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

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

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

45 as income of the previous year in which the period of three years from the date of the transfer of the original asset expires; and (ii) the assessee shall be entitled to withdraw the unutilised amount in accordance with the scheme aforesaid.” On perusal of above section, following conditions are required to be fulfilled for claiming the exemption

SMT. GARIMA MEHTA,GWALIOR vs. I.T.O., WARD-1(2), GWALIOR

In the result, the appeal is partly allowed

Bench: Shri A. D. Jain & Dr. Mitha Lal Meena

45,839/-, the AO worked out the income at Rs.7,61,255/-. 12. The ld. CIT(A) observed that the nature of business in both the businesses of the assessee, i.e., domestic and exports, was the same, since in both the businesses, the assessee was dealing in software development. The assessment order, applying the net profit rate

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

HARDAYAL MILK PRODUCTS PRIVATE LIMITED,SHIKOHABAD vs. DCIT, CIRCLE-2(2)(1), FIROZABAD, FIROZABAD

In the result, the appeal preferred by the assessee is partly

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2013-14

45,000 0.40% 2013-14 2,50,43,49,6 14,24,92,19 5.69% 1,01,55,7 0.41% 70 8 01 The aforesaid table would clearly demonstrate that the trading results disclosed by the appellant are stable and consistent, showing reasonable profit margins. There is no significant variation warranting any adverse inference. Further, despite the consistent financial performance

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

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

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

3), the assessment made is illegal and bad in law. ITA No.216/Agr/2016, 183/Agr/2014,439/Agr/2015 & ITA No. 177/Agr/2014 13 (4) Because Ld.CIT(A) has erred in law and on facts in holding activities of the appellant as commercial activity under the provisions of Sec.2(15). LdCIT(A) has erred in law and on facts in not allowing benefit of section

BIPIN BABU AGRAWAL,MATHURA vs. ACIT, CENTRAL CIRCLE, AGRA, AGRA

The appeal stands partly allowed

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No.149/Agr/2022 (िनधा"रणवष" / Assessment Year: 2019-20) Shri Bipin Babu Agarwal Dcit / Acit बनाम/ 16, Kamla Vihar Colony Central Circle Vs. Masani, Mathura 281 001 Agra "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aawpa-0864-C (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri M. M. Agrawal (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Dr. Arun Kumar Yadav – Ld. Cit-Dr सुनवाईकीतारीख/Date Of Hearing : 19-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 28-03-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2019-20 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Kanpur-4 [Cit(A)] Dated 28-06-2022 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 143(3) Of The Act On 30-09-2021. Having Heard Vehement Arguments Of Both The Sides & Upon Perusal Of Case Records, The Appeal Is Disposed-Off As Under. During The Year, The Assessee Being Resident Individual Carried Out Business Activities In Proprietorship Concern Namely M/S Parshant Silver Handicrafts. Assessment Proceedings 2.1 The Assessee’S Return Of Income Was Scrutinized Pursuant To Search Action On R.S. Bullion & Jewellers Group Of Cases At Mathura

3,64,85,327/- (Rs. 2,43,62,627/- + Rs. 1,21,22,700/-) and accommodation entries of Rs. 45,61,754/- (Rs. 20,00,000/- + Rs. 25,61,754/-) has been considered to be embedded in the addition of Rs. 5,10,00,000/- since this cash may be considered as proceeds of sales of unaccounted purchases and benefit

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.”

45 ITD 12 (Bang.) - DCIT vs. Krorilal Aggarwal (1994) 50 TTJ (Jab.) 393 - M.V. Mathew vs. ITO (1993) 46 TTJ 353 (Coch.) - ITO vs. W.D. Estate (P.) Ltd. (1993) 46 TTJ (Bom.) 143 - Delhi ITAT in case of Shri Neeraj Goel vs. ACIT in ITA No.5951/.Del/2017 vide order dated 21.03.2018 - Mumabi ITAT in the case of ITO vs. Kranti Impex

NALANDA BUILDERS &DVELOPERS I P LTD,AGRA vs. DCIT CENTRAL CIRCLE, AGRA

The appeals are allowed for statistical purposes

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

68 of the Income Tax Act, The penalty imposed by the AO, enhanced by the CIT (Appeals) is against the provisions of Section 271AAB(1)(b)/271AAB(1)(c) of Income Tax Act, same are liable to be cancelled. 4. That while enhancing the penalty, the CIT (Appeals) has not allowed the proper opportunity to the appellant for filing

JOURA CO-OPERATIVE MARKETING SOCIETY LIMITED ,MORENA, MADHYA PRADESH vs. ITO, MORENA

In the result, appeal filed by the assessee is allowed

Bench: : Shri S. Rifaur Rahmanassessment Year: 2018-19 Joura Co-Operative Marketing Vs. Income-Tax Officer, Society Limited Ward-1, Morena The Joura Dist Morena Dist. Morena Pan :Aabaj1828K (Appellant) (Respondent) Assessee By Shri S. N. Agarwal, Ca Department By Shri Anil Kumar, Sr. Dr Date Of Hearing 16.02.2026 Date Of Pronouncement 19.02.2026 Order

45,025/- . In response, the assessee filed a reply which is reproduced by the Assessing Officer at page 8 & 9 of the assessment order. After considering the submissions, Assessing Officer observed that the transactions carried 2 | P a g e out by the assessee are frequent and multiples of varied amounts and pertaining to payments/received from various parties and also

A.C.I.T., CIRCLE-4(1), AGRA vs. DR. ANIL KUMAR VERMA, AGRA

In the result, the appeal of the Revenue is dismissed and the C

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meenaa.Y. :2009-10

68,375 4,50,000 From the above, it is clear that- 1. In the case of Bharat Bansal, the assessee has shown fresh unsecured loan of Rs 3 lacs while the loan of Rs 1.50 lacs was confirmed by the party. The closing balances of unsecured loans is Rs 3,00,000/- while the assessee in his books

