MOHAMMAD GHUFRAN,KAUSHAMBI vs. ITO - 2(5), KAUSHAMBI

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

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2017-18 Mohammad Ghufran V. The Income Tax Officer 2(5) Hazratganj Kaushambi Karari Manjhanpur Kaushambi (U.P) Tan/Pan:Bpfpg0938A (Appellant) (Respondent) Appellant By: Shri Mohit Singh Respondent By: Shri A. K. Singh, D.R. O R D E R

147 read with section 144 of the Act. 2.1 The AO also invoked the provisions of section 115BBE of the Act and initiated penalty proceedings under sections 271AAC and 271F of the Act, separately. 2.2 Aggrieved, the Assessee preferred an appeal before the NFAC, which dismissed the appeal of the assessee ex-parte qua the assessee and confirmed the order

SHERVANI SUGAR SYNDICATE LIMITED,GHAZIABAD vs. DC/ACIT-2, ALLAHABAD, ALLAHABAD

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguriaassessment Year: 2012-13 Shervani Sugar Syndicate V. National Faceless Limited Assessment Centre 17, Navyug Market, Ghaziabad- Delhi. 201001. Pan:Aadcs3658L (Appellant) (Respondent) Assessment Year: 2012-13 Shervani Sugar Syndicate V. Dc/Acit-2, Allahabad Limited Office Of The Assistant C/O 17, Navyug Market, Commissioner Of Income Ghaziabad-201001. Tax, Allahabad, Allahabad-211001. Pan:Aadcs3658L (Appellant) (Respondent) Appellant By: Shri Madhav Kapur Respondent By: Shri A. K. Singh, Sr. Dr Date Of Hearing: 23 09 2025 Date Of Pronouncement: 30 09 2025 O R D E R

147 to 151 of the Income Tax Act, 1961. 5. That on the facts and circumstances of the case and in law, the Ld. CIT(A). erred in law in sustaining the said addition for Rs. 60,90,164/under the head Other Sources made by the Ld. AO without allowing the inter-head set off of current year loss

SHERVANI SUGAR SYNDICATE LIMITED,C/O B. K. KAPUR CO. vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguriaassessment Year: 2012-13 Shervani Sugar Syndicate V. National Faceless Limited Assessment Centre 17, Navyug Market, Ghaziabad- Delhi. 201001. Pan:Aadcs3658L (Appellant) (Respondent) Assessment Year: 2012-13 Shervani Sugar Syndicate V. Dc/Acit-2, Allahabad Limited Office Of The Assistant C/O 17, Navyug Market, Commissioner Of Income Ghaziabad-201001. Tax, Allahabad, Allahabad-211001. Pan:Aadcs3658L (Appellant) (Respondent) Appellant By: Shri Madhav Kapur Respondent By: Shri A. K. Singh, Sr. Dr Date Of Hearing: 23 09 2025 Date Of Pronouncement: 30 09 2025 O R D E R

147 to 151 of the Income Tax Act, 1961. 5. That on the facts and circumstances of the case and in law, the Ld. CIT(A). erred in law in sustaining the said addition for Rs. 60,90,164/under the head Other Sources made by the Ld. AO without allowing the inter-head set off of current year loss

