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

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

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.

reassessment was completed u/s 143(3) of the Act read with Section 147 of the Act determining the income of the assessee by making an addition of Rs.19,90,13,470/-. The said Rs.19,90,13,469/- represents the difference in opening stock, purchases, sales, closing stock and the net profit as shown by the assessee in its return

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.

reassessment was completed u/s 143(3) of the Act read with Section 147 of the Act determining the income of the assessee by making an addition of Rs.19,90,13,470/-. The said Rs.19,90,13,469/- represents the difference in opening stock, purchases, sales, closing stock and the net profit as shown by the assessee in its return

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

section 263 of the Act. He further contended that there is no bar on the Assessing Officer for exploring other issues in reassessment proceedings other than for which the reassessment was resorted to. 12. We have heard the contentions of both the parties and carefully gone through the records and perused the case laws. 13. Undisputedly, the order found

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

section 263 of the Act. He further contended that there is no bar on the Assessing Officer for exploring other issues in reassessment proceedings other than for which the reassessment was resorted to. 12. We have heard the contentions of both the parties and carefully gone through the records and perused the case laws. 13. Undisputedly, the order found

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

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

147 Taxman, 12 (All). 7. Pooran Mal Vs. Director of Inspection, [1974) 93 ITR 505 (SC) 8. Deep Chand Daga Vs. ITO [1970] 77 ITR, 661 (MP) and, 9. Fisher Xomox Sanmar Ltd. V. Assistant CIT, [2007] 294 ITR 620 [2008] 168 Taxman 251 (Mad.) 14. None of the judgments referred to above have any connection to the point

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)

24,83,15,217/- under Section 69A on account of cash deposits in the bank accounts which were duly recorded in the books of accounts and supported by an audit report, making the invocation of Section 69A unwarranted. 4. On the facts and circumstances of the case, the Commissioner of Income Tax (Appeals) has erred not dealt to the ground

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

u/s 148A(d) as a fit 148A(d) AND/OR issuance of case. notice under section 148 of the Name: RAJAT Income-tax Act, 1961? BANSAL Designation: PCCIT, DELHI Date: 20/03/2023 15. It is evident that the approval order is bereft of any reasons. It does not even refer to any material that may have weighed in the grant of approval

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

u/s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‗the Act‘) dated by the Assessing Officer, Agra (hereinafter referred to as ‗ld. AO‘). 2. At the outset, I find that there is a delay in filing of appeal by the revenue before us by 846 days. Considering the reasons adduced in the condonation petition

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)

24,558/- on ‘protective basis’ u/s 68 r.w.s 115BBE of the Act, with a finding that substantive addition be made in the hands of beneficiary being the assessee HMA Agro Industries Ltd. It was further stated in the show cause notice that the AO has failed to examine and establish the modus operandi of bogus purchases and, thus

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)

24,558/- on ‘protective basis’ u/s 68 r.w.s 115BBE of the Act, with a finding that substantive addition be made in the hands of beneficiary being the assessee HMA Agro Industries Ltd. It was further stated in the show cause notice that the AO has failed to examine and establish the modus operandi of bogus purchases and, thus

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)

24,558/- on ‘protective basis’ u/s 68 r.w.s 115BBE of the Act, with a finding that substantive addition be made in the hands of beneficiary being the assessee HMA Agro Industries Ltd. It was further stated in the show cause notice that the AO has failed to examine and establish the modus operandi of bogus purchases and, thus

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

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

BIKESH KUMAR,FIROZABAD vs. INCOME TAX OFFICER 2(2)(1) , FIROZABAD

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

Bench: Shri M. Balaganeshbikesh Kumar, Vs. Income Tax Officer, Nagla Bhoop Nasirpur, Ward-2(2)(1), Shikhabad Firozabad, Firozabad Firozabad (Appellant) (Respondent) Pan: Bglpk0327A Assessee By : Shri Rajendra Sharma, Adv Shri Manuj Sharma, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 23/01/2026 Date Of Pronouncement 03/02/2026

u/s 250 is bad in law, liable to be set aside.” 3. I have heard the rival submissions and perused the materials available on record. The assessee is engaged in the business of selling potatoes to persons outside Agra for which the buyers were sending the sales consideration by depositing the money in the bank account of the assessee

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

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. 149 operate

ANIL KUMAR AGARWAL,AGRA vs. DCIT 2(1)(1), AGRA, AGRA

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh(Through Virtual Hearing) Anil Kumar Agarwal, Vs. Dy. Cit, 44, R. S. Residency, Circle-2(1)(1), Dayal Bagh, Agra, Up Agra (Appellant) (Respondent) Pan: Aampa3335J Assessee By : Shri Rajni Kant Verma, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 17/09/2025 Date Of Pronouncement 19/11/2025

u/s 143(3) r.w.s. 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated by the Assessing Officer, DCIT, Circle-2(1)(1), Agra (hereinafter referred to as ‘ld. AO’). 2. The only issue to be decided on merits in this appeal is as to whether the Learned JCIT(Appeals) was justified in confirming the addition

GUMAN SINGH KUSHWAH,SHIVPURI vs. INCOME TAX OFFICER, ASHOKNAGAR

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

Bench: Shri M. Balaganeshgumnam Singh Kushwah, Vs. Income Tax Officer, Infront Of Collector Kothi, Ashok Nagar, Shiv Colony, Shivpuri, Mp Mp (Appellant) (Respondent) Pan: Bcjpk2729Q Assessee By : Shri Ashish Goyal, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 22/01/2026

u/s 147 r.w.s. 144B of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 16.03.2022 by the Assessing Officer, National Faceless Assessment Centre, Delhi (hereinafter referred to as ‘ld. AO’). 2. One of the ground raised before me is that the learned NFAC had mechanically confirmed the order of the ld AO without giving his independent findings

YOGENDRA SHARMA,DELHI vs. INCOME TAX OFFICER, ETAH

In the result, the appeal preferred by assessee is allowed

Bench: : Shri S. Rifaur Rahmanassessment Year: 2012-13 Yogendra Sharma, I-4695, 2Nd Vs. Income-Tax Officer, Floor, Gali No. 4-B, Balbir Nagar Ward 3(2), Etah. Extension, Shahdara, Delhi. Pan :Cgkps6492J (Appellant) (Respondent)

u/s. 143(2) and 142(1) of the Act were issued and served on the assessee. 3. During the assessment proceedings, the Assessing Officer observed that the assessee has declared income from salary of Rs.1,74,000/- and income from business of Rs.1,38,500/- against gross receipts of Rs.4,50,000/-. Besides above, the assessee has declared nil income