BRAJESH AGRAWAL,PRAYAGRAJ vs. ASST. DIRECTOR OF INCOME TAX, BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri.Vijay Pal Rao & Shri. Ramit Kocharassessment Year: 2021-22 Brajesh Agrawal, V. Asstt. Director Of Income Tax, Cpc, Bengaluru 3/15, Patrika Marg, Civil Lines, Allahabad, U.P. Pan-Acbpa3797R (Appellant) (Respondent) Assessee By: Sh. Saurabh Agrawal, C.A. Respondent By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 14.03.2023 Date Of Pronouncement: 24.03.2023 O R D E R

house property and 5 Sri Brajesh Agrawal income from other sources declared by the assessee. Thus, the total income of the assessee was computed by CPC at Rs. 16,98,990/- as against the declared income of Rs. 1,77,930/-. On careful perusal of the intimation of processing of return of income by the CPC under section 143(1

SHOBHA RASTOGI,ALLAHABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, ALLAHABAD

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

Bench: Shri.Vijay Pal Raoassessment Year: 2008-09 Smt. Shobha Rastogi, V. Deputy Commissioner Of Income 30-A, M.G. Marg, Civil Lines, Tax, Circle-1, Allahabad, U.P. Allahabad, U.P. Pan-Afqpr4774R (Appellant) (Respondent) Appellant By: Mr. Praveen Godbole, C.A. Respondent By: Mr. A.K. Singh, Sr. Dr Date Of Hearing: 12.08.2021 Date Of Pronouncement: 13.08.2021

9,04,580/- and his action as confirmed by CIT(A) is highly unjustified. 6. Because in the facts and circumstances of the case assessee reserved his right to take any fresh ground of appeal before hearing of appeal.” 2. Ground no. 1 is regarding the validity of reassessment framed by the Assessing Officer under section 143(3) read with

M/S. GOVIND STONE PRIVATE LIMITED ,HAMIRPUR vs. INCOME TAX OFFICER -5(4), BANDA

Bench: Shrivijay Pal Rao & Shri Ramit Kochar

house, 4 Faile Place, Notice Served Private Limited 2nd Floor, Kolkata-700001 2 AprajitaVanijya 7A, Bentinck Street, Insufficient address, Private Limited Kolkata-700001 hence returned to sender Zigzag Vanijya 146/2, Old China Bazar, No mention floor 3 Private Limited Kolkata-700001 R/No. hence R. to sender 4 ShradhaVintrade 9/12, Lal Bazar, 2nd Floor, Insufficient address, Private Limited Kolkata-700001 hence

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

Housing Development Company Vs. DCIT Central Circle-I, Bangalore in ITA No. 38/2014 dated 25.07.2014 wherein the Hon’ble Court held that the assessing authority shall determine the total income of the assessee taking into consideration the materials which was the subject matter of earlier return and the undisclosed income unearthed during search and also any other income which comes

MEJA URJA NIGAM (P) LTD.,ALLAHABAD vs. INCOME TAX OFFICE WARD-2 (2), ALLAHABAD

In the result, both the appeals of the assessee for ay: 2015-16 and 2016-17

Bench: Shri.Vijay Pal Rao & Shri Ramit Kochar

9. In our judgment neither of the two factors can affect taxability of the income earned by the company. Under the Act, the total income of the company is chargeable to tax under section 4 of the Act. The total income has to be computed in accordance with the provisions of the Act. Section 14 of the Act lays down

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

housing accommodation or for the purposes of planning, development or improvement of cities, towns and villages were omitted and the benefit conferred by erstwhile section 10(20A) on such authorities were taken away. Thereafter, after insertion of the said proviso, any institution carrying on of any activity in the nature of trade, commerce or business would not be regarded

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

housing accommodation or for the purposes of planning, development or improvement of cities, towns and villages were omitted and the benefit conferred by erstwhile section 10(20A) on such authorities were taken away. Thereafter, after insertion of the said proviso, any institution carrying on of any activity in the nature of trade, commerce or business would not be regarded

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

housing accommodation or for the purposes of planning, development or improvement of cities, towns and villages were omitted and the benefit conferred by erstwhile section 10(20A) on such authorities were taken away. Thereafter, after insertion of the said proviso, any institution carrying on of any activity in the nature of trade, commerce or business would not be regarded

