ACIT CIRCLE-4, AGRA vs. JHANSI DEVELOPMENT AUTHORITY, JHANSI

In the result the appeal of the assessee is allowed and the appeal

Bench: Shri Laliet Kumar,And Dr. Mitha Lal Meenajhansi Development Authority Vs..Dcit Circle-4, Commissionerycompus, Agra. Jhansi. (Now The Dy. Cit Panno.Aaalj0068K (Exemption) Ghaziabad. (Assessee) (Revenue) Acit, 4(1), Vs..Jhansi Development Agra. Authority (Now The Dy. Cit Commissionerycompus, Jhansi. (Exemption) Ghaziabad. Panno.Aaalj0068K (Revenue) (Assessee)

Section 2(15) of the said Act would be that it carves out an exception from the charitable purpose of advancement of any other object of general public utility and that exception is limited to activities in the nature of trade, commerce or business or any activity of rendering any service in relation to any trade, commerce or business

AGRA DEVELOPMENT AUTHORITY,AGRA vs. DCIT., CIRCLE-1, AGRA

The appeals of the assessee are allowed and the appeal of the revenue is dismissed

Section 10(23C) on the requirement that a college must maintain the status- quo, as it were, in regard to its knowledge based infrastructure. Nor for that matter is an educational institution prohibited from upgrading its infrastructure on educational facilities save on the pain of losing the benefit of the exemption under Section 10(23C). Imposing such

VERMA SERVICE STATION,FIROZABAD vs. ACIT, FIROZABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar,And Dr. Mitha Lal Meena

10. In the case of Jagmohan Ram Ram Chandra vs. CIT (2005) 274 ITR 405 (All) wherevide para 20 and 21 held as under: “20. In the case of Jairamdass Lokesh Kumar (supra), the Rajasthan High Court has held that the assessment of different persons in respect of the same income will not absolve one from liability to be taxed

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

10. We observe that it is an undisputed fact that during the original assessment proceedings completed under section 143(3) of the Act, the Assessing Officer had specifically examined the issue of share application money of Rs.18.32 crore received by the assessee from M/s Silver Heritage Nivas Pvt. Ltd. The record clearly evidences that multiple notices under sections

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

10. We observe that it is an undisputed fact that during the original assessment proceedings completed under section 143(3) of the Act, the Assessing Officer had specifically examined the issue of share application money of Rs.18.32 crore received by the assessee from M/s Silver Heritage Nivas Pvt. Ltd. The record clearly evidences that multiple notices under sections

NEETA AGARWAL,AGRA vs. INCOME TAX OFFICER, 2(1)(2), AGRA, AGRA

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

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh(Through Virtual Hearing) Neeta Agarwal, Vs. Income Tax Officer, E-23, New Agra, Agra Ward-2(1)(2), Agra (Appellant) (Respondent) Pan: Aaxpa0936E Assessee By : Shri Amit Goyal, Adv Shri Nitin Goyal, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 16/09/2025 Date Of Pronouncement 04/12/2025

68 was not applicable. 4. That on the facts and in the circumstances of the case and in law, the Ld. Commissioner of Income Tax (Appeals), NFAC has erred in confirming the disallowance of exemption of Rs. 95,20,372 being the long term capital gain arising on transfer of shares Capital Trade Link Ltd. Under section 10

SHRI OM PRAKASH SINGH,MATHURA vs. ACIT CIRCLE-3, AGRA

In the result appeal is partly allowed

Bench: Shri Sudhanshu Srivastava & Dr. Mitha Lal Meena

20,863/- 10. It is seen that rate applied by the authorities below is without any basis, no case comparable to the case of the assessee has been cited, application of N.P rate @ 8% is applied without any material on records, ignoring the past trends of NP rate which shows that in A.Y 2009-10 on turnover of Rs.1

SOURABH KUMAR SONI,ASHOKNAGAR (M.P) vs. ITO - ASHOKNAGAR, ASHOKNAGAR

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

Bench: : Shri Ramit Kocharassessment Year: 2017-18

68 read with Section 115BBE of the Income Tax Act, the NFAC has sustained Rs.2,65,518/-, relief Rs.1,20,000/-. The decision given as "dismissed" is not correct, same is to be "partly allowed." 10

JITENDRA KUMAR AGARWAL HUF,AGRA vs. DCIT, CIRCLE - 2(1)(1), AGRA

In the result, assessee’s appeal is allowed

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

20. Whether the recording of cash sales which is already declared in the books of account will attract the deeming provisions of sec. 68 or 69A of Act. We observed that the assessee has declared all the cash transactions in its books of account and merely because the cash deposits are more during the demonetization period, whether

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

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 assessee had duly proved identity, source and\ncreditworthiness of donors Commissioner

