ALLAHABAD DEVELOPMENT AUTHORITY,ALLAHABAD vs. ACIT (EXEMPTION), LUCKNOW

In the result all three appeals of the Assessee are partly allowed

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

e) the judgment and order dated 16.09.2013 (supra) had attained finality as the revenue did not challenge the same by taking the matter before the Hon'ble High Court; and f) since then, the judgment of the Allahabad Bench of ITAT in ITA No.390(Alld)2016 as has been referred to (a) above, has also has been

M/S. GOVIND STONE PRIVATE LIMITED ,HAMIRPUR vs. INCOME TAX OFFICER -5(4), BANDA

Bench: Shrivijay Pal Rao & Shri Ramit Kochar

section 68 of the Income-tax Act relating to cash credits. 51 Assessment Year: 2013-14 M/s. Govind Stone Pvt. Ltd. v. ITO Banda “The existing provisions of the aforesaid section 68 provide that where any sum is found credited in the books of an assessee maintained for any previous year, and the assessee offers no explanation about

SHRI MAHAVEER CHARITABLE TRUST ,ALLAHABAD vs. ITO(EXEMPTION), ALLAHABAD

In the result, the appeal of the assessee is partly allowed

Bench: Sh. Subhash Malguria & Sh. Nikhil Choudharya.Y. 2013-14 Shri Mahaveer Charitable Trust, Vs Income Tax Officer 46, Rajendra Nagar, Baluaghat, (Exemption), Allahabad Allahabad-211003, U.P. Pan: Aahts9123K (Appellant) (Respondent) Assessee By: Dr. Pawan Jaiswal & Sh. Ajit Kumar, Advocates Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 22.07.2025 Date Of 14.10.2025 Pronouncement: O R D E R Per Nikhil Choudhary, A.M. This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit, Nfac Dated 28.09.2024, Wherein The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee That Was Filed Against The Orders Of The Income Tax Officer (Exemption), Allahabad Dated 30.03.2018. The Grounds Of Appeal Are As Under: - “1. Because The Impugned Order Of The Ld. Cit(A) Dated 28.09.2024 Affirming The Addition Of Rs. 1,97,69,650/- On Account Of Donation Received & Rejection Of The Submissions Of The Appellant That Appeal Proceedings Pending Against The Order Passed Under Section 143(3) Dated 30.03.2016 Are Infructuous Is Absolutely Illegal & Against The Principles Of Law. 2. Because The Hon'Ble Supreme Court In The Case Of Cit V. Alagendran Finance Ltd. [27.07.2007] Had Observed That When An Order Of Assessment Is Reopened, The Previous Assessment Will Be Held To Be Set Aside & The Whole Proceedings Would Start Afresh & In The Case In Hands The Assessment Order Dated 30.03.2016 Has Been Set-Aside By The Then Incumbent Ld. Cit(E); That Is To Say That No Assessment Existed On The Date When Order Dated 28.02.2018 Under Section 263 Of The Act Was Passed By The Then Incumbent Cit(E). 3. Because Section 263 Of The Act Grants Power To The Jurisdictional Commissioner To Direct For Revision Of Orders & Reads As Under (Relevant Statute Quoted):

E) and thereafter no assessment order existed after 28.02.2018 when the order under section 263 was passed by the then ld. CIT (Exemption). It was further submitted that the subject matter of the appeal against the assessment order under section 143(3) dated 30.03.2016 and order dated 28.12.2018 under section 143(3) r.w.s. 263 that were made

SHRI MAHAVEER CHARITABLE TRUST,ALLAHABAD vs. COMMISSIONER OF INCOME TAX (EXEMPTIONS), LUCKNOW

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

Bench: Shri.Vijay Pal Rao & Shri. Ramit Kocharassessment Year: 2013-14 Shri Mahaveer Charitable V. Commissioner Of Income Tax Trust (Exemption), Lucknow 46, Rajendra Nagar Balua Ghat, Allahabad Tan/Pan: Aahts9123K (Respondent) Appellant By: Mr. Pawan Jaiswal, C.A. Respondent By: Mr. Shantanu Dhamija, Cit Dr Date Of Hearing: 26.07.2021 Date Of Pronouncement: 03.08.2021 O R D E R

3) at a total income of Rs. Nil but, however, the anonymous donations of Rs. 1,97,69,650/- were charged to tax by AO under section 115BBC. The CIT(E) noticed that the Assessing Officer has not completed the assessment as per the provisions of section 13(7) of the Income Tax Act. The Commissioner was also

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)