SMT. NEETA NATH L/H OF LATE DR. JITENDRA NATH,ALLAHABAD vs. ACIT, CENTRAL CIRCLE, ALLAHABAD

In the result, both the appeals in ITA No

Bench: Shri.Vijay Pal Rao & Shri. Ramit Kocharassessment Year: 2013-14 Vs. The Asstt. Commissioner Of Smt. Neeta Nath, L/H Of Lt. Dr. Jitendra Nath Income Tax, Central Circle, Civil Lines, Allahabad B/401, Mayan Enclave, 49/13, Clive Road, Allahabad Pan-Abepn1795Q (Appellant) (Respondent) Assessment Year: 2013-14 Madhurendra Nath, Vs. The Asstt. Commissioner Of B-502, Vinayak Le Grande, Income Tax, Central Circle, 16/12, Lal Bahadur Shastri Civil Lines, Allahabad Road, Allahabad-211001 Pan-Aaipn8161D (Appellant) (Respondent) Appellant By: Sh. Siddharth Pathak, Adv Respondent By: Sh. Rabin Chaudhari, Cit Dr Date Of Hearing: 18.01.2023 Date Of Pronouncement: 16.02.2023 O R D E R Shri Vijay Pal Rao, J.M.: These Two Appeals By The Two Related Assessees Are Directed Against Two Separate Orders Of The Cit(A), Both Dated 28.04.2016 For The Assessment Year 2013-14. 2. These Appeals Are Arising From The Assessment Orders Passed Under Section 153C In Pursuant To The Search & Seizure Action Under Section 132(1) Of The Income Tax Act, Dated 05.12.2013 In The Case Of Shri. Hemant Kumar Sindhi. Therefore, The Facts & Circumstances As Well As The Grounds Of Appeal

property was happened between M/s H.K. Infraventures Pvt. Ltd. through its Director Shri Hemant Kumar Sindhi and with Dinesh Kumar Pahuja President of Sindhu Sahkari Avas Samiti and the contrary view taken by the Id. CIT(Appeals) to confirm the addition in the hands of appellant is wholly illegal and erroneous. 8. BECAUSE there was no business dealings with Dinesh

MADHURENDRA NATH,ALLAHABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, ALLAHABAD

In the result, both the appeals in ITA No

Bench: Shri.Vijay Pal Rao & Shri. Ramit Kocharassessment Year: 2013-14 Vs. The Asstt. Commissioner Of Smt. Neeta Nath, L/H Of Lt. Dr. Jitendra Nath Income Tax, Central Circle, Civil Lines, Allahabad B/401, Mayan Enclave, 49/13, Clive Road, Allahabad Pan-Abepn1795Q (Appellant) (Respondent) Assessment Year: 2013-14 Madhurendra Nath, Vs. The Asstt. Commissioner Of B-502, Vinayak Le Grande, Income Tax, Central Circle, 16/12, Lal Bahadur Shastri Civil Lines, Allahabad Road, Allahabad-211001 Pan-Aaipn8161D (Appellant) (Respondent) Appellant By: Sh. Siddharth Pathak, Adv Respondent By: Sh. Rabin Chaudhari, Cit Dr Date Of Hearing: 18.01.2023 Date Of Pronouncement: 16.02.2023 O R D E R Shri Vijay Pal Rao, J.M.: These Two Appeals By The Two Related Assessees Are Directed Against Two Separate Orders Of The Cit(A), Both Dated 28.04.2016 For The Assessment Year 2013-14. 2. These Appeals Are Arising From The Assessment Orders Passed Under Section 153C In Pursuant To The Search & Seizure Action Under Section 132(1) Of The Income Tax Act, Dated 05.12.2013 In The Case Of Shri. Hemant Kumar Sindhi. Therefore, The Facts & Circumstances As Well As The Grounds Of Appeal

property was happened between M/s H.K. Infraventures Pvt. Ltd. through its Director Shri Hemant Kumar Sindhi and with Dinesh Kumar Pahuja President of Sindhu Sahkari Avas Samiti and the contrary view taken by the Id. CIT(Appeals) to confirm the addition in the hands of appellant is wholly illegal and erroneous. 8. BECAUSE there was no business dealings with Dinesh

SHAKUN DEVI,,ALLAHABAD vs. JT.CIT,, ALLAHABAD

In the result, the appeal of the assessee is partly allowed

Bench: Shri.Vijay Pal Rao & Shri. Ramit Kochara.Y. 2010-11 Shakun Devi, Vs. Joint Commissioner Of Sahson, Allahabad Income Tax, Central Pan-Adapk7419E Circle, Allahabad (Assessee) (Respondent) Appellant By: Sh. Praveen Godbole, C.A. Respondent By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 31.10.2022 Date Of Pronouncement: 05.01.2023 O R D E R

section 132(4) on the date of search explained the source of acquisition of the jewellery in reply to question no. 6 as under:- """ 6 तलाशी के दौरान आपके बेड"म की अलमारी से 1182 "ाम सोने के जेवरात "ा" "ए ह" तथा बरामदे की अलमारी से 623 "ाम सोने की तार "ा" 5 Shakun Devi "ए ह"। यह जेवरात तथा गो

