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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

penalty proceedings against the Appellant under Section 271(1)(c) and 271(1)(b) of the Act.” I.T.A. No.129/Alld/2025 (A.Y. 2012-13 I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 6 (A.1) For the sake of convenience, these appeals are hereby disposed of through this consolidated order. At the time of hearing before

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

penalty proceedings against the Appellant under Section 271(1)(c) and 271(1)(b) of the Act.” I.T.A. No.129/Alld/2025 (A.Y. 2012-13 I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 6 (A.1) For the sake of convenience, these appeals are hereby disposed of through this consolidated order. At the time of hearing before

DCIT CIRCLE-3, MIRZAPUR vs. SHRI NEERAJ AGRAWAL, MIRZAPUR

Bench: Shrivijay Pal Rao & Shri Ramit Kochar

Penalty proceedings u/s 271(1)(c) is being initiated separately for concealment of income. Addition of Rs. 78,059/-/” 4c. The AO further observed that there are cash deposits recorded in the cash books maintained by the assessee, which were found during the course of survey operations u/s 133A on 24.02.2012, as detailed hereunder: S.No. Date Concerned Perons/Firm name Amount

NEERAJ AGRAWAL,,MIRZAPUR vs. DCIT, MIRZAPUR

Bench: Shrivijay Pal Rao & Shri Ramit Kochar

Penalty proceedings u/s 271(1)(c) is being initiated separately for concealment of income. Addition of Rs. 78,059/-/” 4c. The AO further observed that there are cash deposits recorded in the cash books maintained by the assessee, which were found during the course of survey operations u/s 133A on 24.02.2012, as detailed hereunder: S.No. Date Concerned Perons/Firm name Amount

GRIJESH TIWARI,ALLAHABAD vs. ITO 2 (1), ALLAHABAD

In the result, ITA. No. 21/Alld/2023 of the assessee is allowed for statistical purposes and ITA

Bench: Shri Aby T. Varkey, Jm आयकर अपील सं/ I.T.A. Nos. 21 & 22/Alld/2023 (निर्धारण वर्ा / Assessment Year: 2012-13) Grijesh Tiwari बिधम/ Ito-2(1) 22-A/16-A, T. B. Sapru Income Tax Office, 38 M. Vs. Road, Civil Lines, G. Marg, Allahabad- Allahabad-211001. 211001. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Akkpt9797R (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Ms. Srishti Gupta Revenue By: Shri A. K. Singh (Sr. Dr) सुनवाई की तारीख / Date Of Hearing: 14/09/2023 घोषणा की तारीख /Date Of Pronouncement: 04/10/2023 आदेश / O R D E R Per Aby T. Varkey, Jm:

section 250(6) of the Act, in accordance to law. In the result, the appeal filed by the assessee is allowed for statistical purposes. ITA. NO.22/Alld/2023 This is an appeal preferred by the assessee against the order of the Ld. CIT(A)/NFAC dated 17.02.2023 for AY. 2012-13 confirming the penalty levied of Rs.10,000/- u/s 271

GRIJESH TIWARI,ALLAHABAD vs. ITO 2 (1), ALLAHABAD

In the result, ITA. No. 21/Alld/2023 of the assessee is allowed for statistical purposes and ITA

Bench: Shri Aby T. Varkey, Jm आयकर अपील सं/ I.T.A. Nos. 21 & 22/Alld/2023 (निर्धारण वर्ा / Assessment Year: 2012-13) Grijesh Tiwari बिधम/ Ito-2(1) 22-A/16-A, T. B. Sapru Income Tax Office, 38 M. Vs. Road, Civil Lines, G. Marg, Allahabad- Allahabad-211001. 211001. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Akkpt9797R (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Ms. Srishti Gupta Revenue By: Shri A. K. Singh (Sr. Dr) सुनवाई की तारीख / Date Of Hearing: 14/09/2023 घोषणा की तारीख /Date Of Pronouncement: 04/10/2023 आदेश / O R D E R Per Aby T. Varkey, Jm:

section 250(6) of the Act, in accordance to law. In the result, the appeal filed by the assessee is allowed for statistical purposes. ITA. NO.22/Alld/2023 This is an appeal preferred by the assessee against the order of the Ld. CIT(A)/NFAC dated 17.02.2023 for AY. 2012-13 confirming the penalty levied of Rs.10,000/- u/s 271

