwal 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

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)

151 of the Act in the prescribed proforma which is reproduced herein:- ITA Nos. 54 & 76/AGR/2025 Manoj Kumar Agarwal 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

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

151 of the Act, a notice u/s 148 was issued by the A.O. The reasons for issuing notice dated 30/03/2016 u/s 148 of the Act reads as under:- Page 6 of 23 Tej Singh vs. ITO “The undersigned is in possession that the assessee has sold immovable property of Rs. 5040273/- during the year under consideration

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

In the result, assessee’s appeal is allowed

reassessment order passed by Ld. Assessing Officer under section 147/144B, as the very assumption of jurisdiction under section 147 is bad in law and void ab initio, inter alia, for the reason that the reopening was initiated on the basis of mechanical and invalid approval, and without complying with mandatory conditions prescribed under section 147 to 151 of the Income

PRAMOD KUMAR GARG,AGRA vs. DCIT,CIRCLE 2(1)(1), AGRA

In the result, assessee’s appeal is allowed

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2015-16

sections 147 to 151 of the old law ceased to operate from 01.04.2021. The Apex Court in Rajeev Bansal (supra) specifically observed that after 01.04.2021, any reference to the Income Tax Act means the Income Tax Act as amended by Finance Act, 2021 and held that the time limit prescribed for issuing reassessment notice u/s