JAI MAA DURGA TRADERS,BALLIA vs. COMMISSIONER OF INCOME-TAX (APPEALS), INCOME TAX DEPARTMENT

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

Bench: Sh. Subhash Malguria & Sh. Nikhil Choudharya.Y. 2012-13 Jai Maa Durga Traders, Vs. Commissioner Of Income-Tax Ballia (Appeals), Income Tax Department Pan:Aagfj8468H (Appellant) (Respondent) Assessee By: Sh. Kumar Ankit Srivastava, Adv Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 10.02.2025 Date Of Pronouncement: 01.05.2025 O R D E R Per Nikhil Choudhary, A.M.: [ This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A), Nfac Dated 20.05.2024 Under Section 250 Of The Income Tax Act, 1961 Dismissing The Appeal Of The Assessee. The Grounds Of Appeal Filed By The Assessee Are Detailed & Run Into 16 Pages. Accordingly, For Reasons Of Brevity, The Grounds Of Appeal Are Not Being Reproduced In The Order But The Essence Of The Grounds Are That The Unilateral Order In Question Was Excessive, Illegal & Without Justice & That The Complete Details Of Inward Supplies & Outward Supplies Received By The Assessee In The Relevant Year Had Been Submitted, The Accounts Had Been Audited & Audit Report Uploaded On The Portal. The Firm Had Erroneously Been Allotted A Second Pan In The F.Y. 2011-12 On Application For Duplicate Pan & This Second Pan Had Been Furnished To The Bank While The Itr & Tax Audit Report Had Been Submitted On The Existing Pan. As A Result Of This, An Impression Had Been Created That There Were Unexplained Deposits In The Bank Account But The Fact Is That All The Deposits Were 1 Jai Maa Durga Traders A.Y. 2012-13

condone the delay and admit the appeal for hearing in the interest of justice. 3. The facts of the case are that the assessee is a partnership firm engaged in wholesale trading of sugar, it purchases sugar bags in the bulk quantity from sugar mills and sells to it to retailers in the city of Ballia. It filed

HASAN JAVED,MEERANPUR vs. ITO, AMBEDKARNAGAR

In the result, the appeal of the assessee stands partly allowed for statistical purposes

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

delay in filing of this appeal is condoned; and the appeal is admitted for hearing. (C) The facts of the case, in brief, are that the assessee filed his return of income under section 148 of the Act on 24/04/2022 declaring total income of Rs.1,72,110/-. The Assessing Officer completed the assessment and passed order under section 147

RAM KUMAR MAURYA,BHADOHI vs. ITO, WARD - 1(5), BHADOHI, BHADOHI

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

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2012-13 Ram Kumar Maurya V. The Income Tax Officer Parkritkar Khamaria Ward 1(5) Bhadohi (U.P) Bhadohi Tan/Pan:Babpm1314H (Appellant) (Respondent) Appellant By: Shri Ashish Bansal, Advocate Respondent By: Shri A. K. Singh, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 22.07.2024, Passed By The Addl/Jcit(A)-6, Kolkata For Assessment Year 2012-13. 2.0 The Brief Facts Of The Case Are That The Assessee Had Not Filed The Return Of Income For The Year Under Consideration. On The Basis Of The Information In Possession Of The Income Tax Department That The Assessee Had Made Cash Deposits To The Tune Of Rs.12,84,330/- In His Saving Bank Account No.28260100004067 Maintained With Bank Of Baroda, Khamaria Branch, Bhadohi, The Case Of The Assessee Was Reopened Under Section 147 Of The Income Tax Act, 1961 (Hereinafter Called “The Act’) After Issuing Notice Under Section 148 Of The Act. In Response To The Statutory Notice Issued By The Assessing Officer

147 of the Act have neither been validly initiated nor concluded in accordance with law, hence the entire proceedings are void- ab-initio and the order dated 29.03.2019 passed under section 144 of the Act alongwith the appellate order dated 22.07.2024 passed against the appellant deserves to be set aside. 2. BECAUSE the jurisdictional notice under section

HARISH CHANDAR MISHRA,ALLAHABAD vs. INCOME TAX OFFICER- 2(1) ALLAHABAD, ALLAHABAD

In the result, the appeal is allowed for statistical purposes

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

delay in filing of this appeal is condoned; and the appeal is admitted for hearing. 3. The facts of the case, in brief, are that the assessee is an individual and engaged in agricultural activities. The assessee has not filed his return of income for the year under consideration. The assessee has purchased immovable property amount to Rs.20

AROTI GHOSH,ALLAHABAD vs. INCOME TAX OFFICER WARD-1(1), ALLAHABAD

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

condonation of delay and there is mismatch in particular of challan of appeal filing fee as furnished in Form No. 35 and copy of challan furnished. I.T.A. No.23/Alld/2025 Assessment Year:2008-09 2 2. BECAUSE the NFAC has failed to appreciate the fact that appellant has filed appeal manually in Form No. 35 on 26.04.2016 vide Acknowledgement No. Book

