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

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

INCOME TAX OFFICER-1, MORENA vs. SHRI AGRASEN LOGISTICS, JOTAI ROAD, PORSA,

In the result, the appeal of the Revenue is dismissed

section 68. SLP dismissed by Supreme Court reported at 258 Tахтап\n160 (SC).\n17.3 It was held by Hon'ble Gujarat High Court in Blessing Construction Vs ITO [2013] 214\nТахтап 645 (Gujarat) where sizeable amounts were deposited in cash in account of\ndepositors only before their withdrawal through cheques in favour of assessee, addition\nwas justified. Surrounding Circumstances

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

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

68,984 in respect of Interest on FOR out of Path Kar receipts. (14) Because the order appealed against is contrary to the facts, law and principles of natural justice. (15) The appellant craves leave to add, delete, modify or substitute any or all the grounds of appeal at any appropriate time.” ITA No.216/Agr/2016, 183/Agr/2014,439/Agr/2015 & ITA No. 177/Agr/2014

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

sections 68 of the act. Merely, filing of an affidavit of the partner would not sufficient to discharge the assessees primary onus of credit liability to verify the three ingredient the identity, credit worthiness and genuineness of the transaction. I.T.A No. 212/Agra/2018 15

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

68 of the Act for the share application money received by it and after satisfying himself, he had accepted the transaction as genuine. Therefore, in the light of the proviso to u/s. 147 of the Act, there was no failure on part of the Assessee to disclose fully and truly, all material facts relating to the information regarding accommodation entries

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

68 of the Act for the share application money received by it and after satisfying himself, he had accepted the transaction as genuine. Therefore, in the light of the proviso to u/s. 147 of the Act, there was no failure on part of the Assessee to disclose fully and truly, all material facts relating to the information regarding accommodation entries

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

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)

section 115BBE of the Act which enhance the rate of tax could be made applicable only from 01.04.2017, relevant to A.Y. 2018-19 and not earlier year.” 8. In support, learned AR for assessee has placed reliance on the decisions of coordinate Benches of Delhi Tribunal in Ankit Garg vs. ITO (ITA No.5507/Del/2024 (A.Y. 2017-18) – order dated

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

section 68 of the Act. 12. The Ld. CIT(A) during the course of hearing of the appeal after receipt of written submission filed by the assessee sought further evidences from the assessee pertaining to the advance so received from M/s Easyway Solutions (P) Ltd, which were partly brought on records, Ld. CIT(A) referred the matter

ITO 1(2), GWALIOR vs. SMT REENA AGRAWAL, GWALIOR

In the result, the appeal is allowed for statistical purposes

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meenaassessment Year: 2012-13

15 along with front wall and entry gate at Emerland Garden, Gutaiya Scheme No. VII vide registered purchase deed dated 30.03.2012. The said plot was purchased by the assessee along with husband for a total consideration of Rs.2,89,39,690/-. The assessee had also pointed out a contractor for the purpose of construction of ground floor on turnkey basis

AKHIL BHARTIYA GAHOI VAISHAY CHARITABLE TRUST,GWALIOR vs. INCOME TAX OFFICER, EXEMPTION, WARD EXEMPLTION

In the result, the appeal of the assessee is dismissed

15,780/-. Assessment was framed under section 143(3) of the Act on 29-12-2019 determining total income at Rs 25,60,360/- after making addition of Rs 25,44,579/- on account of unexplained cash credit under section 68

LOKENDRA KUMAR GAUTAM,MATHURA vs. ITO WARD, 1(3)(2), MATHURA

In the result, assessee’s appeal is allowed

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2017-18

68 read 8 | P a g e with section 115BBE is liable to be deleted. The appeal of the assessee deserves to be allowed. 15

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

68 of the Act in the hands of the firm. 15. The Assessing Officer has to satisfy whether the penalty proceedings be initiated or not during the course of the assessment proceedings and the Assessing Officer is not required to record his satisfaction in a particular manner or reduce it into writing. The scope of section

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

15,90,061/- and claimed the same as exempt u/s 10(38) of the Act. f. HPC Biosciences Ltd is a scrip listed on Bombay stock Exchange (BSE). g. The shares were sold by the assessee in secondary market, through a stock broker duly registered with SEBI in the recognised stock exchange. h. The sale transaction carried out in secondary

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 15

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

SANJANA GUPTA,JHANSI vs. ITO-WARD-2(3)(1) JHANSI, JHANSI

In the result, appeal of the assessee is allowed

Bench: Shri M. Balaganeshsanjana Gupta, Vs. Ito, 130, Gudri Bazar, Jhansi Ward-2(3)(1), Jhansi (Appellant) (Respondent) Pan: Awbpg1536E Assessee By : Smt Prathna Jalan, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026 O R D E R

15. The use of the word "thereon" is important and it reflects that the Tribunal has to confined itself to the questions, which are arising or are subject matter in the appeal and it cannot be travelled beyond the same. The power to pass such orders as the Tribunal thinks fit can be exercised only in relation to the matter

ARJUN TRADING CO. PVT. LTD.,FIROZABAD vs. I.T.O.-5(1), FIROZABAD

In the result, the appeal is allowed

Bench: Shri A. D. Jain & Dr. Mitha Lal Meenaarjun Trading Company Private Vs..Ito-5,(1), Ltd. A-4, Ganesh Nagar, Firozabad. Firozabad. Panno.Aadca7230J (Assessee) (Revenue)

section 68 i.e. the identity, creditworthiness and genuineness of transactions involved, has not been proved by the assessee, therefore, the AO's action, in making the addition is found justified and the same is therefore sustained and confirmed. Accordingly, the addition of Rs. 59,80,000/- as made by the AO u/s 68 of the Act is hereby