ACIT,, ALLAHABAD vs. M/S KESARWANI & CO., ALLAHABAD

In the result, appeal in ITA No

section 145(3) to this extent and made an addition of Rs.1,00,000/- on this account, thereby giving the assessee relief of Rs.86,94,292/-. 3. The second issue in the Department’s appeal is the decision of the ld. CIT(A) to delete an addition of Rs.2,66,73,629/- on account of unaccounted purchases, without appreciating that

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

In the result, appeal in ITA No

section 145(3) to this extent and made an addition of Rs.1,00,000/- on this account, thereby giving the assessee relief of Rs.86,94,292/-. 3. The second issue in the Department’s appeal is the decision of the ld. CIT(A) to delete an addition of Rs.2,66,73,629/- on account of unaccounted purchases, without appreciating that

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

73 taxmann.com 146 (Orissa)/454 ITR 312 (Orissa) and aforesaid order of Hon'ble Allahabad High Court in the case of PCIT vs. Siddharth Gupta 147 taxmann.com 305 (Allahabad)/ 450 ITR 534 (Allahabad); have been dismissed by Hon'ble Supreme Court in decisions at ACIT vs. Serajuddin and Co. 163 taxmann.com 118 (SC) and vide order dated 09/08/2024

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

73 taxmann.com 146 (Orissa)/454 ITR 312 (Orissa) and aforesaid order of Hon'ble Allahabad High Court in the case of PCIT vs. Siddharth Gupta 147 taxmann.com 305 (Allahabad)/ 450 ITR 534 (Allahabad); have been dismissed by Hon'ble Supreme Court in decisions at ACIT vs. Serajuddin and Co. 163 taxmann.com 118 (SC) and vide order dated 09/08/2024

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

73 taxmann.com 146 (Orissa)/454 ITR 312 (Orissa) and aforesaid order of Hon'ble Allahabad High Court in the case of PCIT vs. Siddharth Gupta 147 taxmann.com 305 (Allahabad)/ 450 ITR 534 (Allahabad); have been dismissed by Hon'ble Supreme Court in decisions at ACIT vs. Serajuddin and Co. 163 taxmann.com 118 (SC) and vide order dated 09/08/2024

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

73 taxmann.com 146 (Orissa)/454 ITR 312 (Orissa) and aforesaid order of Hon'ble Allahabad High Court in the case of PCIT vs. Siddharth Gupta 147 taxmann.com 305 (Allahabad)/ 450 ITR 534 (Allahabad); have been dismissed by Hon'ble Supreme Court in decisions at ACIT vs. Serajuddin and Co. 163 taxmann.com 118 (SC) and vide order dated 09/08/2024

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

disallowance or addition in computation of income. He submitted that as can be seen from the assessment order for assessment year 2012-13 that the reason has been given that assessee had deposited Rs.5,01,33,312/- but has not filed his ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 63 of 79 return

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

disallowance or addition in computation of income. He submitted that as can be seen from the assessment order for assessment year 2012-13 that the reason has been given that assessee had deposited Rs.5,01,33,312/- but has not filed his ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 63 of 79 return

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

disallowance or addition in computation of income. He submitted that as can be seen from the assessment order for assessment year 2012-13 that the reason has been given that assessee had deposited Rs.5,01,33,312/- but has not filed his ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 63 of 79 return

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

disallowance or addition in computation of income. He submitted that as can be seen from the assessment order for assessment year 2012-13 that the reason has been given that assessee had deposited Rs.5,01,33,312/- but has not filed his ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 63 of 79 return

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

disallowance or addition in computation of income. He submitted that as can be seen from the assessment order for assessment year 2012-13 that the reason has been given that assessee had deposited Rs.5,01,33,312/- but has not filed his ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 63 of 79 return

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

disallowance or addition in computation of income. He submitted that as can be seen from the assessment order for assessment year 2012-13 that the reason has been given that assessee had deposited Rs.5,01,33,312/- but has not filed his ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 63 of 79 return

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

disallowance or addition in computation of income. He submitted that as can be seen from the assessment order for assessment year 2012-13 that the reason has been given that assessee had deposited Rs.5,01,33,312/- but has not filed his ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 63 of 79 return

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

disallowance or addition in computation of income. He submitted that as can be seen from the assessment order for assessment year 2012-13 that the reason has been given that assessee had deposited Rs.5,01,33,312/- but has not filed his ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 63 of 79 return

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

disallowance or addition in computation of income. He submitted that as can be seen from the assessment order for assessment year 2012-13 that the reason has been given that assessee had deposited Rs.5,01,33,312/- but has not filed his ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 63 of 79 return

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

disallowance or addition in computation of income. He submitted that as can be seen from the assessment order for assessment year 2012-13 that the reason has been given that assessee had deposited Rs.5,01,33,312/- but has not filed his ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 63 of 79 return