RUBY JAIN,AGRA vs. INCOME TAX OFFICER, WARD 1(1)(3), AGRA

In the result, the questions referred to us are answered as follows :

Bench: Shri M. Balaganeshruby Jain, Vs. Income Tax Officer, 1/78A, Kale Ka Tall, Delhi Ward-1(1)(3), Gate, Agra Agra (Appellant) (Respondent) Pan: Aevpj4936P Assessee By : Shri K. K. Jain, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026

10,000 made by the assessee on January 20, 1961, in the bank was not includible under section 68

M/S VERMA SERVICE STATION,FIROZABAD vs. D.C.I.T., RANGE-5, FIROZABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar,And Dr. Mitha Lal Meena

10,07,560/- and thereby the difference of Rs.Rs.68,50,000/- (-) Rs.10,07,560/- = Rs.58,42,440/- remained unexplained liability against sale of land as per the balance sheet in the hands of the assessee. 12. We are inclined to agree with the finding of the ld. CIT(A) logically supported with due reasoning by the Ld. DR that

ACIT, C 2(1)(1), AGRA, AGRA vs. SUNIL KUMAR JOSHAN, AGRA

In the result, the appeal of the revenue is dismissed and cross objection of the assessee is dismissed as infructuous

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singhacit, Vs. Sunil Kumar Joshan, Foot On Shoes, 7Th Circle-2(1)(1), Agra Km Stone, Agra Delhi Bye Pass Road, Agra (Appellant) (Respondent) Pan: Abqpj4015P Co 07/Agr/2025 (In Ita No.494/Agr/2025) (Assessment Year: 2014-15) Sunil Kumar Joshan, Vs. Acit, Foot On Shoes, 7Th Km Circle-2(1)(1), Stone, Agra Delhi Bye Agra Pass Road, Agra (Appellant) (Respondent) Pan: Abqpj4015P

68 read with section 115BBE of the Act without conducting any enquiries on his side. The following are the documentary evidences submitted by the assessee before the Learned AO to prove the nature and source of credit of the aforesaid sums:- Sl Particulars PB No. Page No. 1 Invitation letter of PHI Singapore dated 28.08.2012 with enclosures

ACIT, CC, AGRA, AGRA vs. M/S. UNITED FARM PRODUCT PRIVATE LIMITED, AGRA

In the result, appeal preferred by the revenue is dismissed

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhacit, Cc, Vs. M/S. United Farm Product Pvt. Ltd., 2/220, 2Nd Floor, Glory Plaza, Agra. Soor Sadan, M.G. Road, Agra – 282 002 (Agra) (Pan :Aaccu2505M) (Appellant) (Respondent) Assessee By : Shri Sudhir Sehgal, Advocate Shri Deependra Mohan, Ca Revenue By : Shri Arun Kumar Yadav, Cit Dr Date Of Hearing : 13.10.2025 Date Of Order : 04.12.2025 O R D E R Per S. Rifaur Rahman,Am: 1. This Appeal Is Filed By The Revenue Against The Order Of Ld. Commissioner Of Income-Tax (Appeals), Kanpur – 4 Dated 28.03.2025 For Assessment Year2022-23 Raising Following Grounds Of Appeal :- “L. Whether On Facts & Circumstances Of The Case & In Law. The Ld. Cit(A)-Iv. Kanpur Has Erred In Deleting The Addition Of Rs.43,71,37,934/- On Account Of Unexplained Expenditure U/S 69C Of The Act Incurred For Construction Of Plant At Mewat, Haryana, Without Appreciating The Fact That The Assessee Company Itself Has Surrendered Amount Of Rs.41,40,35,700/- & Admitted To Take The Unexplained Expenditure At Rs.43,71,37,934/- Incurred In The 2 Construction Of Said Plant. Hence, The Addition Made By The Ao Is Based On Admittance By The Assessee, Which Is Corroborated By The Incriminating Material Found During The Course Of Search. 2. Whether On Facts & Circumstances Of The Case & In Law, Ld. Cit(A)-Iv. Kanpur Has Erred In Deleting The Addition. Without Appreciating The Facts That The Assessing Officer Has Passed The Assessment Order After Thoroughly Examining & Analysing The Seized Material & Proper Appreciation Of Facts Of Unexplained Expenditure U/S 69C Of The Act.”

section 68 and there was no cogent reason to interfere with same merely because on a reappraisal of entire matter, it might have been possible to form a different opinion - Held, yes.” 8. Considered the rival submissions and material placed on record. We observed that the assessee is incorporated on 21.05.2018, in order to manufacture meat and meat products