CHANDRA BHAWAN,KAUSHAMBI vs. ADDL./JOINT/ACIT/ITO, NFAC, DELHI

In the result, while appeal in ITA No

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2017-18 Chandra Bhawan, Vs. Additional/Joint/Deputy/Assis Chak Guraini, Baish Kanti, Kaushambi- Tant Commissioner Of Income 212206 Tax/Income-Tax Officer, Present Address National Faceless Assessment 39A/L/2, Om Prakash, Sabhasad Marg, Centre, Delhi Kalindipuram, Prayagraj-211011 Pan:Ahjpb4378C (Appellant) (Respondent) A.Y. 2016-17 Chandra Bhawan, Vs. Income Tax Officer, Chak Guraini, Baish Kanti, Kaushambi- Ward-2(5), Kaushambi 212206 Present Address 39A/L/2, Om Prakash, Sabhasad Marg, Kalindipuram, Prayagraj-211011 Pan:Ahjpb4378C (Appellant) (Respondent) Assessee By: Sh. Mayank Arora, Advocate Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 14.11.2024 Date Of Pronouncement: 29.11.2024 O R D E R Per Nikhil Choudhary, A.M.: These Two Appeals Have Been Filed Against The Orders Of The Ld. Cit(A), Nfac Under Section 250 Of The Income Tax Act, 1961 On 19.01.2024 (For The Assessment

penalty proceedings under section 271(1)(c). 4. Aggrieved with this order of the ld. AO, the assessee went in appeal before the ld. CIT(A), Allahabad. Subsequently, his appeal was migrated to the National Faceless Appeal Centre. The ld. CIT(A), NFAC records that a total 13 notices were issued to the assessee during appeal proceedings and in response

CHANDRA BHAWAN,KAUSHAMBI vs. ITO WARD-2(5), , KAUSHAMBI

In the result, while appeal in ITA No

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2017-18 Chandra Bhawan, Vs. Additional/Joint/Deputy/Assis Chak Guraini, Baish Kanti, Kaushambi- Tant Commissioner Of Income 212206 Tax/Income-Tax Officer, Present Address National Faceless Assessment 39A/L/2, Om Prakash, Sabhasad Marg, Centre, Delhi Kalindipuram, Prayagraj-211011 Pan:Ahjpb4378C (Appellant) (Respondent) A.Y. 2016-17 Chandra Bhawan, Vs. Income Tax Officer, Chak Guraini, Baish Kanti, Kaushambi- Ward-2(5), Kaushambi 212206 Present Address 39A/L/2, Om Prakash, Sabhasad Marg, Kalindipuram, Prayagraj-211011 Pan:Ahjpb4378C (Appellant) (Respondent) Assessee By: Sh. Mayank Arora, Advocate Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 14.11.2024 Date Of Pronouncement: 29.11.2024 O R D E R Per Nikhil Choudhary, A.M.: These Two Appeals Have Been Filed Against The Orders Of The Ld. Cit(A), Nfac Under Section 250 Of The Income Tax Act, 1961 On 19.01.2024 (For The Assessment

penalty proceedings under section 271(1)(c). 4. Aggrieved with this order of the ld. AO, the assessee went in appeal before the ld. CIT(A), Allahabad. Subsequently, his appeal was migrated to the National Faceless Appeal Centre. The ld. CIT(A), NFAC records that a total 13 notices were issued to the assessee during appeal proceedings and in response

SHIV SHANKAR,MIRZAPUR vs. ITO, WARD-3(1), MIRZAPUR

In the result, all the appeals are allowed for statistical purposes

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

147 read with section 144, read with section 144B of the I. T. Act whereby the assessee’s total income was assessed at Rs.87,46,000/-. The order passed by the Assessing Officer was an ex-parte order qua the assessee. Aggrieved, the assessee carried the matter in appeal before the learned CIT(A). Vide impugned appellate order dated 04/10/2024

SHIV SHANKAR,MIRZAPUR vs. ITO, WARD-3(1), MIRZAPUR

In the result, all the appeals are allowed for statistical purposes

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

147 read with section 144, read with section 144B of the I. T. Act whereby the assessee’s total income was assessed at Rs.87,46,000/-. The order passed by the Assessing Officer was an ex-parte order qua the assessee. Aggrieved, the assessee carried the matter in appeal before the learned CIT(A). Vide impugned appellate order dated 04/10/2024

SHIV SHANKAR,MIRZAPUR vs. ITO WARD-3(1), MIRZAPUR

In the result, all the appeals are allowed for statistical purposes

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

147 read with section 144, read with section 144B of the I. T. Act whereby the assessee’s total income was assessed at Rs.87,46,000/-. The order passed by the Assessing Officer was an ex-parte order qua the assessee. Aggrieved, the assessee carried the matter in appeal before the learned CIT(A). Vide impugned appellate order dated 04/10/2024