68 of the 1961 Act. The ld. CIT-DR submitted that no evidences 13 P a g e | 14 ITA No. 103/Alld/2017 and C.O.No. 22/Alld/2017 (arising out of ITA No. 103/Alld/2017) Assessment Year 2011-12 Sunshine Infraestate Private Limited,Allahabad were brought on record by the assessee before ld. AO/Ld. CIT(A) and even before the tribunal. It was submitted

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

E R PER ANADEE NATH MISSHRA, A.M. Grounds taken by the assessee and the Revenue in these appeals are as under: I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 2 GROUNDS OF APPEAL I.T.A. No.113/Alld/2025 (A.Y. 2011-12) “1. That the notice dated 03.04.2013 issued under Section 153A of the Income

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

E R PER ANADEE NATH MISSHRA, A.M. Grounds taken by the assessee and the Revenue in these appeals are as under: I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 2 GROUNDS OF APPEAL I.T.A. No.113/Alld/2025 (A.Y. 2011-12) “1. That the notice dated 03.04.2013 issued under Section 153A of the Income

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

E R PER ANADEE NATH MISSHRA, A.M. Grounds taken by the assessee and the Revenue in these appeals are as under: I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 2 GROUNDS OF APPEAL I.T.A. No.113/Alld/2025 (A.Y. 2011-12) “1. That the notice dated 03.04.2013 issued under Section 153A of the Income

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

E R PER ANADEE NATH MISSHRA, A.M. Grounds taken by the assessee and the Revenue in these appeals are as under: I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 2 GROUNDS OF APPEAL I.T.A. No.113/Alld/2025 (A.Y. 2011-12) “1. That the notice dated 03.04.2013 issued under Section 153A of the Income

M/S. SUBHASH STONE INDUSTRIES (P) LTD.,NAINITAL vs. DCIT, CENTRAL CIRCLE, ALLAHABAD

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

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

e) Disallowance of Proportionate Expenses Rs.1,55,700/- ----------------- Total Rs. 6,26,650/- 5 Assessment Year: 2008-09 M/s Subhash Stone Industries Private Limited (Formerly Rajluxmi Stone Crushers Private Limited) v. Deputy Commissioner of Income Tax, Central Circle, Allahabad ------------------- Hence, an addition of Rs. 6,26,650/- was made by the AO to the income of the assessee

M/S KESARWANI ZARDA BHANDAR,,ALLAHABAD vs. JT.CIT,, ALLAHABAD

In the result, the appeal of Revenue is dismissed and the appeal of the assessee is partly allowed

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

3) of the Income Tax Act by the various higher authorities of the department so as per the principles of consistency addition made is unwarranted as the assessing officer is bound to give cognizance to the past records. (c) That in the assessment year 1999-2000 for the first time in the history of the case an identical and similar

ACIT,, ALLAHABAD vs. KESARWANI ZARDA BHANDAR,, ALLAHABAD

In the result, the appeal of Revenue is dismissed and the appeal of the assessee is partly allowed

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

3) of the Income Tax Act by the various higher authorities of the department so as per the principles of consistency addition made is unwarranted as the assessing officer is bound to give cognizance to the past records. (c) That in the assessment year 1999-2000 for the first time in the history of the case an identical and similar

GHAUS MEMORIAL SAHKARI AWAS SAMITI LTD.,ALLAHABAD vs. ACIT RANGE-2, ALLAHABAD

In the result, appeal filed by assessee in ITA no

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

e-mail address/speed post submitted by the applicant while filing the appeal. No written submission or any paper books has been filed in support of any of the grounds of appeal in this office. It appears that assessee is not interested in pursuing his own appeal. The case is being decided in absence of any submission or attendance

MADHU DUBEY,ALLAHABAD vs. DC/AC-1(1),ALLAHABAD, MG MARG ALLAHABAD

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

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguriaassessment Year: 2014-15 Madhu Dubey V. Dc/Ac-1(1) 657A/1, Jamuna Nagar, Chak Mg Marg, Allahabad- Raghunath, Naini-211008. 211001. Pan:Asipd8489J (Appellant) (Respondent) Appellant By: Shri Naman Agrawal, C.A. Respondent By: Shri A. K. Singh, Sr. Dr Date Of Hearing: 09 09 2025 Date Of Pronouncement: 30 09 2025 O R D E R

e. Rs 56 06.000/is added to the income of assessee under provision of section 56(2)(vii)(b) (ii) of IT Act,1961. (Addition of Rs.56,06,000/-] 5. The assessee has made capital addition of Rs 2 lacs & Rs 1 lac on 1110/2013 & 31/10/2013 respectively till this date assessee has made withdrawal of Rs.3

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

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 & ITA Nos.5

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

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 & ITA Nos.5

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

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 & ITA Nos.5

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

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

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 & ITA Nos.5