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), 142(1) and 133(6) were issued, not only to the assessee but also directly to the share applicant. In response thereto, the assessee and the investor company furnished exhaustive details, including identity particulars, income-tax returns, audited financial statements, bank statements, share application forms, details of liquidation of investments and copies of assessment orders passed under section

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)

15,63,030/- was sought to be added by the ld AO by treating it as income from other sources. 5. Before the ld CIT(A), the assessee reiterated the submission made before the ld AO. The crux of the argument of the assessee before the ld CIT(A) and before us could be summarised as under

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)

15,63,030/- was sought to be added by the ld AO by treating it as income from other sources. 5. Before the ld CIT(A), the assessee reiterated the submission made before the ld AO. The crux of the argument of the assessee before the ld CIT(A) and before us could be summarised as under

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

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

15 (SC), in which, it has been held as\nunder:-\n“Section 68 read with section 263, of the Income-tax Act,\n1961 - Cash credit (Gift) Assessment years 2007-08 and\n2008-09 - Assessee received certain amount as gifts from\nhis father and sister who were non-residents in India\nAssessing Officer after making detailed enquiries, took a\nview that

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

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

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

INCOME TAX OFFICER, ASHOKNAGAR vs. AJIT SINGH , SHIVPURI

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

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh (Through Virtual Hearing) Income Tax Officer, Vs. Ajit Singh, Ashoknagar, Village-Haatodh, Madhya Pradesh Post-Kota, Shivpuri (Appellant) (Respondent) Pan: Ccnps7470K Assessee By : Shri Vipin Upadhyay, Adv Revenue By: Shri Sukesh Kumar Jain, Cit(Dr) Date Of Hearing 17/11/2025 Date Of Pronouncement 04/11/2025

147 of the Act on 30-3- 2022. This assessment was framed by the Learned JAO, Income Tax Officer, Ajit Singh Ashok Nagar. It is pertinent to note that both the notice under section 148 of the Act was issued by the Learned JAO and reassessment was framed by the Learned JAO. 6. The Assessee filed detailed submissions before

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)

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 the time limit prescribed under section 149(1)(b) of the Act. Since all these

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

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

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

2) assessment was there for rightly illegal. 19. That the provision U/S 144 was not followed by the AO & hence the order is bad in law. 20. That the learned ITO no proper and adequate oppurnitey was provide to the appellant thus the order is illegal uncalled for and liable to be quashed. 21. That regarding the entire facts

M/S UMA GLASS WORKS,AGRA vs. PR.CIT.-1, AGRA

In the result, both the appeals of the assessee for AYs 2014-15 and

Bench: Shri Anil Chaturvedi & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A Nos.17 & 18/Agra/2021 िनधा"रणवष"/Assessment Years:2014-15 & 2015-16 बनाम M/S Uma Glass Works Pcit, 22, Near Industrial Estate, Vs. Agra-1, Firozabad - 283203 Uttar Pradesh.

147 of the Act in not making addition U/s 68 resulted in erroneous and prejudicial to the interests of revenue except stating that the Assessing Officer should have been made addition U/s 68 I.T.A.Nos.17 & 18/Agra/2021/A.Ys.2014-15 & 2015-16 instead of treating the net profit as assessed income of the Assessee on account of alleged difference in closing stock

M/S UMA GLASS WORKS ,FIROZABAD vs. PR.CIT.-1, AGRA

In the result, both the appeals of the assessee for AYs 2014-15 and

Bench: Shri Anil Chaturvedi & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A Nos.17 & 18/Agra/2021 िनधा"रणवष"/Assessment Years:2014-15 & 2015-16 बनाम M/S Uma Glass Works Pcit, 22, Near Industrial Estate, Vs. Agra-1, Firozabad - 283203 Uttar Pradesh.

147 of the Act in not making addition U/s 68 resulted in erroneous and prejudicial to the interests of revenue except stating that the Assessing Officer should have been made addition U/s 68 I.T.A.Nos.17 & 18/Agra/2021/A.Ys.2014-15 & 2015-16 instead of treating the net profit as assessed income of the Assessee on account of alleged difference in closing stock

SOURABH JAIN,GUNA vs. INCOME TAX OFFICER GUNA, GUNA

In the result, the appeal of the assessee is dismissed

Bench: Shri Sunil Kumar Singh & Shri Manish Agarwalincome Tax Officer, Saurabh Jain, Guna. 1, Near Sanjeevani Vs. Hospital Garha Colony, Guna, Madhaya Pradesh-473001 Pan-Bgjpj7915F (Appellant) (Respondent)

u/s 250 of the Income Tax Act, 1961 (‘the Act’ for short). Saurabh Jain vs. ITO 2. The assessee has taken the following grounds of appeal: 1. On the facts and circumstances of the case, the Commissioner of Income Tax (Appeals) has erred in setting aside assessment without dealt to filed ground of appeal hence whole order

HMA AGRO INDUSTRIES LIMITED,AGRA vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE, AGRA, AGRA

In the result, ground no.1 raised by the Revenue is accordingly dismissed

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

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

ACIT, CC, AGRA, AGRA vs. HMA AGRO INDUSTRIES LIMITED,, AGRA

In the result, ground no.1 raised by the Revenue is accordingly dismissed

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

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

ACIT, CC, AGRA, AGRA vs. HMA AGRO INDUSTRIES LIMITED,, AGRA

In the result, ground no.1 raised by the Revenue is accordingly dismissed

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

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