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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

25 of 79 example that "the money in my bank account is meant to be donated to charity and hence it is not my income" which, according to the principles of taxation of income is not an acceptable proposition" 5 BECAUSE the CIT(A) has completely erred in law as well as on facts in treating the excess of receipts

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

25 of 79 example that "the money in my bank account is meant to be donated to charity and hence it is not my income" which, according to the principles of taxation of income is not an acceptable proposition" 5 BECAUSE the CIT(A) has completely erred in law as well as on facts in treating the excess of receipts

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

25 of 79 example that "the money in my bank account is meant to be donated to charity and hence it is not my income" which, according to the principles of taxation of income is not an acceptable proposition" 5 BECAUSE the CIT(A) has completely erred in law as well as on facts in treating the excess of receipts

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

25 of 79 example that "the money in my bank account is meant to be donated to charity and hence it is not my income" which, according to the principles of taxation of income is not an acceptable proposition" 5 BECAUSE the CIT(A) has completely erred in law as well as on facts in treating the excess of receipts

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

25 of 79 example that "the money in my bank account is meant to be donated to charity and hence it is not my income" which, according to the principles of taxation of income is not an acceptable proposition" 5 BECAUSE the CIT(A) has completely erred in law as well as on facts in treating the excess of receipts

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

25 of 79 example that "the money in my bank account is meant to be donated to charity and hence it is not my income" which, according to the principles of taxation of income is not an acceptable proposition" 5 BECAUSE the CIT(A) has completely erred in law as well as on facts in treating the excess of receipts

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

25 of 79 example that "the money in my bank account is meant to be donated to charity and hence it is not my income" which, according to the principles of taxation of income is not an acceptable proposition" 5 BECAUSE the CIT(A) has completely erred in law as well as on facts in treating the excess of receipts

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

25 of 79 example that "the money in my bank account is meant to be donated to charity and hence it is not my income" which, according to the principles of taxation of income is not an acceptable proposition" 5 BECAUSE the CIT(A) has completely erred in law as well as on facts in treating the excess of receipts

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

25 of 79 example that "the money in my bank account is meant to be donated to charity and hence it is not my income" which, according to the principles of taxation of income is not an acceptable proposition" 5 BECAUSE the CIT(A) has completely erred in law as well as on facts in treating the excess of receipts

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

25 of 79 example that "the money in my bank account is meant to be donated to charity and hence it is not my income" which, according to the principles of taxation of income is not an acceptable proposition" 5 BECAUSE the CIT(A) has completely erred in law as well as on facts in treating the excess of receipts

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

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

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

25 which conducted search under section 132 of the I.T. Act; also prepared appraisal report after full consideration of materials found/seized in the course of search under section 132 of the Act. They contended that the appraisal report thus prepared by the Investigation Wing of Income Tax Department is made available to the Assessing Officer as well

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

25 which conducted search under section 132 of the I.T. Act; also prepared appraisal report after full consideration of materials found/seized in the course of search under section 132 of the Act. They contended that the appraisal report thus prepared by the Investigation Wing of Income Tax Department is made available to the Assessing Officer as well

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

25 which conducted search under section 132 of the I.T. Act; also prepared appraisal report after full consideration of materials found/seized in the course of search under section 132 of the Act. They contended that the appraisal report thus prepared by the Investigation Wing of Income Tax Department is made available to the Assessing Officer as well

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

25 which conducted search under section 132 of the I.T. Act; also prepared appraisal report after full consideration of materials found/seized in the course of search under section 132 of the Act. They contended that the appraisal report thus prepared by the Investigation Wing of Income Tax Department is made available to the Assessing Officer as well

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

25 REVISED GROUNDS IN I.T.A. No.37/Alld/2019 27 I.T.A. No.38/Alld/2019 (Assessment year 2011-12) 30 32 I.T.A. No.39/Alld/2019 (Assessment year 2012-13) 34 36 REVISED GROUNDS IN I.T.A. No.39/Alld/2019 38 I.T.A. No.40/Alld/2019 (Assessment year 2013-14) 41 REVISED GROUNDS IN I.T.A. No.40/Alld/2019 44 I.T.A. No.13/Alld/2025 (Assessment year 2011-12) I.T.A. No.14/Alld/2025 (Assessment year 2013-14) I.T.A. No.39/Alld/2025 (Assessment year

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

25 REVISED GROUNDS IN I.T.A. No.37/Alld/2019 27 I.T.A. No.38/Alld/2019 (Assessment year 2011-12) 30 32 I.T.A. No.39/Alld/2019 (Assessment year 2012-13) 34 36 REVISED GROUNDS IN I.T.A. No.39/Alld/2019 38 I.T.A. No.40/Alld/2019 (Assessment year 2013-14) 41 REVISED GROUNDS IN I.T.A. No.40/Alld/2019 44 I.T.A. No.13/Alld/2025 (Assessment year 2011-12) I.T.A. No.14/Alld/2025 (Assessment year 2013-14) I.T.A. No.39/Alld/2025 (Assessment year

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

25 REVISED GROUNDS IN I.T.A. No.37/Alld/2019 27 I.T.A. No.38/Alld/2019 (Assessment year 2011-12) 30 32 I.T.A. No.39/Alld/2019 (Assessment year 2012-13) 34 36 REVISED GROUNDS IN I.T.A. No.39/Alld/2019 38 I.T.A. No.40/Alld/2019 (Assessment year 2013-14) 41 REVISED GROUNDS IN I.T.A. No.40/Alld/2019 44 I.T.A. No.13/Alld/2025 (Assessment year 2011-12) I.T.A. No.14/Alld/2025 (Assessment year 2013-14) I.T.A. No.39/Alld/2025 (Assessment year