IRFAN AHMAD,ALLAHABAD vs. ITO RANGE 1(2),, ALLAHABAD

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

Section 138 of the Negotiable Instruments Act, 1881 and any other laws, which prescribe period(s) of limitation for instituting proceedings, outer limits (within which the court or tribunal can condone delay) and termination of proceedings. 6. As prayed for by learned Senior Counsel, M.A. No. 29 of 2022 is dismissed as withdrawn.” 5. Thus, the period of limitation from

RAJESH KUMAR,MIRZAPUR vs. NFAC,, DELHI

In the result, the appeal is allowed for statistical purposes

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2017-18 Rajesh Kumar, Vs. Nfac, Delhi Tarkapur, Mirzapur-231001 Pan:Aoopk0542B (Appellant) (Respondent) Assessee By: Sh. Praveen Godbole, C.A. Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 25.10.2024 Date Of Pronouncement: 27.12.2024 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Against The Order Of The Ld. Cit(A), Nfac Under Section 250 Of The Act, 1961 Passed On 7.03.2024. The Grounds Of Appeal Preferred Are As Under:- “1. That In Any View Of The Matter Assessment Made On Income Of Rs.1,53,13,406/ U/S 147 R.W.S. 144B Is Highly Unjustified. 2. That In Any View Of The Matter Proceeding U/S 147 Was Initiated Is Not Correct As There Was No Proper Satisfaction Nor Information With The Assessing Officer That Assessee Has Escaped Assessment Hence The Entire Proceeding Is Bad In Law. 3. That In Any View Of The Matter Addition Of Rs. 1,53, 13,406/- (1,36,16,605/- + 16,96,801/-) As Added Us/ 69A R.W.S. 115Bbe Of The Act By Alleging Unexplained Money By The Assessing As Per Para 8 Of The Assessment Order Is Highly Unjustified. 4. That In Any View Of The Matter The Assessing Officer Was Wrong In Adding Only Credit Entries In Bank Account Without Considering The Debit Entries When The Law Is Settled That Document Should Be Considered As Whole & Not A Piece- Meal Hence The Addition Made Is Highly Unjustified.

section 250 of the Act, 1961 passed on 7.03.2024. The grounds of appeal preferred are as under:- “1. That in any view of the matter assessment made on income of Rs.1,53,13,406/ u/s 147 r.w.s. 144B is highly unjustified. 2. That in any view of the matter proceeding u/s 147 was initiated is not correct as there

MOHAMMAD SAHADAT ALI,FATEHPUR vs. INCOME TAX OFFICER, NATIONAL FACELESS ASSESSMENT CENTRE

In the result, appeals in ITA No

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos.138, 139,147 & 148/Alld/2024 A.Ys. 2013-14 & 2014-15 Mohammad Sahadat Ali, Vs. Income Tax Officer, Sayyad Nagar, Khakhreru, National Faceless Assessment Khaga, Fatehpur Centre Pan:Cunpa0977K (Appellant) (Respondent) Assessee By: Sh. Aditya Chhajed & Sh. Shivang, Advocates Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 21.10.2024 Date Of Pronouncement: 29.11.2024 O R D E R Per Nikhil Choudhary, A.M.: These Four Appeals Have Been Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac Under Section 250 Of The Income Tax Act, 1961 For The A.Y. 2013-14 & 2014-15 Vide Separate Orders Dated 8.07.2024. The Grounds Of Appeal In All These Cases Are Identical & Are Reproduced As Under:- “1. On The Facts & Circumstances Of The Case, The Order Passed By The Commissioner Of Income Tax (Appeals) National Faceless Appeal Centre (Nfac). Delhi U/S 250 Of The Act Is Bad Both In The Eye Of Law & On Facts. 2. On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit (A) (Nfac) Erred In Dismissing The Appeal Filed By The Appellant On The Grounds Of Non-Submission Of Documents By The Appellant Without Considering The Submitted Document & The Facts Of The Case. The Appellant, Therefore, Prays That The Impugned Order Be Set Aside. A.Ys. 2013-14 & 2014-15 Mohammad Sahadat Ali