PUSHPA,MATHURA vs. ITO-1(2)(3), MATHURA

In the result,both appeals are allowed

Bench: Shri Sudhanshu Srivastava & Dr. Mitha Lal Meenashri. Pushpendra Singh. Vs.. Income Tax Officer- 1(2)(3), M-22, Phase-I, Mahavidhya Colony. Agra. Mathura. Pan: Dldps6755P (Appellant) (Respondent) Smt. Pushpa Vs.. Income Tax Officer- 1(2)(3), M-22, Phase-I, Mahavidhya Colony. Agra. Mathura. Pan: Bcopd0484L (Appellant) (Respondent)

20. The last part of reasons recorded mentions the fact that assessee had not filed return of income, which according to learned D.R was itself a sufficient ground for issuing notice under section 148 of the Act as this is a case of deemed escapement in view of clause (a) of section 147 of the Act. (ASSESSMENT YEAR

SH. KULDEEP SRIVASTAVA,MATHURA vs. I.T.O., WARD-3(2), MATHURA

Appeal is dismissed

Bench: : Shri Satbeer Singh Godara & Shri Manoj Kumar Aggarwalassessment Year: 2009-10

section 50C and the same is reproduced as under: - Name of the Amount of Stamp Amount Sale Proportionate vendee total sale registration considered amount stamp value consideration value for received for assesse computing by the capital gain assesse 1 2 3 4 5 6 Sanjeev Kumar 20,30,000 18,25,000 20

MAHESH EDIBLE OIL INDUSTRIES LIMITED,DELHI vs. ASSTT. COMMISSIONER OF INCOME TAX, AGRA

The appeal of the assessee stands partly allowed

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.113/Agr/2023 (िनधा"रणवष" / Assessment Year: 2013-14) & 2. आयकरअपीलसं./ Ita No.114/Agr/2023 (िनधा"रणवष" / Assessment Year: 2014-15) & 3. आयकरअपीलसं./ Ita No.115/Agr/2023 (िनधा"रणवष" / Assessment Year: 2015-16) & 4. आयकरअपीलसं./ Ita No.116/Agr/2023 (िनधा"रणवष" / Assessment Year: 2016-17) & 5. आयकरअपीलसं./ Ita No.117/Agr/2023 (िनधा"रणवष" / Assessment Year: 2017-18) & 6. आयकरअपीलसं./ Ita No.118/Agr/2023 (िनधा"रणवष" / Assessment Year: 2018-19) & 7. आयकरअपीलसं./ Ita No.119/Agr/2023 (िनधा"रणवष" / Assessment Year: 2019-20) M/S Mahesh Edible Oil Industries Ltd. Acit-Central Circle बनाम/ 3/14-A, Jungpura-B Agra. Vs. New Delhi – 110 014. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccm-7102-J (अपीलाथ"/Appellant) : (""थ" / Respondent) & 8. आयकरअपीलसं./ Ita No.157/Agr/2023 (िनधा"रणवष" / Assessment Year: 2013-14) &

68,22,031 5,43,77,066 54,58,13,054 36,17,16,578 108,13,44,591 Purchases It was observed by Ld. AO that the bogus purchases in respect to first two parties was compiled from the bank statements of the two concerns as the assessee did not produce the ledger of these two parties. There

MAHESH EDIBLE OIL INDUSTRIES LIMITED,DELHI vs. ASSTT. COMMISSIONER OF INCOME TAX, AGRA

The appeal of the assessee stands partly allowed

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.113/Agr/2023 (िनधा"रणवष" / Assessment Year: 2013-14) & 2. आयकरअपीलसं./ Ita No.114/Agr/2023 (िनधा"रणवष" / Assessment Year: 2014-15) & 3. आयकरअपीलसं./ Ita No.115/Agr/2023 (िनधा"रणवष" / Assessment Year: 2015-16) & 4. आयकरअपीलसं./ Ita No.116/Agr/2023 (िनधा"रणवष" / Assessment Year: 2016-17) & 5. आयकरअपीलसं./ Ita No.117/Agr/2023 (िनधा"रणवष" / Assessment Year: 2017-18) & 6. आयकरअपीलसं./ Ita No.118/Agr/2023 (िनधा"रणवष" / Assessment Year: 2018-19) & 7. आयकरअपीलसं./ Ita No.119/Agr/2023 (िनधा"रणवष" / Assessment Year: 2019-20) M/S Mahesh Edible Oil Industries Ltd. Acit-Central Circle बनाम/ 3/14-A, Jungpura-B Agra. Vs. New Delhi – 110 014. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccm-7102-J (अपीलाथ"/Appellant) : (""थ" / Respondent) & 8. आयकरअपीलसं./ Ita No.157/Agr/2023 (िनधा"रणवष" / Assessment Year: 2013-14) &

68,22,031 5,43,77,066 54,58,13,054 36,17,16,578 108,13,44,591 Purchases It was observed by Ld. AO that the bogus purchases in respect to first two parties was compiled from the bank statements of the two concerns as the assessee did not produce the ledger of these two parties. There