SURENDRA KUMAR MISHRA,ALLAHABAD vs. ACIT, CIR-2, ALLAHABAD

In the result, the appeal of the assessee is dismissed

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2002-03 Surendra Kumar Mishra, Vs. Assistant Commissioner Of 794A/1, Sohabatiyabagh, Income Tax, Circle-2, Allahabad Allahabad-211006, U.P. Pan:Aibpm4858R (Appellant) (Respondent) Assessee By: Sh. Ashish Bansal, Advocate Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 14.11.2024 Date Of Pronouncement: 10.02.2025 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), Under Section 250 R.W.S. 254 Of The Income Tax Act, 1961 On 26.10.2023. The Grounds Of Appeal Preferred By The Assessee Are As Under:- “1. Because The Cit(A) Has Erred In Law As Well As On Facts In Dismissing The 'Additional Ground' Relating To Non-Issuance Of Notice Under Section 143(2) Of The Act, Raised Before The Appellate Authority During The Course Of First Round Of Litigation, Which Has Been Remanded Back By The Hon'Ble Itat In Terms Of Order Dated 09.11.2012, By Observing That The Return Filed By The Appellant In Terms Of Letter Dated 10.11.2008 As Not A Valid Return In Compliance To Notice Dated 11.02.2008 Issued Under Section 148 Of The Act, As The Said Letter Was Filed By The Appellant After The Time Limit Of 30 Days Provided To Do So In Terms Of Notice Dated 11.02.208 Issued Under Section 148 Of The Act. 2. Because The Cit(A) Has Erred In Law As Well As On Facts In Observing That The Appellant Could Not Have Demand For Issuance Of Notice Under Section 143(2) Of The 1 Surendra Kumar Mishra

section 48 of the Act. 12. BECAUSE the authorities below have erred in law and on facts in not allowing full deduction of expenses claimed (other than freehold charges) at Rs.15,73,360/- and in restricting the same to Rs.14,16,024/- (being 90% of the claimed amount). 13. BECAUSE adhoc disallowance

PANNA LAL PRAJAPATI,MIRZAPUR vs. ITO, WARD 3(2), MIRZAPUR

In the result, the appeal of the assessee is allowed

Bench: Udayan Das Gupta & Sh. Nikhil Choudharya.Y. 2011-12 Shri Panna Lal Prajapati, Vs. Income Tax Officer, Bhudev Dubey, Kai Gali, Ward-3(2), Mirzapur Bhatwa Ki Pokhari, Mirzapur Pan:Azeps1524N (Appellant) (Respondent) Assessee By: Sh. Praveen Godbole, C.A. Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 01.10.2024 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. Addl Cit(A)-Kolkata Passed Under Section 250 Of The Income Tax Act, 1961 On 27.03.2024. The Grounds Of Appeal Are As Under: “1. That In Any View Of The Matter Assessment Made On Income Of The Rs. 12,73,650/- By Order Dated 26.12.2018 Passed U/S 143 (3)/147 Of The I.T. Act Is Bad Both On The Facts & In Law. 2. That In Any View Of The Matter The Proceeding U/S 147 Of The Act As Initiated On The Allegation That Assessee Has Made Cash Deposit Amounting To Rs.30,63,500/- In Bank Account Which Remain Unexplained Is Not Correct Since The Cash Deposit Are From Disclosed Sources Hence The Satisfaction Recorded Is Not Correct & There Was No Independent Application Of Mind By The Assessing Officer Before Initiating Proceeding U/S 147 Of The Act. 3. That In Any View Of The Matter The Learned Cit Appeal Was Not Correct In Deciding The Appeal Ex-Parte Without Providing Reasonable Opportunity To The Assessee & The Order Not Speaking Order In The Eye Of Law.

73,650/- by order dated 26.12.2018 passed u/s 143 (3)/147 of the I.T. Act is bad both on the facts and in law. 2. That in any view of the matter the proceeding u/s 147 of the Act as initiated on the allegation that assessee has made cash deposit amounting to Rs.30,63,500/- in bank account which remain

VANDANA BANSAL L/H OF LATE DR. ASHWANI KUMAR BANSAL, ,ALLAHABAD vs. ACIT, CENTRAL CIRCLE,, ALLAHABAD

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

73 75 77 79 COMMON PAPER BOOK – PART-2 S.No. Description of Documents enclosed 1. Appraisal report (of the search) dated 31/12/2012 forwarded to the Pr.CIT/JCIT/AO 5. Navjeevan Pediatrics Pvt. Ltd., A.Y. 2013-14 6. Minto Colonizers Pvt. Ltd. A.Y.-2009-10 7. Jeevan Joti Infrastructure Co. Pvt. Ltd. A.Y.2012-13 - Further relevant documents/evidences are placed in another part