KARAM UDHOG,AGRA vs. J.A.O., DY. CIT.., CIRCLE-1(1)(1), AGRA

In the result all the appeals filed by the

Bench: : Shri Anil Chaturvedi & Sh. Laliet Kumarassessment Year: 2018-19 Sharda Oil Industries Pvt. Ltd. Vs. Jo Circle-2(1)(1), 17, Tundla Road, Nunhai Agrau.P. Agrau.P. Pan: Aaecs1396L (Appellant) (Respondent) Assessment Year: 2019-20 Prem Motors Pvt. Ltd. Vs. Jo Dcit/Acit, Circle-1(1) Kanwal Complex, B-32, A.G. Office Gwalior M.P. Road, Gwalior M.P. 474001 Pan: Aabcp2035Q (Respondent) (Appellant) Assessment Year: 2019-20 Karam Udyog Vs. Jo Circle - 1(1)(1) 9, Gailana Road Agra U.P. Agra U.P. Pan: Abbfk0897L (Appellant) (Respondent)

3. In the case of CIT Vs. Bharat Hotels Ltd. 410 ITR 417, the question of law at serial no. 2 framed by the Hon’ble High Court reads as under: (order dated 06.09.2018) “2. Whether the payment of provident fund and employees state insurance dues deposited by the assessee within the grace period would qualify for deduction under Section

SHARDA OIL INDUSTRIES PVT. LTD.,AGRA vs. JURISDICTIONAL OFFICER,CIRCLE-2(1)(1), AGRA

In the result all the appeals filed by the

Bench: : Shri Anil Chaturvedi & Sh. Laliet Kumarassessment Year: 2018-19 Sharda Oil Industries Pvt. Ltd. Vs. Jo Circle-2(1)(1), 17, Tundla Road, Nunhai Agrau.P. Agrau.P. Pan: Aaecs1396L (Appellant) (Respondent) Assessment Year: 2019-20 Prem Motors Pvt. Ltd. Vs. Jo Dcit/Acit, Circle-1(1) Kanwal Complex, B-32, A.G. Office Gwalior M.P. Road, Gwalior M.P. 474001 Pan: Aabcp2035Q (Respondent) (Appellant) Assessment Year: 2019-20 Karam Udyog Vs. Jo Circle - 1(1)(1) 9, Gailana Road Agra U.P. Agra U.P. Pan: Abbfk0897L (Appellant) (Respondent)

3. In the case of CIT Vs. Bharat Hotels Ltd. 410 ITR 417, the question of law at serial no. 2 framed by the Hon’ble High Court reads as under: (order dated 06.09.2018) “2. Whether the payment of provident fund and employees state insurance dues deposited by the assessee within the grace period would qualify for deduction under Section

PREM MOTORS PRIVATE LIMITED ,GWALIOR vs. JURISDICTIONAL ASSESSING OFFICER ,DCIT/ACIT,CIRCLE1(1), GWALIOR

In the result all the appeals filed by the

Bench: : Shri Anil Chaturvedi & Sh. Laliet Kumarassessment Year: 2018-19 Sharda Oil Industries Pvt. Ltd. Vs. Jo Circle-2(1)(1), 17, Tundla Road, Nunhai Agrau.P. Agrau.P. Pan: Aaecs1396L (Appellant) (Respondent) Assessment Year: 2019-20 Prem Motors Pvt. Ltd. Vs. Jo Dcit/Acit, Circle-1(1) Kanwal Complex, B-32, A.G. Office Gwalior M.P. Road, Gwalior M.P. 474001 Pan: Aabcp2035Q (Respondent) (Appellant) Assessment Year: 2019-20 Karam Udyog Vs. Jo Circle - 1(1)(1) 9, Gailana Road Agra U.P. Agra U.P. Pan: Abbfk0897L (Appellant) (Respondent)

3. In the case of CIT Vs. Bharat Hotels Ltd. 410 ITR 417, the question of law at serial no. 2 framed by the Hon’ble High Court reads as under: (order dated 06.09.2018) “2. Whether the payment of provident fund and employees state insurance dues deposited by the assessee within the grace period would qualify for deduction under Section

ACIT-CIRCLE-2(1)(1), AGRA vs. PUNEET AGARWAL, AGRA

In the result, the appeal filed by the assessee is allowed, the CO raised by the assessee and appeal filed by the Revenue are dismissed

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

45 and 46 of Document Lp-22 from 1 to 50 were seized from the search of Pushpanjali Constructions Pvt. Ltd., Pushpanjali 4. 17.10.2014. Hospital and Research Centre Pvt. Ltd. and P.P. Buildcon Pvt. Ltd. at premises Pushpanjali Palace, Delhi Gate, Agra. The case of the assessee was transferred to the 5. 20.07.2015 DCIT, Central Circle, Agra vide order passed

ACIT-CIRCEL-2(1)(1), AGRA vs. MAYANK AGRAWAL, AGRA

In the result, the appeal filed by the assessee is allowed, the CO raised by the assessee and appeal filed by the Revenue are dismissed

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

45 and 46 of Document Lp-22 from 1 to 50 were seized from the search of Pushpanjali Constructions Pvt. Ltd., Pushpanjali 4. 17.10.2014. Hospital and Research Centre Pvt. Ltd. and P.P. Buildcon Pvt. Ltd. at premises Pushpanjali Palace, Delhi Gate, Agra. The case of the assessee was transferred to the 5. 20.07.2015 DCIT, Central Circle, Agra vide order passed