147 r.w.s. 144 and section 144B of the Income A.Ys. 2013-14 & 2014-15 Mohammad Sahadat Ali Tax Act on 20.03.2022 in the A.Y. 2013-14 and 21.03.2022 in the A.Y. 2014-15. The investments made by the assessee in the construction of the house property and the credits in his bank accounts were brought to tax in his hands

MOHAMMAD SAHADAT ALI,FATEHPUR vs. AO NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, appeals in ITA No

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos.138, 139,147 & 148/Alld/2024 A.Ys. 2013-14 & 2014-15 Mohammad Sahadat Ali, Vs. Income Tax Officer, Sayyad Nagar, Khakhreru, National Faceless Assessment Khaga, Fatehpur Centre Pan:Cunpa0977K (Appellant) (Respondent) Assessee By: Sh. Aditya Chhajed & Sh. Shivang, Advocates Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 21.10.2024 Date Of Pronouncement: 29.11.2024 O R D E R Per Nikhil Choudhary, A.M.: These Four Appeals Have Been Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac Under Section 250 Of The Income Tax Act, 1961 For The A.Y. 2013-14 & 2014-15 Vide Separate Orders Dated 8.07.2024. The Grounds Of Appeal In All These Cases Are Identical & Are Reproduced As Under:- “1. On The Facts & Circumstances Of The Case, The Order Passed By The Commissioner Of Income Tax (Appeals) National Faceless Appeal Centre (Nfac). Delhi U/S 250 Of The Act Is Bad Both In The Eye Of Law & On Facts. 2. On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit (A) (Nfac) Erred In Dismissing The Appeal Filed By The Appellant On The Grounds Of Non-Submission Of Documents By The Appellant Without Considering The Submitted Document & The Facts Of The Case. The Appellant, Therefore, Prays That The Impugned Order Be Set Aside. A.Ys. 2013-14 & 2014-15 Mohammad Sahadat Ali

147 r.w.s. 144 and section 144B of the Income A.Ys. 2013-14 & 2014-15 Mohammad Sahadat Ali Tax Act on 20.03.2022 in the A.Y. 2013-14 and 21.03.2022 in the A.Y. 2014-15. The investments made by the assessee in the construction of the house property and the credits in his bank accounts were brought to tax in his hands

MOHAMMAD SAHADAT ALI,FATEHPUR vs. AO NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, appeals in ITA No

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos.138, 139,147 & 148/Alld/2024 A.Ys. 2013-14 & 2014-15 Mohammad Sahadat Ali, Vs. Income Tax Officer, Sayyad Nagar, Khakhreru, National Faceless Assessment Khaga, Fatehpur Centre Pan:Cunpa0977K (Appellant) (Respondent) Assessee By: Sh. Aditya Chhajed & Sh. Shivang, Advocates Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 21.10.2024 Date Of Pronouncement: 29.11.2024 O R D E R Per Nikhil Choudhary, A.M.: These Four Appeals Have Been Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac Under Section 250 Of The Income Tax Act, 1961 For The A.Y. 2013-14 & 2014-15 Vide Separate Orders Dated 8.07.2024. The Grounds Of Appeal In All These Cases Are Identical & Are Reproduced As Under:- “1. On The Facts & Circumstances Of The Case, The Order Passed By The Commissioner Of Income Tax (Appeals) National Faceless Appeal Centre (Nfac). Delhi U/S 250 Of The Act Is Bad Both In The Eye Of Law & On Facts. 2. On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit (A) (Nfac) Erred In Dismissing The Appeal Filed By The Appellant On The Grounds Of Non-Submission Of Documents By The Appellant Without Considering The Submitted Document & The Facts Of The Case. The Appellant, Therefore, Prays That The Impugned Order Be Set Aside. A.Ys. 2013-14 & 2014-15 Mohammad Sahadat Ali

147 r.w.s. 144 and section 144B of the Income A.Ys. 2013-14 & 2014-15 Mohammad Sahadat Ali Tax Act on 20.03.2022 in the A.Y. 2013-14 and 21.03.2022 in the A.Y. 2014-15. The investments made by the assessee in the construction of the house property and the credits in his bank accounts were brought to tax in his hands

