ACIT,ALLAHABAD vs. M/S SUNSINE INFRASTATE PVT TTD, ALLAHABAD

In the result, the appeal filed by Revenue in ITA no

Bench: Shri.Vijay Pal Rao & Shri Ramit Kocharassessment Year: 2011-12 The Assistant Commissioner Of Sunshine Infraestate Income-Tax, Central Circle, V. Private Limited Allahabad, U.P. 17, Industrial Area, Naini, Allahabad, U.P. Pan: Aancs9247H (Appellant) (Respondent) C.O.No. 22/Alld/2017 (Arising Out Of Ita No.103/Alld/2017) Assessment Year: 2011-12 Sunshine Infraestate Private Limited The Assistant 17, Industrial Area, Naini, V. Commissioner Of Allahabad, U.P. Income-Tax, Central Circle, Allahabad, U.P. Pan: Aancs9247H (Appellant) (Respondent)

D E R PER SHRI RAMIT KOCHAR, ACCOUNTANT MEMBER: This appeal filed by Revenue with Income Tax Appellate Tribunal, Allahabad Bench, Allahabad (hereinafter called “the tribunal”) in ITA No. 103/Alld/2017 for assessment year(ay) 2011-12 has arisen from the appellate order dated 22.02.2017 passed by learned Commissioner of Income Tax(Appeals)- III, Lucknow, U.P. (hereinafter called

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3, MIRZAPUR vs. M/S. J.P.YADAV , SONEBHADRA

In the result, appeal filed by the Revenue in ITA no

Bench: Shrivijay Pal Rao & Shri Ramit Kochar

147 of the 1961 Act, which is a best judgment reassessment order passed by the AO. Our attention was drawn by ld. Sr. DR to page number 46, 59 , 63 and 68 of the paper book filed by the assessee . The ld. Sr. DR would submit that ld. CIT(A) erred in deleting the additions as were made

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

1 pees. 8GB” . He also drew our attention to the report of an expert (included in the paper book, filed by the assessee) in which it has been mentioned that there were approximately 40,434 seized documents, 7 CPUs, 26 HDDs and one laptop seized during the search u/s 132 of the Act. The expert has opined that the storage

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

1 pees. 8GB” . He also drew our attention to the report of an expert (included in the paper book, filed by the assessee) in which it has been mentioned that there were approximately 40,434 seized documents, 7 CPUs, 26 HDDs and one laptop seized during the search u/s 132 of the Act. The expert has opined that the storage

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

1 pees. 8GB” . He also drew our attention to the report of an expert (included in the paper book, filed by the assessee) in which it has been mentioned that there were approximately 40,434 seized documents, 7 CPUs, 26 HDDs and one laptop seized during the search u/s 132 of the Act. The expert has opined that the storage

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

1 pees. 8GB” . He also drew our attention to the report of an expert (included in the paper book, filed by the assessee) in which it has been mentioned that there were approximately 40,434 seized documents, 7 CPUs, 26 HDDs and one laptop seized during the search u/s 132 of the Act. The expert has opined that the storage

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

D E R PER BENCH: These TEN appeals have been preferred by two different assessees. The appeals in ITA Nos.50 to 54/Alld/2023 in the case of Sanjana are directed against separate orders, all dated 06.03.2023, passed by the National Faceless Appeal Centre (NFAC), Delhi for assessment years 2012-13, 2013-14, 2014-15, ITA Nos.50, 51, 52, 53 & 54/ALLD/2023

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

D E R PER BENCH: These TEN appeals have been preferred by two different assessees. The appeals in ITA Nos.50 to 54/Alld/2023 in the case of Sanjana are directed against separate orders, all dated 06.03.2023, passed by the National Faceless Appeal Centre (NFAC), Delhi for assessment years 2012-13, 2013-14, 2014-15, ITA Nos.50, 51, 52, 53 & 54/ALLD/2023