ALFALAH EDUCATIONAL & WELFARE SOCIETY ,FAIZABAD vs. ASSESSMENT UNIT ITD, DELHI

In the result, the appeal is allowed for statistical purposes

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2015-16 Alfalah Educational & Welfare Vs. Assessment Unit, Income Tax Society Qusba Bhadarsa Department Bharatkund, Faizabad, U.P. Pan:Aadfi7669A (Appellant) (Respondent) Assessee By: Sh. Praveen Godbole, C.A. Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 22.10.2024 Date Of Pronouncement: 27.12.2024 O R D E R Per Nikhil Choudhary, A.M.: This Appeal Has Been Filed Against The Order Of The Ld. Cit(A), Nfac, Passed Under Section 250 Of The Income Tax Act, 1961 Dated 13.09.2014. The Grounds Of Appeal Preferred By The Assessee Are As Under:- “1. The 1. That In Any View Of The Matter Assessment Made On Income Of Rs.2,45,71,147/- U/S 147 R.W.S. 144 Of The Act Vide Order Dated 02.03.2023 Is Bad Both On The Facts & In Law. 2. That In Any View Of The Matter Appeal Decided Ex-Parte By Cit Appeal Nfac By Order Dated 13.09.2024 Without Providing Reasonable Opportunity To The Assessee Is Highly Unjustified. 3. That In Any View Of The Matter Proceedings As Initiated U/S 147 Of The Act Is An Illegal Proceedings & There Is No Concealment Of Income & Moreover There Was No Proper Satisfaction Was Recorded By The Department For Initiation Of Proceedings Hence Entire Proceedings Liable To Be Annulled.

u/s 69 of the Act is incorrect as no investment was made by the assessee society in time deposit in Punjab National Bank as alleged and the chart as reproduced in the assessment order at Para 3.3 Pg. 4-8 by alleging investment made in time deposit is nothing but amount transferred to autosweep account out of reversal credited from

DEPUTY COMMISSIONER OF INCOME TAX(CENTRAL CIRCLE), ALLAHABAD vs. JEEVAN JYOTI CHARITABLE TRUST, 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

271 ITR 401 (SC) for the proposition that rule of construction is to be applied only when there is an ambiguity. Learned Departmental Representatives also relied on orders of Mumbai Bench of ITAT in the cases of Pratibha Pipes & Structurals Ltd. vs. DCIT 173 taxmann.com 147 (Mumbai-Trib) and Usha Satish Salvi vs. ACIT (order dated 23/10/2025 in I.T.A. Nos.4237

ARPIT HOSPITAL PRIVATE LIMITED,,ALLAHABAD vs. DCIT, 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

271 ITR 401 (SC) for the proposition that rule of construction is to be applied only when there is an ambiguity. Learned Departmental Representatives also relied on orders of Mumbai Bench of ITAT in the cases of Pratibha Pipes & Structurals Ltd. vs. DCIT 173 taxmann.com 147 (Mumbai-Trib) and Usha Satish Salvi vs. ACIT (order dated 23/10/2025 in I.T.A. Nos.4237

DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE), ALLAHABAD vs. JEEVAN JYOTI CHARITABLE TRUST, 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

271 ITR 401 (SC) for the proposition that rule of construction is to be applied only when there is an ambiguity. Learned Departmental Representatives also relied on orders of Mumbai Bench of ITAT in the cases of Pratibha Pipes & Structurals Ltd. vs. DCIT 173 taxmann.com 147 (Mumbai-Trib) and Usha Satish Salvi vs. ACIT (order dated 23/10/2025 in I.T.A. Nos.4237

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

271 ITR 401 (SC) for the proposition that rule of construction is to be applied only when there is an ambiguity. Learned Departmental Representatives also relied on orders of Mumbai Bench of ITAT in the cases of Pratibha Pipes & Structurals Ltd. vs. DCIT 173 taxmann.com 147 (Mumbai-Trib) and Usha Satish Salvi vs. ACIT (order dated 23/10/2025 in I.T.A. Nos.4237

DEPUTY COMMISSIONER OF INCOME TAX, ALLAHABAD vs. JEEVAN JYOTI CHARITABLE TRUST, 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

271 ITR 401 (SC) for the proposition that rule of construction is to be applied only when there is an ambiguity. Learned Departmental Representatives also relied on orders of Mumbai Bench of ITAT in the cases of Pratibha Pipes & Structurals Ltd. vs. DCIT 173 taxmann.com 147 (Mumbai-Trib) and Usha Satish Salvi vs. ACIT (order dated 23/10/2025 in I.T.A. Nos.4237

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

271 ITR 401 (SC) for the proposition that rule of construction is to be applied only when there is an ambiguity. Learned Departmental Representatives also relied on orders of Mumbai Bench of ITAT in the cases of Pratibha Pipes & Structurals Ltd. vs. DCIT 173 taxmann.com 147 (Mumbai-Trib) and Usha Satish Salvi vs. ACIT (order dated 23/10/2025 in I.T.A. Nos.4237