SANJAY MAJUMDAR,ALLAHABAD vs. PR. CIT, ALLAHABAD

Bench: Shri.Vijay Pal Rao & Shri Ramit Kocharassessment Year: 2012-13 Mr. Sanjay Majumdar, V. The Principal Commissioner Type Ii – 112, Devprayagam Of Income Tax, Sangam Vatika – Jhalwa, Aayakar Bhawan, Allahabad 211012 38, M.G. Marg, Civil Lines, Allahabad 211001 Pan: Adopm 2688P (Appellant) (Respondent)

9 and 9/2 new no. 10 and 41 respectively at Minto Road, Allahabad including 3 out houses bearing Nos. 42/9/1, 39/9/3 & 38/9/4 which are situated at plot no. 6 Rajapur, Bandhwa, Allahabad. The total area of land was of 2593.58 Sq. Meter. Shri Narain Das Majumdar was the lessee of this property vide lease deed dated 18.10.1937 executed

AJAY KUMAR GUPTA,FATEHPUR vs. CIT(A), NFAC, DELHI (AO:ITO-2(4),FATEHPUR, FATEHPUR

In the result, appeal filed by assessee in ITA No

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

House, G.T. Road, v. Fatehpur, U.P. Khaga, Fatehpur- 212655, U.P. PAN:AHCPG3595K (Appellant) (Respondent) Appellant by: Shri Rajeev Kumar Agrawal, Advocate Respondent by: Shri A.K. Singh ,Sr. D.R. Date of hearing: 20.03.2023 Date of pronouncement: 20 .03.2023 O R D E R PER SHRI RAMIT KOCHAR, ACCOUNTANT MEMBER: This appeal, filed by assessee, being ITA No.19/Alld./2023, is directed against

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

1) on three occasions. Upon the failure to receive any compliance, a show cause notice under section 144 was issued to the assessee and upon failure to receive compliance to the same, orders were passed under section 147 r.w.s. 144 and section 144B of the Income A.Ys. 2013-14 & 2014-15 Mohammad Sahadat

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

1) on three occasions. Upon the failure to receive any compliance, a show cause notice under section 144 was issued to the assessee and upon failure to receive compliance to the same, orders were passed under section 147 r.w.s. 144 and section 144B of the Income A.Ys. 2013-14 & 2014-15 Mohammad Sahadat

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

1) on three occasions. Upon the failure to receive any compliance, a show cause notice under section 144 was issued to the assessee and upon failure to receive compliance to the same, orders were passed under section 147 r.w.s. 144 and section 144B of the Income A.Ys. 2013-14 & 2014-15 Mohammad Sahadat

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

1) on three occasions. Upon the failure to receive any compliance, a show cause notice under section 144 was issued to the assessee and upon failure to receive compliance to the same, orders were passed under section 147 r.w.s. 144 and section 144B of the Income A.Ys. 2013-14 & 2014-15 Mohammad Sahadat

DHIRENDRA SINGH,MIRZAPUR vs. INCOME TAX OFFICER, WARD- 3(1), MIRZAPUR

In the result, the appeal of the assessee is partly allowed

Bench: Shri Subhash Malguria & Shri Nikhil Choudharyassessment Year: 2015-16 Dhirendra Singh V. Income Tax Officer Mangraha, Chunar Ward 3(1) Mirzapur Mirzapur Pan:Bipps5569C (Appellant) (Respondent) Appellant By: Shri Brij Bhushan Goenka, C.A. Respondent By: Shri A. K. Singh, Sr. D.R. Date Of Hearing: 02 01 2025 Date Of Pronouncement: 20 03 2025

1) of the Act dated 30.08.2017. In response to the notice, the assessee filed a copy of Audit Report, Balance Sheet, profit and loss account and copy of ITR. The Assessing Officer records that when asked to substantiate the issue involved, i.e., “increase in capital”, the ITA No.133/ALLD/2024 Page 3 of 11 A.R. of the assessee could offer no explanation

M/S GANGA NURSING HOME,,ALLAHABAD vs. DCIT,, ALLAHABAD

In the result, appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

9 Assessment Year: 2008-09 Ganga Nursing Home v. DCIT, Range-1, Allahabad authorities below. Further, it was submitted by ld. Counsel for the assessee that if it is held that Section 50C is applicable, then the authorities below , did not refer the matter to DVO for valuing the property as no report of DVO was called by authorities below