ALLAHABAD DEVELOPMENT AUTHORITY,ALLAHABAD vs. ACIT (EXEMPTION), LUCKNOW

In the result all three appeals of the Assessee are partly allowed

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

3) and statutory notices under section 143(2) / 142(1) of the Income Tax Act, 1961 were issued by the learned AO from time to time. The main question that was addressed by the Assessing Officer, was with regard to the claim of the assessee for grant of exemption under sections 11, 12 and 13 of the Income

SBW UDYOG LIMITED,,PRAYAGRAJ vs. DCIT, CIR-1,, ALLAHABAD

In the result, the appeal of the assessee is dismissed

Bench: Sh.Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y.2021-22 Sbw Udyog Limited, Vs. Deputy Commissioner Of Income 44, Thornhill Road, Prayagraj Tax, Circle-1, Prayagraj Pan:Aadcs2883B (Appellant) (Respondent) Assessee By: Sh. N.C. Agrawal, C.A. Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 18.12.2024 Date Of Pronouncement: 13 .03.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed Against The Orders Of The Ld. Cit(A) Under Section 250 Of The Income Tax Act, 1961 On 31.01.2024, Dismissing The Appeal Of The Assessee Against The Orders Of The Cpc Bengaluru, Under Section, 143(1) Dated 17.10.2022. Subsequently, The Said Appeal Was Migrated To The Nfac & Later On, The Appeal Proceedings Were Transferred To The Additional / Jcit(A), Aurangabad, Who Has Dismissed The Appeal Of The Assessee. The Grounds Of Appeal Preferred By The Assessee Are As Under:- “1. Because, Income Tax Department, Ministry Of Finance, Government Of India Has Observed In The Notice Under Section 250 Of The Income Tax Act, 1961, Which Reads As Under:- "The Income Tax Department Recognizes & Is Sensitive To The Hardships Being Faced By Taxpayers In Coping With The Challenges Posed By Covid-19 Pandemic." Consequently, Appeal Is Liable To Be Allowed.

3) or under section 143(1). Therefore, in view of the aforesaid, we hold that once the legal position had been made clear in the case of Checkmate Services (P)Ltd (supra) and the disallowance had been indicated by the information in the audit report, the Assessing Officer was well within his rights to make the disallowance, while processing

M/S. SUBHASH STONE INDUSTRIES (P) LTD.,NAINITAL vs. DCIT, CENTRAL CIRCLE, ALLAHABAD

In the result, appeal filed by the assessee in ITA no

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

disallowance under various heads to the tune of Rs. 6,26,650/- and completed the assessment u/s 143(3), vide order dated 21-12- 2010. The Assessing Officer while framing the assessment u/s 153A of the Act has added an amount of Rs. 6,26,650/- which was earlier added U/s 143(3) of the Act. It is relevant

JYOTI MEDISERVICES PRIVATE LIMITED,,ALLAHABAD vs. DCIT, CENTRAL CIRCLE,, ALLAHABAD

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

3 (SC). Similar view has also been taken by Hon'ble Delhi High Court in the cases reported at Pr.CIT vs. Pioneer Tour Planner (P.) Ltd. 160 taxmann.com 652/ 465 ITR 356 (Delhi) and in Pr.CIT vs. MDLR Hotels (P.) Ltd. 166 taxmann.com 327 (Delhi). (J.1.4) In the case of Pr.CIT vs. Subodh Agarwal [2023] 149 taxmann.com 373 (Allahabad High

JYOTI MEDISERVICES PRIVATE LIMITED,ALLAHABAD vs. DCIT, CENTRAL CIRCLE, ALLAHABAD, ALLAHABAD

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

3 (SC). Similar view has also been taken by Hon'ble Delhi High Court in the cases reported at Pr.CIT vs. Pioneer Tour Planner (P.) Ltd. 160 taxmann.com 652/ 465 ITR 356 (Delhi) and in Pr.CIT vs. MDLR Hotels (P.) Ltd. 166 taxmann.com 327 (Delhi). (J.1.4) In the case of Pr.CIT vs. Subodh Agarwal [2023] 149 taxmann.com 373 (Allahabad High

ASSISTANT COMMISSIONER OF INCOME TAX, ALLAHABAD vs. JYOTI MEDISERVICES LTD., ALLAHABAD

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

3 (SC). Similar view has also been taken by Hon'ble Delhi High Court in the cases reported at Pr.CIT vs. Pioneer Tour Planner (P.) Ltd. 160 taxmann.com 652/ 465 ITR 356 (Delhi) and in Pr.CIT vs. MDLR Hotels (P.) Ltd. 166 taxmann.com 327 (Delhi). (J.1.4) In the case of Pr.CIT vs. Subodh Agarwal [2023] 149 taxmann.com 373 (Allahabad High

