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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

45 of 79 Rs.88,000/-. The grounds of appeal raised by the appellant are partly allowed." by the CIT(A) in the impugned appellate order, he has completely erred in restricting the relief to 50% only and sustaining the addition of Rs.88,000/-without any valid reason. 4. BECAUSE the CIT(A) has completely ignored and overlooked the facts

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

45 of 79 Rs.88,000/-. The grounds of appeal raised by the appellant are partly allowed." by the CIT(A) in the impugned appellate order, he has completely erred in restricting the relief to 50% only and sustaining the addition of Rs.88,000/-without any valid reason. 4. BECAUSE the CIT(A) has completely ignored and overlooked the facts

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

45 of 79 Rs.88,000/-. The grounds of appeal raised by the appellant are partly allowed." by the CIT(A) in the impugned appellate order, he has completely erred in restricting the relief to 50% only and sustaining the addition of Rs.88,000/-without any valid reason. 4. BECAUSE the CIT(A) has completely ignored and overlooked the facts

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

45 of 79 Rs.88,000/-. The grounds of appeal raised by the appellant are partly allowed." by the CIT(A) in the impugned appellate order, he has completely erred in restricting the relief to 50% only and sustaining the addition of Rs.88,000/-without any valid reason. 4. BECAUSE the CIT(A) has completely ignored and overlooked the facts

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

45 of 79 Rs.88,000/-. The grounds of appeal raised by the appellant are partly allowed." by the CIT(A) in the impugned appellate order, he has completely erred in restricting the relief to 50% only and sustaining the addition of Rs.88,000/-without any valid reason. 4. BECAUSE the CIT(A) has completely ignored and overlooked the facts

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

45 of 79 Rs.88,000/-. The grounds of appeal raised by the appellant are partly allowed." by the CIT(A) in the impugned appellate order, he has completely erred in restricting the relief to 50% only and sustaining the addition of Rs.88,000/-without any valid reason. 4. BECAUSE the CIT(A) has completely ignored and overlooked the facts

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

45 of 79 Rs.88,000/-. The grounds of appeal raised by the appellant are partly allowed." by the CIT(A) in the impugned appellate order, he has completely erred in restricting the relief to 50% only and sustaining the addition of Rs.88,000/-without any valid reason. 4. BECAUSE the CIT(A) has completely ignored and overlooked the facts

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

45 of 79 Rs.88,000/-. The grounds of appeal raised by the appellant are partly allowed." by the CIT(A) in the impugned appellate order, he has completely erred in restricting the relief to 50% only and sustaining the addition of Rs.88,000/-without any valid reason. 4. BECAUSE the CIT(A) has completely ignored and overlooked the facts

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

45 of 79 Rs.88,000/-. The grounds of appeal raised by the appellant are partly allowed." by the CIT(A) in the impugned appellate order, he has completely erred in restricting the relief to 50% only and sustaining the addition of Rs.88,000/-without any valid reason. 4. BECAUSE the CIT(A) has completely ignored and overlooked the facts

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

45 Nos. 76 – 81/CTK/2022) in which grounds raised by the assessee against validity of approval granted u/s 153D of the I.T. Act were dismissed. (H.1) Learned Departmental Representatives also submitted that procedural irregularity was not fatal if jurisdictional issue was established. Further, learned Departmental Representatives submitted that fiscal acts should be interpreted in a way which enables functioning

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

45 Nos. 76 – 81/CTK/2022) in which grounds raised by the assessee against validity of approval granted u/s 153D of the I.T. Act were dismissed. (H.1) Learned Departmental Representatives also submitted that procedural irregularity was not fatal if jurisdictional issue was established. Further, learned Departmental Representatives submitted that fiscal acts should be interpreted in a way which enables functioning

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

45 Nos. 76 – 81/CTK/2022) in which grounds raised by the assessee against validity of approval granted u/s 153D of the I.T. Act were dismissed. (H.1) Learned Departmental Representatives also submitted that procedural irregularity was not fatal if jurisdictional issue was established. Further, learned Departmental Representatives submitted that fiscal acts should be interpreted in a way which enables functioning

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

45 Nos. 76 – 81/CTK/2022) in which grounds raised by the assessee against validity of approval granted u/s 153D of the I.T. Act were dismissed. (H.1) Learned Departmental Representatives also submitted that procedural irregularity was not fatal if jurisdictional issue was established. Further, learned Departmental Representatives submitted that fiscal acts should be interpreted in a way which enables functioning

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

reassessment or re-computation shall be one year from the date of receipt of order of passed by the Settlement Commission. Since the order u/s 245D(4) was passed by the Settlement Commission on 17/08/2016 therefore the case shall not be barred by limitation before16//08/2017, i.e. one year from the date of order of the Settlement Commission not providing

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

reassessment or re-computation shall be one year from the date of receipt of order of passed by the Settlement Commission. Since the order u/s 245D(4) was passed by the Settlement Commission on 17/08/2016 therefore the case shall not be barred by limitation before16//08/2017, i.e. one year from the date of order of the Settlement Commission not providing

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

reassessment or re-computation shall be one year from the date of receipt of order of passed by the Settlement Commission. Since the order u/s 245D(4) was passed by the Settlement Commission on 17/08/2016 therefore the case shall not be barred by limitation before16//08/2017, i.e. one year from the date of order of the Settlement Commission not providing