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

D E R PER BENCH: These TEN appeals have been preferred by two different assessees. The appeals in ITA Nos.50 to 54/Alld/2023 in the case of Sanjana are directed against separate orders, all dated 06.03.2023, passed by the National Faceless Appeal Centre (NFAC), Delhi for assessment years 2012-13, 2013-14, 2014-15, ITA Nos.50, 51, 52, 53 & 54/ALLD/2023

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

D E R PER BENCH: These TEN appeals have been preferred by two different assessees. The appeals in ITA Nos.50 to 54/Alld/2023 in the case of Sanjana are directed against separate orders, all dated 06.03.2023, passed by the National Faceless Appeal Centre (NFAC), Delhi for assessment years 2012-13, 2013-14, 2014-15, ITA Nos.50, 51, 52, 53 & 54/ALLD/2023

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

D E R PER BENCH: These TEN appeals have been preferred by two different assessees. The appeals in ITA Nos.50 to 54/Alld/2023 in the case of Sanjana are directed against separate orders, all dated 06.03.2023, passed by the National Faceless Appeal Centre (NFAC), Delhi for assessment years 2012-13, 2013-14, 2014-15, ITA Nos.50, 51, 52, 53 & 54/ALLD/2023

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

D E R PER BENCH: These TEN appeals have been preferred by two different assessees. The appeals in ITA Nos.50 to 54/Alld/2023 in the case of Sanjana are directed against separate orders, all dated 06.03.2023, passed by the National Faceless Appeal Centre (NFAC), Delhi for assessment years 2012-13, 2013-14, 2014-15, ITA Nos.50, 51, 52, 53 & 54/ALLD/2023

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

D E R PER BENCH: These TEN appeals have been preferred by two different assessees. The appeals in ITA Nos.50 to 54/Alld/2023 in the case of Sanjana are directed against separate orders, all dated 06.03.2023, passed by the National Faceless Appeal Centre (NFAC), Delhi for assessment years 2012-13, 2013-14, 2014-15, ITA Nos.50, 51, 52, 53 & 54/ALLD/2023

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

D E R PER BENCH: These TEN appeals have been preferred by two different assessees. The appeals in ITA Nos.50 to 54/Alld/2023 in the case of Sanjana are directed against separate orders, all dated 06.03.2023, passed by the National Faceless Appeal Centre (NFAC), Delhi for assessment years 2012-13, 2013-14, 2014-15, ITA Nos.50, 51, 52, 53 & 54/ALLD/2023

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

D E R PER BENCH: These TEN appeals have been preferred by two different assessees. The appeals in ITA Nos.50 to 54/Alld/2023 in the case of Sanjana are directed against separate orders, all dated 06.03.2023, passed by the National Faceless Appeal Centre (NFAC), Delhi for assessment years 2012-13, 2013-14, 2014-15, ITA Nos.50, 51, 52, 53 & 54/ALLD/2023

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

D E R PER BENCH: These TEN appeals have been preferred by two different assessees. The appeals in ITA Nos.50 to 54/Alld/2023 in the case of Sanjana are directed against separate orders, all dated 06.03.2023, passed by the National Faceless Appeal Centre (NFAC), Delhi for assessment years 2012-13, 2013-14, 2014-15, ITA Nos.50, 51, 52, 53 & 54/ALLD/2023

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

1)(iiia) of the Act. Hence, specified date shall be the date on which the order under sub-section (4) of section 245D was passed for not providing for the terms of the settlement. 20. Therefore on examining the provisions as hereinabove, relating to the limitation of assessment in cases abated before Settlement Commission, it is clearly evident that

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

1)(iiia) of the Act. Hence, specified date shall be the date on which the order under sub-section (4) of section 245D was passed for not providing for the terms of the settlement. 20. Therefore on examining the provisions as hereinabove, relating to the limitation of assessment in cases abated before Settlement Commission, it is clearly evident that