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

u/s section 11. (3) Because the CIT(A) erred both on facts and in law in confirming the addition of net excess of income over expenditure of Rs.3,00,11,855/ under the head Income from business or profession. (4) Because the CIT(A) erred both on facts and in law in sustaining the addition of Rs.36

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

u/s section 11. (3) Because the CIT(A) erred both on facts and in law in confirming the addition of net excess of income over expenditure of Rs.3,00,11,855/ under the head Income from business or profession. (4) Because the CIT(A) erred both on facts and in law in sustaining the addition of Rs.36

SHRI KAMALENDRA BHADUR MISHRA,,SONEBHADRA vs. DCIT, RANGE-III, MIRZAPUR

In the result, the appeal of the assessee is allowed

Bench: Shri. A. D. Jain & Shri T. S. Kapoorassessment Year: 2011-12 Shri Kamalendra Bhadur Mishra V. Dcit Prop. M/S K.S. Engineearing Range Iii Iii-19, Jme Colony Mirzapur Shakti Dnagar, Sonebhadra Tan/Pan:Adbpm4445K (Appellant) (Respondent) Appellant By: Shri K.R. Singh, Advocate Respondent By: Shri A. K. Singh, D.R. Date Of Hearing: 13 02 2020 Date Of Pronouncement: 14 02 2020 O R D E R

III-19, JME Colony Mirzapur Shakti dNagar, Sonebhadra TAN/PAN:ADBPM4445K (Appellant) (Respondent) Appellant by: Shri K.R. Singh, Advocate Respondent by: Shri A. K. Singh, D.R. Date of hearing: 13 02 2020 Date of pronouncement: 14 02 2020 O R D E R PER A. D. JAIN, V.P.: This is assessee’s appeal against the order

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

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

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

AJIT TRIPATHI,ALLAHABAD vs. CIT (A), DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Raoassessment Year: 2017-18 Ajit Tripathi, V. Income Tax Officer, Village Pandor, Jasra, Ward-1(1), Allahabad Allahabad, U.P. Pan:Aknpt9902B (Appellant) (Respondent) Appellant By: Shri. S.K. Yogeshwar, Adv Respondent By: Shri A. K. Singh, Sr. D.R. Date Of Hearing: 14 02 2023 Date Of Pronouncement: 16 02 2023 O R D E R

14 02 2023 Date of pronouncement: 16 02 2023 O R D E R VIJAY PAL RAO, J.M.: This appeal by the assessee is directed against the order dated 31.10.2022 of the ld. CIT(A), NFAC, New Delhi arising from penalty order passed under section 271A of the Income Tax Act for the Assessment Year 2017-18. 2. The assessee

INCOME TAX OFFICER WARD-2(2), ALLAHABAD vs. MONAD INFRASOLUTION LIMITED, ALLAHABAD

In the result, the appeal of the revenue is allowed for statistical purpose and the Cross-objection of the assessee are dismissed

Bench: Shri.Vijay Pal Rao & Shri Ramit Kocharassessment Year: 2015-16 Income Tax Officer, V. Monad Infrasolution Limited, Ward-2(2), Allahabad C-80 Gtb Nagar Kareli, Allahabad, 211016 U.P. Pan-Aajcm2155J (Appellant) (Respondent) C.O. No. 01/Alld/2021 In Assessment Year: 2015-16 Monad Infrasolution Limited, V. Income Tax Officer, C-80 Gtb Nagar Kareli, Ward-2(2), Allahabad Allahabad, 211016 U.P. Pan-Aajcm2155J (Appellant) (Respondent)

penalty order u/s 271 (1) (b) of the Income tax Act, 1961 dated 20.11.2017 was passed Imposing Rs. 10,000/-. Final Show cause notice dated 04.12.2017 was issued through registered post /email, fixing the date of compliance on 11.12.2017 at 12.50 P.M at 38 M.G Marg, Kayaker Bhawan and show cause why following addition may not be made in your

MINTO COLONIZERS PRIVATE LIMITED,ALLAHABAD vs. DCIT CENTRAL CIRCLE , ALLAHABAD, 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

JEEVAN JYOTI INFRASTRUCTURE COMPANY PRIVATE LIMITED,ALLAHABAD vs. DCIT, CENTRAL CIRCLE, ALLAHABAD , 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. NAVJEEVAN PEDIATRICS PRIVATE LIMITED, 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

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