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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

29 of 79 her return of income declaring a total income of Rs.83,150/-. In this year also, the AO disallowed 5% of the payments made by the assessee in cash, i.e., 5% of Rs.10,50,000/-, which came to Rs.52,500/- and the same was added to the income of the assessee. In this year, the AO noticed that

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

29 of 79 her return of income declaring a total income of Rs.83,150/-. In this year also, the AO disallowed 5% of the payments made by the assessee in cash, i.e., 5% of Rs.10,50,000/-, which came to Rs.52,500/- and the same was added to the income of the assessee. In this year, the AO noticed that

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

29 of 79 her return of income declaring a total income of Rs.83,150/-. In this year also, the AO disallowed 5% of the payments made by the assessee in cash, i.e., 5% of Rs.10,50,000/-, which came to Rs.52,500/- and the same was added to the income of the assessee. In this year, the AO noticed that

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

29 of 79 her return of income declaring a total income of Rs.83,150/-. In this year also, the AO disallowed 5% of the payments made by the assessee in cash, i.e., 5% of Rs.10,50,000/-, which came to Rs.52,500/- and the same was added to the income of the assessee. In this year, the AO noticed that

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

29 of 79 her return of income declaring a total income of Rs.83,150/-. In this year also, the AO disallowed 5% of the payments made by the assessee in cash, i.e., 5% of Rs.10,50,000/-, which came to Rs.52,500/- and the same was added to the income of the assessee. In this year, the AO noticed that

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

29 of 79 her return of income declaring a total income of Rs.83,150/-. In this year also, the AO disallowed 5% of the payments made by the assessee in cash, i.e., 5% of Rs.10,50,000/-, which came to Rs.52,500/- and the same was added to the income of the assessee. In this year, the AO noticed that

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

29 of 79 her return of income declaring a total income of Rs.83,150/-. In this year also, the AO disallowed 5% of the payments made by the assessee in cash, i.e., 5% of Rs.10,50,000/-, which came to Rs.52,500/- and the same was added to the income of the assessee. In this year, the AO noticed that

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

29 of 79 her return of income declaring a total income of Rs.83,150/-. In this year also, the AO disallowed 5% of the payments made by the assessee in cash, i.e., 5% of Rs.10,50,000/-, which came to Rs.52,500/- and the same was added to the income of the assessee. In this year, the AO noticed that

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

29 of 79 her return of income declaring a total income of Rs.83,150/-. In this year also, the AO disallowed 5% of the payments made by the assessee in cash, i.e., 5% of Rs.10,50,000/-, which came to Rs.52,500/- and the same was added to the income of the assessee. In this year, the AO noticed that

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

29 of 79 her return of income declaring a total income of Rs.83,150/-. In this year also, the AO disallowed 5% of the payments made by the assessee in cash, i.e., 5% of Rs.10,50,000/-, which came to Rs.52,500/- and the same was added to the income of the assessee. In this year, the AO noticed that

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)

reassessment order dated 24.06.2016 passed by Assessing Officer u/s. 143(3) 4 Assessment Year: 2012-13 Sanjay Majumdar r.w.s. 147 of the 1961 Act is erroneous so far as is prejudicial to the interest of the Revenue within provisions of Section 263 of the 1961 Act, by holding as under: “3. I have considered the assessment proceeding of the Assessing

ARIES MARKETERS PRIVATE LIMITED,ALLAHABAD vs. COMMISSIONER OF INCOME TAX (APPEALS), ALLAHABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Vijay Pal Raoassessment Year: 2007-08

10 as under: “In the present case, admittedly the original assessment was under Section 143(3). The notice under Section 148 was sought to be issued more than four years after the end of the relevant assessment year. The assessment year is A.Y. 1998-99. Notice under Section 148 was issued on 29 March 2005. In the circumstance, clearly

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

section 153A have been framed by ACIT, Central Circle, New Delhi, therefore, prior approval of the JCIT in respect of each assessment year referred to under section 153A or 153B shall have to be obtained. Thus, no order of assessment or re-assessment shall be passed by the A.O. in the present cases in respect of each assessment years under

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

section 153A have been framed by ACIT, Central Circle, New Delhi, therefore, prior approval of the JCIT in respect of each assessment year referred to under section 153A or 153B shall have to be obtained. Thus, no order of assessment or re-assessment shall be passed by the A.O. in the present cases in respect of each assessment years under

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

section 153A have been framed by ACIT, Central Circle, New Delhi, therefore, prior approval of the JCIT in respect of each assessment year referred to under section 153A or 153B shall have to be obtained. Thus, no order of assessment or re-assessment shall be passed by the A.O. in the present cases in respect of each assessment years under

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

section 153A have been framed by ACIT, Central Circle, New Delhi, therefore, prior approval of the JCIT in respect of each assessment year referred to under section 153A or 153B shall have to be obtained. Thus, no order of assessment or re-assessment shall be passed by the A.O. in the present cases in respect of each assessment years under

DCIT, CIRCLE-II , ALLAHABAD vs. BHARAT PUMPS & COMPRESSORS LTD, ALLAHABAD

In the result, appeal filed by Revenue for ay: 2007-08 is allowed for statistical purposes

Bench: Shri.Vijay Pal Rao & Shri Ramit Kochar

147 r.w. Section 148 of the Act and statutory notices were issued by Revenue from Bharat Pumps & Compressors Ltd. Assessment Years: 2005-06 & 2007-08 time to time during the course of reassessment proceedings . The Revenue also furnished to the assessee reasons recorded for reopening of the concluded assessment . The assessee was asked to furnish return of income in response

DCIT, CIRCLE-II , ALLAHABAD vs. BHARAT PUMPS & COMPRESSORS LTD, ALLAHABAD

In the result, appeal filed by Revenue for ay: 2007-08 is allowed for statistical purposes

Bench: Shri.Vijay Pal Rao & Shri Ramit Kochar

147 r.w. Section 148 of the Act and statutory notices were issued by Revenue from Bharat Pumps & Compressors Ltd. Assessment Years: 2005-06 & 2007-08 time to time during the course of reassessment proceedings . The Revenue also furnished to the assessee reasons recorded for reopening of the concluded assessment . The assessee was asked to furnish return of income in response

M/S UDVASIT BEROJGAR SAHAKARI SHRAM SAMVIDA SAMITI LTD.,,SONBHADRA vs. CIT (EXEMPTION), ALLAHABAD

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

Bench: Shri.Vijay Pal Raoassessment Year: 2018-19

reassessment was unjustified - S.R. Batliboi & Co. v. Assistant Commissioner of Income-tax, Circle - 54, Kolkata - [2018] 100 taxmann.com 328 (Calcutta).” 3 3. The main thrust of the written submissions filed by the assessee is that the amended provisions of section 36(1) (va) as well as section 43B vide Finance Bill, 2021 is applicable only with effect from assessment year