KARAM SAFETY PRIVATE LIMITED,SITARGANJ vs. THE INCOME TAX OFFICER, WARD-2(3)(5), UDHAM SINGH NAGAR

In the result, both the appeals of the assessee are allowed and that of the Stay Applications are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

capital of other company which remains in existence and continues its undertaking but the context in which the term is used may show that it is intended to include such an acquisition. See: Halsbury's Laws of England (4th edition volume 7 para 1539). Two companies may join to form a new company, but there may be absorption or blending

KARAM SAFETY PRIVATE LIMITED,UDHAM SINGH NAGAR vs. THE INCOME TAX OFFICER, WARD-2(3)(5), UDHAM SINGH NAGAR

In the result, both the appeals of the assessee are allowed and that of the Stay Applications are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

capital of other company which remains in existence and continues its undertaking but the context in which the term is used may show that it is intended to include such an acquisition. See: Halsbury's Laws of England (4th edition volume 7 para 1539). Two companies may join to form a new company, but there may be absorption or blending

SHRI ABHISHEK JOSHI,DEHRADUN vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX , DEHRADUN

In the result, the appeal of the assessee is allowed

Bench: Sh. Saktijit Dey & Shri M. Balaganeshshri Abhishek Joshi, Vs. The Pr. Cit, C/O. Parimal Patet, Gk Patet & Dehradun Co, 14 Abhishek Tower, Subhash Road, Dehradun (Appellant) (Respondent) Pan: Ajopj4300M Assessee By : Dr. Rakesh Gupta, Adv Shri Somil Aggarwal, Adv Revenue By: Shri N. S. Jangpangi, Cit Dr Date Of Hearing 26/07/2023 Date Of Pronouncement 15/09/2023

143(3) rws 147 of the Income-tax Act, 1961 (hereinafter referred to as „the Act‟) dated 30.10.2018 by the Assessing Officer, ITO, Ward-1(1), Dehradun (hereinafter referred to as „ld. AO‟). 2. The assessee has raised the following grounds of appeal:- “1. That having regard to the facts and circumstances of the case, Ld. PCIT has erred

DIGVIJAY SINGH,DEHRADUN vs. DCIT,CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee for assessment year

section 143(3) of the Act, dated 28.12.2018 for assessment year 2015-16 by DCIT, Central, Circle, Dehradun (who is the same officer assessing the assessee also), wherein, in para 7 of the said order, the Assessing Officer of Sh. Rameshwar Havelia had categorically stated that it is Sh. Rameshwar Havelia, who had made cash payment of Rs. 1 crore

DIGVIJAY SINGH,DEHRADIM vs. DCIT,CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee for assessment year

section 143(3) of the Act, dated 28.12.2018 for assessment year 2015-16 by DCIT, Central, Circle, Dehradun (who is the same officer assessing the assessee also), wherein, in para 7 of the said order, the Assessing Officer of Sh. Rameshwar Havelia had categorically stated that it is Sh. Rameshwar Havelia, who had made cash payment of Rs. 1 crore

ITO, WARD-1(1)(3), DEHRADUN, DEHRADUN vs. TRISHLA STEEL PVT LTD, DEHRADUN

In the result, the appeal filed by the Revenue is dismissed

gains, the land was deemed agricultural, not a capital asset, and thus not taxable.", "result": "Dismissed", "sections": [ "143(2)", "142(1)", "68", "2(14)" ], "issues

OMWATI,DEHRADUN vs. PR.CIT, DEHRADUN

In the result, the appeal of the assessee is allowed

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshsmt. Omwati Pr. Cit W/O Sh. Dariyav Singh Dehradun 171/1, Vasant Vihar, Vs. Dehradun Pan-Aanpw 6438K (Appellant) (Respondent)

143(3)/147 dated 21-03-2016 was not maintainable and an invalid re-assessment cannot be set aside u/s 263 of the Act. 4. That the appellant craves the leave to add, amend, modify, delete any of the grounds of appeal before or at the time of hearing and all the above grounds are without prejudice to each other

SMT. KUSUM KUJWAL,NAINITAL vs. PCIT, BAIREILLY

Appeal is dismissed in above terms

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

143(3) r.ws 144(B) of the Act is erroneous in so far as prejudicial to the interest of revenue as per explanation 2(a) to section 263 of the Income Tax Act, 1961. As the AO failed to understand the nature of transaction, applicability of section 500 and to compute the long term capital gain

DARIYAV SINGH,DEHRADUN vs. PR. CIT, DEHRADUN

In the result, both the appeals of the assessee are allowed

Bench: Shri Saktijit Dey & Shri M. Balaganeshsh. Sanjay Kumar Pr. Cit 170, Vasant Vihar-1 Dehradun Dehradun Vs. Pan-Akkpk 1007F (Appellant) (Respondent) Sh. Dariyav Singh Pr. Cit 28-Chakrata Road, Dehradun Dehradun Vs. Pan-Awkps 6026L (Appellant) (Respondent) Appellant By Dr. Rakesh Gupta & Mr. Sherey Jain, Advocates Respondent By Mr. N.S.Jangpangi, Cit-Dr

143(3) r.w.s. 147 of the Act on 15/03/2016. This assessment was sought to be revised by the Ld. PCIT by invoking revision jurisdiction u/s 263 of the Act on the ground that the Ld. A.O. had not examined the claim of deduction u/s 54B of the Act made by the Ld. AO, thereby making reassessment order erroneous and prejudicial

