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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

24) r.w.s 56 of the Act liable for taxation during the year under consideration. 8. BECAUSE the CIT(A) failed to appreciate the facts and circumstances of the case and position of law, as most of the voluntary donations received by Kriya Yog Ashram/Trust are from that foreign nationals who have donated the same out of the income on which

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

24) r.w.s 56 of the Act liable for taxation during the year under consideration. 8. BECAUSE the CIT(A) failed to appreciate the facts and circumstances of the case and position of law, as most of the voluntary donations received by Kriya Yog Ashram/Trust are from that foreign nationals who have donated the same out of the income on which

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

24) r.w.s 56 of the Act liable for taxation during the year under consideration. 8. BECAUSE the CIT(A) failed to appreciate the facts and circumstances of the case and position of law, as most of the voluntary donations received by Kriya Yog Ashram/Trust are from that foreign nationals who have donated the same out of the income on which

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

24) r.w.s 56 of the Act liable for taxation during the year under consideration. 8. BECAUSE the CIT(A) failed to appreciate the facts and circumstances of the case and position of law, as most of the voluntary donations received by Kriya Yog Ashram/Trust are from that foreign nationals who have donated the same out of the income on which

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

24) r.w.s 56 of the Act liable for taxation during the year under consideration. 8. BECAUSE the CIT(A) failed to appreciate the facts and circumstances of the case and position of law, as most of the voluntary donations received by Kriya Yog Ashram/Trust are from that foreign nationals who have donated the same out of the income on which

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

24) r.w.s 56 of the Act liable for taxation during the year under consideration. 8. BECAUSE the CIT(A) failed to appreciate the facts and circumstances of the case and position of law, as most of the voluntary donations received by Kriya Yog Ashram/Trust are from that foreign nationals who have donated the same out of the income on which

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

24) r.w.s 56 of the Act liable for taxation during the year under consideration. 8. BECAUSE the CIT(A) failed to appreciate the facts and circumstances of the case and position of law, as most of the voluntary donations received by Kriya Yog Ashram/Trust are from that foreign nationals who have donated the same out of the income on which

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

24) r.w.s 56 of the Act liable for taxation during the year under consideration. 8. BECAUSE the CIT(A) failed to appreciate the facts and circumstances of the case and position of law, as most of the voluntary donations received by Kriya Yog Ashram/Trust are from that foreign nationals who have donated the same out of the income on which

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

24) r.w.s 56 of the Act liable for taxation during the year under consideration. 8. BECAUSE the CIT(A) failed to appreciate the facts and circumstances of the case and position of law, as most of the voluntary donations received by Kriya Yog Ashram/Trust are from that foreign nationals who have donated the same out of the income on which

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

24) r.w.s 56 of the Act liable for taxation during the year under consideration. 8. BECAUSE the CIT(A) failed to appreciate the facts and circumstances of the case and position of law, as most of the voluntary donations received by Kriya Yog Ashram/Trust are from that foreign nationals who have donated the same out of the income on which

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

24,420/- . The aforesaid return of income was processed by Revenue u/s 143(1) of the 1961 Act. Later, the return of income was selected for framing scrutiny assessment u/s 143(3) read with Section 143(2) of 2 Assessment Year: 2011-12 ACIT Circle-3, Mirzapur, U.P. v. M/s J.P. Yadav Sonebhadra,U.P. the 1961 Act ,and vide assessment

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

24,91,415) deposited on 10.01.2006 i.e. , after the due date of filing return u/s 139(1) as the same were not deposited to the credit of the employees’ PF a/cs within the due dates of 15 days from the close of the month as required under Explanation to section 36(1)(va) read with Paragraph

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

24,91,415) deposited on 10.01.2006 i.e. , after the due date of filing return u/s 139(1) as the same were not deposited to the credit of the employees’ PF a/cs within the due dates of 15 days from the close of the month as required under Explanation to section 36(1)(va) read with Paragraph

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

reassessment. However, in view of the fact that section 153A contains non-obstante clause qua section 147, the consequential requirement of issuing notice u/s 143(2) before making assessment u/s 147, also gets obliterated in an assessment u/s 153A. Moreover, section 153A directly empowers the AO to take up the assessment without acquiring any separate jurisdiction

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

reassessment. However, in view of the fact that section 153A contains non-obstante clause qua section 147, the consequential requirement of issuing notice u/s 143(2) before making assessment u/s 147, also gets obliterated in an assessment u/s 153A. Moreover, section 153A directly empowers the AO to take up the assessment without acquiring any separate jurisdiction

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

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