JYOTI MEDISERVICES PRIVATE LIMITED, ,ALLAHABAD vs. DCIT, CENTRAL CIRCLE, , ALLAHABAD

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

3 (SC). Similar view has also been taken by Hon'ble Delhi High Court in the cases reported at Pr.CIT vs. Pioneer Tour Planner (P.) Ltd. 160 taxmann.com 652/ 465 ITR 356 (Delhi) and in Pr.CIT vs. MDLR Hotels (P.) Ltd. 166 taxmann.com 327 (Delhi). (J.1.4) In the case of Pr.CIT vs. Subodh Agarwal [2023] 149 taxmann.com 373 (Allahabad High

M/S KESARWANI ZARDA BHANDAR,,ALLAHABAD vs. JT.CIT,, ALLAHABAD

In the result, the appeal of Revenue is dismissed and the appeal of the assessee is partly allowed

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

disallowance by Rs.73,16,513/- on account of bogus purchases even though the facts brought on records by the AO have been admitted by the CIT(A). 6. That the order of the Ld. CIT (A) being erroneous in law and on facts needs to be vacated and the order of the A.O. be restored.” 2. The facts

ACIT,, ALLAHABAD vs. KESARWANI ZARDA BHANDAR,, ALLAHABAD

In the result, the appeal of Revenue is dismissed and the appeal of the assessee is partly allowed

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

disallowance by Rs.73,16,513/- on account of bogus purchases even though the facts brought on records by the AO have been admitted by the CIT(A). 6. That the order of the Ld. CIT (A) being erroneous in law and on facts needs to be vacated and the order of the A.O. be restored.” 2. The facts

YOGI SATYAM,ALLAHABAD vs. ITO, WARD-1(5), ALLAHABAD

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

3) read with section 147 of the Act. 11. BECAUSE after having verified all payments made by the appellant, there remains no scope of disallowance on ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 8 of 79 adhoc basis by the authorities below, the addition of Rs.40,000/- sustained by the CIT(A) is wholly

SANJANA,ALLAHABAD vs. ITO, WARD-1(5), ALLAHABAD

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

3) read with section 147 of the Act. 11. BECAUSE after having verified all payments made by the appellant, there remains no scope of disallowance on ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 8 of 79 adhoc basis by the authorities below, the addition of Rs.40,000/- sustained by the CIT(A) is wholly

YOGI SATYAM,ALLAHABAD vs. ITO, WARD- 1(5), ALLAHABAD

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

3) read with section 147 of the Act. 11. BECAUSE after having verified all payments made by the appellant, there remains no scope of disallowance on ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 8 of 79 adhoc basis by the authorities below, the addition of Rs.40,000/- sustained by the CIT(A) is wholly

SANJANA,ALLAHABAD vs. ITO, WARD- 1 (5), ALLAHABAD

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

3) read with section 147 of the Act. 11. BECAUSE after having verified all payments made by the appellant, there remains no scope of disallowance on ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 8 of 79 adhoc basis by the authorities below, the addition of Rs.40,000/- sustained by the CIT(A) is wholly

SANJANA,ALLAHABAD vs. ITO, WARD- 1 (5), ALLAHABAD

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

3) read with section 147 of the Act. 11. BECAUSE after having verified all payments made by the appellant, there remains no scope of disallowance on ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 8 of 79 adhoc basis by the authorities below, the addition of Rs.40,000/- sustained by the CIT(A) is wholly

SANJANA,ALLAHABAD vs. ITO, WARD- 1(5), ALLAHABAD

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

3) read with section 147 of the Act. 11. BECAUSE after having verified all payments made by the appellant, there remains no scope of disallowance on ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 8 of 79 adhoc basis by the authorities below, the addition of Rs.40,000/- sustained by the CIT(A) is wholly

YOGI SATYAM,ALLAHABAD vs. ITO, WARD- 1(5), ALLAHABAD

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

3) read with section 147 of the Act. 11. BECAUSE after having verified all payments made by the appellant, there remains no scope of disallowance on ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 8 of 79 adhoc basis by the authorities below, the addition of Rs.40,000/- sustained by the CIT(A) is wholly

YOGI SATYAM,ALLAHABAD vs. ITO, WARD- 1 (5), ALLAHABAD

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

3) read with section 147 of the Act. 11. BECAUSE after having verified all payments made by the appellant, there remains no scope of disallowance on ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 8 of 79 adhoc basis by the authorities below, the addition of Rs.40,000/- sustained by the CIT(A) is wholly

SANJANA,ALLAHABAD vs. ITO, WARD-1(5), ALLAHABAD

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

3) read with section 147 of the Act. 11. BECAUSE after having verified all payments made by the appellant, there remains no scope of disallowance on ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 8 of 79 adhoc basis by the authorities below, the addition of Rs.40,000/- sustained by the CIT(A) is wholly