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)

1) shall be construed as reference to the date of receiving the books of accounts or documents or assets seized by the Assessing Officer, having jurisdiction over such other person. xviii). We are relying upon the discussion on this issue by the CIT(A) in para 6.19, page 73 to page 74 and he has relied upon on various judgments

ACIT, CIRCLE-2(1)(1), AGRA, AGRA vs. SH. VISHWAMBHAR DAYAL AGARWAL, AGRA

Bench: Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

68 -Do- -Do- 2013-14 153A 69 -Do- Do- 2014-15 153A 70 -Do- -Do- 2015-16 143(3) 71 Shri Prakhar Garg ACJPG8778N 2009-10 153A 72 -Do- -Do- 2010-11 153A 73 -Do- -Do- 2011-12 153A 74 -Do- Do- 2012-13 153A 75 -Do- -Do- 2013-14 153A 76 -Do- -Do- 2014-15 153A

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

68,67,586 = Rs. 53,19,502 1,73,10,000 For computing the total cost of property sold, purchase cost of land should be added in the proportionate cost of construction as computed above. The total value of cost of purchase is computed as under: - Cost of land (7flats) + proportionate cost of construction (7flats

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 145(3) is wholly illegal in the facts and circumstances of the case of the appellant. 6. Because the Ld. CIT(A) erred, both in law and on facts, in sustaining the addition of Rs 24,68,23,586/- out of addition of Rs 42,24,51,350/- made by the Assessing Officer. The Ld. CIT(A) further

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

section 68 of the Act was deleted by observing as under:- “5.2.3 On examination of the facts on record and the material evidence presented by the appellant, the following observations are made: CO 07/AGR/2025 Sunil Kumar Joshan The art exhibition stated to be held at Singapore as claimed is supported by invitation letter of PHI Singapore dated 28.08.2012 with

SURESH CHAND GUPTA,JHANSI vs. DCIT-6, JHANSI

In the result, the assessee’s appeal is dismissed

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

1) 624, 1991 SCC (2) 558 (SC). ‘CIT vs. Popular Vehicles & Services Ltd.’, ITA No.1628/2009 iii) (Kerala) 10. Heard the rival contention, perused the material on record and the case law relied upon on the issue of validity of reopening of assessment u/s 147.The AO has recorded reason to believe u/s 147 of the IT Act 1961 as follows

VECTUS INDUSTRIES LTD.,,GWALIOR vs. DCIT/ACIT 1(1), GWALIOR

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh(Through Virtual Hearing)

73 taxmann.com 241, the appeal against which was dismissed by the Supreme Court of India in SLP No. 11485 of 2016 by order dated 5th August, 2016. 22. On this issue again this Court is unable to find any error having been committed by the ITAT. No substantial question of law arises. 23. The appeals are accordingly dismissed

VECTUS INDUSTRIES LTD.,GWALIOR vs. DCIT/ACIT 1(1), GWALIOR

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh(Through Virtual Hearing)

73 taxmann.com 241, the appeal against which was dismissed by the Supreme Court of India in SLP No. 11485 of 2016 by order dated 5th August, 2016. 22. On this issue again this Court is unable to find any error having been committed by the ITAT. No substantial question of law arises. 23. The appeals are accordingly dismissed

VECTUS INDUSTRIES LTD.,,GWALIOR vs. DCIT/ACIT 1(1) , GWALIOR

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh(Through Virtual Hearing)

73 taxmann.com 241, the appeal against which was dismissed by the Supreme Court of India in SLP No. 11485 of 2016 by order dated 5th August, 2016. 22. On this issue again this Court is unable to find any error having been committed by the ITAT. No substantial question of law arises. 23. The appeals are accordingly dismissed

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.”

73,27,808 from Loan Total Loan amount taken Loan outstanding as per Yes from Yes bank upto Bank statement as on 31.3.22 31.3.2022 is Rs.61,91,02,337/- From the above tabulated sheet in respect of the amount mentioned in the loose sheet of paper, it is clearly discernible that the amounts don't tally with the Ledger balances

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

JHASI DEVELOPMENT AUTHORITY,JHANSI vs. DY. C.I.T., 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

STATE BANK OF INDIA,GWALIOR vs. CIT A, GWALIOR

In the result, ITA No.42/Agr/2018 is allowed for statistical

68, 61, State Bank of ITO (TDS), AAACS8577K 57 City Center, BPLS11822G 85,,76,77 India, Branch- Gwalior /Ag/2018 Raghaogarh, A.Y.2013-14 Guna 58- ITO (TDS), AAACS8577K 70 & 64 State Bank of 59 City Center, BPLS11718A /Ag/2018 India, Branch- Gwalior A.Y.2013-14 Mayana, guna 60- ITO (TDS), AAACS8577K 69 & 65 State Bank of 61- City Center, BPLS11689G /Ag/2018 India, Branch- Gwalior Pagagra

STATE BANK OF INDIA,GWALIOR vs. CIT A , GWALIOR

In the result, ITA No.42/Agr/2018 is allowed for statistical

68, 61, State Bank of ITO (TDS), AAACS8577K 57 City Center, BPLS11822G 85,,76,77 India, Branch- Gwalior /Ag/2018 Raghaogarh, A.Y.2013-14 Guna 58- ITO (TDS), AAACS8577K 70 & 64 State Bank of 59 City Center, BPLS11718A /Ag/2018 India, Branch- Gwalior A.Y.2013-14 Mayana, guna 60- ITO (TDS), AAACS8577K 69 & 65 State Bank of 61- City Center, BPLS11689G /Ag/2018 India, Branch- Gwalior Pagagra

ANUPAM MITTAL,AGRA vs. ITO WARD 2(1)(1), AGRA, AGRA

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

Bench: Shri Sunil Kumar Singh & Shri Brajesh Kumar Singh[Assessment Year: 2018-19]

1. That the Commissioner of Income Tax (Appeals) (NFAC) has erred in law and on facts in sustaining the additions amounting to Rs. 71,08,000/- made u/s 68 of the Income Tax Act, 1961 on account of alleged unexplained unsecured loan (including addition of Rs.2,40,000/- made on account of disallowance of payment of interest) without properly appreciating

AJIT SINGH,SHIVPURI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, GWALIOR

In the result, assessee’s appeal ITA No 263/Agr/2025 is allowed

1 - The PCIT has gone beyond its jurisdiction and has made observations on the merits of the case 1.1 The Appellant submits that the PCIT under Section 263 was only required to see whether the Assessment order dated 22.12.2017 passed by the Ld. ITO was erroneous and prejudicial to the interest of revenue. However, in the present case

MODERN AGENCIES,JHANSI vs. ACIT CIRCLE-6, JHANSI

In the result, both the appeals of the assessee are partly

68,184.63 Working of the excess stock valued at cost as declared by the assessee on the basis of the excess quantity of material found during survey and declared in the above Profit & Loss Account at Rs. 39,13,263/- is shown to have been computed by the assessee (appellant) as under— Physical statement date of survey taken by department