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

13 of the Income Tax Act, 1961. The assessee is registered under section 12A of the 1961 Act. It is a State Government body constituted by an Act of State Government and is engaged in the business of development and sale of land for residential and commercial purposes. The object of the authority as defined under section

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.

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

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

C) Diary No.43280/2023 in the case of Pr.CIT vs. Siddharth Gupta, respectively. (J.1.2) Similarly, in the case of Pr.CIT & Anr. Vs. Sapna Gupta (supra), Hon'ble Allahabad High Court held as under: I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 74 I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 75 I.T.A. Nos.113

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

C) Diary No.43280/2023 in the case of Pr.CIT vs. Siddharth Gupta, respectively. (J.1.2) Similarly, in the case of Pr.CIT & Anr. Vs. Sapna Gupta (supra), Hon'ble Allahabad High Court held as under: I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 74 I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 75 I.T.A. Nos.113

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

C) Diary No.43280/2023 in the case of Pr.CIT vs. Siddharth Gupta, respectively. (J.1.2) Similarly, in the case of Pr.CIT & Anr. Vs. Sapna Gupta (supra), Hon'ble Allahabad High Court held as under: I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 74 I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 75 I.T.A. Nos.113

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

C) Diary No.43280/2023 in the case of Pr.CIT vs. Siddharth Gupta, respectively. (J.1.2) Similarly, in the case of Pr.CIT & Anr. Vs. Sapna Gupta (supra), Hon'ble Allahabad High Court held as under: I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 74 I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 75 I.T.A. Nos.113

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

3) of the Income Tax Act by the various higher authorities of the department so as per the principles of consistency addition made is unwarranted as the assessing officer is bound to give cognizance to the past records. (c) That in the assessment year 1999-2000 for the first time in the history of the case an identical and similar

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

3) of the Income Tax Act by the various higher authorities of the department so as per the principles of consistency addition made is unwarranted as the assessing officer is bound to give cognizance to the past records. (c) That in the assessment year 1999-2000 for the first time in the history of the case an identical and similar

KESARWANI & C0,,ALLAHABAD vs. JT CIT,, ALLAHABAD

In the result the appeal of the assessee is partly allowed

c) were initiated. During the course of assessment, the following additions were made by the ld. AO. i. On account of suppressed sale – Rs. 16,68,561/-. ii. On account of inflated expenses on the basis of print outs of CPU marked as KZ-1 – Rs. 20,76,268/-. iii. On account of repair and maintenance - Rs.10

KESARWANI & CO.,ALLAHABAD vs. JT.CIT,, ALLAHABAD

In the result the appeal of the assessee is partly allowed

c) were initiated. During the course of assessment, the following additions were made by the ld. AO. i. On account of suppressed sale – Rs. 16,68,561/-. ii. On account of inflated expenses on the basis of print outs of CPU marked as KZ-1 – Rs. 20,76,268/-. iii. On account of repair and maintenance - Rs.10

KESARWANI & C0.,ALLAHABAD vs. JT.CIT., ALLAHABAD

In the result the appeal of the assessee is partly allowed

c) were initiated. During the course of assessment, the following additions were made by the ld. AO. i. On account of suppressed sale – Rs. 16,68,561/-. ii. On account of inflated expenses on the basis of print outs of CPU marked as KZ-1 – Rs. 20,76,268/-. iii. On account of repair and maintenance - Rs.10

RAMJI VAISH,ALLAHABAD vs. DCIT, (CC), ALLAHABAD

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

C) r.w.s. 153A & 143(3) / 143(3) r.w.s. 153(B)(1). 2. The facts of the case are that a search and seizure operation under section 132(1) of the Income Tax Act, 1961 was conducted in respect of all these assessees on 3.02.2011. Thereafter, assessment proceedings were taken up under section 153A r.w.s. 143(3) for the period starting

RAMJI VAISH,ALLAHABAD vs. DCIT(CC), ALLAHABAD

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

C) r.w.s. 153A & 143(3) / 143(3) r.w.s. 153(B)(1). 2. The facts of the case are that a search and seizure operation under section 132(1) of the Income Tax Act, 1961 was conducted in respect of all these assessees on 3.02.2011. Thereafter, assessment proceedings were taken up under section 153A r.w.s. 143(3) for the period starting

RAMJI VAISH,ALLAHABAD vs. DCIT(CC), ALLAHABAD

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

C) r.w.s. 153A & 143(3) / 143(3) r.w.s. 153(B)(1). 2. The facts of the case are that a search and seizure operation under section 132(1) of the Income Tax Act, 1961 was conducted in respect of all these assessees on 3.02.2011. Thereafter, assessment proceedings were taken up under section 153A r.w.s. 143(3) for the period starting

RAMJI VAISH,ALLAHABAD vs. DCIT(CC), ALLAHABAD

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

C) r.w.s. 153A & 143(3) / 143(3) r.w.s. 153(B)(1). 2. The facts of the case are that a search and seizure operation under section 132(1) of the Income Tax Act, 1961 was conducted in respect of all these assessees on 3.02.2011. Thereafter, assessment proceedings were taken up under section 153A r.w.s. 143(3) for the period starting

ASSTT. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, ALLAHABAD vs. VIJAY STONE PRODUCTS, SONEBHADRA

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

C) r.w.s. 153A & 143(3) / 143(3) r.w.s. 153(B)(1). 2. The facts of the case are that a search and seizure operation under section 132(1) of the Income Tax Act, 1961 was conducted in respect of all these assessees on 3.02.2011. Thereafter, assessment proceedings were taken up under section 153A r.w.s. 143(3) for the period starting

M/S JAI MAA SHARDA SERVICE STATION,ALLAHABAD vs. ACIT, CENTRAL CIRCLE, ALLAHABAD

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

C) r.w.s. 153A & 143(3) / 143(3) r.w.s. 153(B)(1). 2. The facts of the case are that a search and seizure operation under section 132(1) of the Income Tax Act, 1961 was conducted in respect of all these assessees on 3.02.2011. Thereafter, assessment proceedings were taken up under section 153A r.w.s. 143(3) for the period starting

VIJAY STONE PRODUCT,SONEBHADRA vs. ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, ALLAHABAD

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

C) r.w.s. 153A & 143(3) / 143(3) r.w.s. 153(B)(1). 2. The facts of the case are that a search and seizure operation under section 132(1) of the Income Tax Act, 1961 was conducted in respect of all these assessees on 3.02.2011. Thereafter, assessment proceedings were taken up under section 153A r.w.s. 143(3) for the period starting