MOHAMMAD SAHADAT ALI,FATEHPUR vs. AO (NATIONAL FACELESS ASSESSMENT CENTRE), DELHI

In the result, appeals in ITA No

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos.138, 139,147 & 148/Alld/2024 A.Ys. 2013-14 & 2014-15 Mohammad Sahadat Ali, Vs. Income Tax Officer, Sayyad Nagar, Khakhreru, National Faceless Assessment Khaga, Fatehpur Centre Pan:Cunpa0977K (Appellant) (Respondent) Assessee By: Sh. Aditya Chhajed & Sh. Shivang, Advocates Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 21.10.2024 Date Of Pronouncement: 29.11.2024 O R D E R Per Nikhil Choudhary, A.M.: These Four Appeals Have Been Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac Under Section 250 Of The Income Tax Act, 1961 For The A.Y. 2013-14 & 2014-15 Vide Separate Orders Dated 8.07.2024. The Grounds Of Appeal In All These Cases Are Identical & Are Reproduced As Under:- “1. On The Facts & Circumstances Of The Case, The Order Passed By The Commissioner Of Income Tax (Appeals) National Faceless Appeal Centre (Nfac). Delhi U/S 250 Of The Act Is Bad Both In The Eye Of Law & On Facts. 2. On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit (A) (Nfac) Erred In Dismissing The Appeal Filed By The Appellant On The Grounds Of Non-Submission Of Documents By The Appellant Without Considering The Submitted Document & The Facts Of The Case. The Appellant, Therefore, Prays That The Impugned Order Be Set Aside. A.Ys. 2013-14 & 2014-15 Mohammad Sahadat Ali

147 r.w.s. 144 and section 144B of the Income A.Ys. 2013-14 & 2014-15 Mohammad Sahadat Ali Tax Act on 20.03.2022 in the A.Y. 2013-14 and 21.03.2022 in the A.Y. 2014-15. The investments made by the assessee in the construction of the house property and the credits in his bank accounts were brought to tax in his hands

ALOK RAI,ALLAHBAD vs. INCOME TAX OFFICER NFAC DELHI, ALLAHABAD

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

147 read with section 144 read with section 144AB of the I. T. Act (DIN I.T.A. No.48/Alld/2025 Assessment Year:2014-15 2 ITBA/AST/S/147/2021-22/1035750590(1) whereby the assessee’s total income was determined at Rs.57,10,200/-/- against the returned income of Rs.12,29,630/-. In the aforesaid assessment order addition of Rs.35,71,428/- was made towards unexplained investment

SATYA PRAKASH GUPTA,ALLAHABAD vs. ACIT, ALLAHABAD

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

147 of the Income-tax Act,1961(hereinafter called “ the Act”) .We have heard these four appeals through physical hearing mode in Open Court proceedings . 2. At the outset, it is observed that these four appeals were filed late belatedly beyond the time stipulated under Section 253(3) of the Income-tax Act, 1961. The separate Appellate Order(s) passed

SATYA PRAKASH GUPTA,ALLAHABAD vs. ACIT, ALLAHABAD

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

147 of the Income-tax Act,1961(hereinafter called “ the Act”) .We have heard these four appeals through physical hearing mode in Open Court proceedings . 2. At the outset, it is observed that these four appeals were filed late belatedly beyond the time stipulated under Section 253(3) of the Income-tax Act, 1961. The separate Appellate Order(s) passed

SATYA PRAKASH GUPTA,ALLAHABAD vs. ACIT, ALLAHABAD

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

147 of the Income-tax Act,1961(hereinafter called “ the Act”) .We have heard these four appeals through physical hearing mode in Open Court proceedings . 2. At the outset, it is observed that these four appeals were filed late belatedly beyond the time stipulated under Section 253(3) of the Income-tax Act, 1961. The separate Appellate Order(s) passed

SATYA PRAKASH GUPTA,ALLAHABAD vs. ACIT, ALLAHABAD

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

147 of the Income-tax Act,1961(hereinafter called “ the Act”) .We have heard these four appeals through physical hearing mode in Open Court proceedings . 2. At the outset, it is observed that these four appeals were filed late belatedly beyond the time stipulated under Section 253(3) of the Income-tax Act, 1961. The separate Appellate Order(s) passed