SANJAY KUMAR,DEHRADUN vs. PRCIT, DEHRADUN

In the result, both the appeals of the assessee are allowed

Bench: Shri Saktijit Dey & Shri M. Balaganeshsh. Sanjay Kumar Pr. Cit 170, Vasant Vihar-1 Dehradun Dehradun Vs. Pan-Akkpk 1007F (Appellant) (Respondent) Sh. Dariyav Singh Pr. Cit 28-Chakrata Road, Dehradun Dehradun Vs. Pan-Awkps 6026L (Appellant) (Respondent) Appellant By Dr. Rakesh Gupta & Mr. Sherey Jain, Advocates Respondent By Mr. N.S.Jangpangi, Cit-Dr

143(3) r.w.s. 147 of the Act on 15/03/2016. This assessment was sought to be revised by the Ld. PCIT by invoking revision jurisdiction u/s 263 of the Act on the ground that the Ld. A.O. had not examined the claim of deduction u/s 54B of the Act made by the Ld. AO, thereby making reassessment order erroneous and prejudicial

DR. VIRENDRA SWAROOP EDUCATIONAL FOUNDATION,KANPUR vs. ACIT, CENTRAL CIRCLE, DEHRADUN, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2023-24] Dr. Virendra Swaroop Vs Acit Educational Foundation Central Circle 15/96, Civil Lines, Kanpur Dehradun Uttar Pradesh-208001 Pan-Aaajd0224D Appellant Respondent Assessee By Shri Salil Kapoor, Adv. Shri Rajiv Sahni, Ca Shri Sumit Lal Chandanim, Adv. Shri Shivam Yadav, Adv. & Ms. Ananya Kapoor, Adv. Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 11.12.2025 Date Of Pronouncement 16.01.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 16.09.2025 By Ld. Pr. Commissioner Of Income Tax (Central), Kanpur [“Pcit”] Passed U/S 12(Ab)(4)(Ii) Of The Income Tax Act, 1961[“The Act”] Cancelling The Registration Granted U/S 12A Of The Act From Assessment Year 2023-24 & Onwards.

gains of the real estate business of sale, purchase and leasing activities can be termed as incidental to the attainment of trust's objectives and are in the nature of commercial activities carried out for purposes other than for the objects of the trust. Therefore, vide impugned order, ld. PCIT has cancelled the registration granted u/s 12A/12AA or 12AB

AKRAM,ROORKEE vs. DCIT, CIRCLE, HARIDWAR

Appeal is partly allowed for statistical purposes in above terms

Bench: Sh. Satbeer Singh Godara & Sh. Naveen Chandra

143 of ZALR Act to convert the land use by the assessee. The contention of the AO that, because the area had been notified as industrial zone, the nature of the land 4 Akram would change to industrial on account of narration in the sale deed, is not well founded. In the first place, the industrial zone

JOINT COMMISSIONER OF INCOME TAX, SUBHASH ROAD DEHADUN vs. M/S TIMES SQUARE, SAHASTRADHARA ROAD

In the result, appeal of the Revenue is dismissed

capital gains (section 50C) and\nother sources (section 56) arising out of transactions in immovable\nproperty, the higher of sale consideration or stamp duty value\nwas adopted. The difference was taxed as income both in the\nhands of the purchaser and the seller.\n\n16.2 It has been pointed out that the variation between stamp duty\nvalue and actual consideration

DAVINDER KUMAR MAGO,PUNJABI BAGH vs. DCIT/ACIT CENTRAL CIRCLE, DDN, DEHRADUN

In the result appeal of the assessee is allowed

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2019-20] Davinder Kumar Mago Vs Dcit/Acit 12/1, Punjabi Bagh, Central Circle, External Punjabi Bagh, Dehradun New Delhi-110026 Uttarakhand Pan-Ajhpm9802A Appellant Respondent Appellant By Shri Ajay Wadhwa, Adv. (Vc) Respondent By Ms. Poonam Sharma, Cit Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026 Order Per Manish Agarwal, Am : This Appeal Filed By The Assessee Against The Order By Pr.Cit (Central), Kanpur At Meerut Passed U/S 263 Of The Income Tax Act, 1861 (“The Act”) Dated 08.01.2026 Arising Out Of The Order Passed U/S 143(3) R.W.S. 147 Of The Act.

capital gain', secondly, the nil ALV or lower ALV as discussed in regard to above stated properties, in the above part of this order vide Paragraph No. 07 to 40, and non-initiation of penalty proceedings under Section 271C of the Act, whether these attract the revision provisions under Section 263 of the Act or not. We note that

SIDHIDATRI BUILDERS & DEVELOPERS,DEHRADUN vs. ITO, WARD-2(3), DEHRADUN

Appeal is allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh(Through Video Conferencing) Assessment Year: 2014-15 Sidhidatri Builders & Vs. Income Tax Officer, Developers, C/O- R Gupta & Ward-2(3), Associates, 1St Floor, Mid Dehradun Building, 88-Nehru Colony, Dehradun Pan: Acgfs8424G (Appellant) (Respondent) Assessee By Sh. Praveen Goyal, Self Department By Sh. Amar Pal Singh, Sr. Dr

sections 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused. 2. We notice during the course of hearing that the assessee/appellate herein is aggrieved against both the learned lower authorities’ action adding short-term capital gains

DY. COMMISSISSIONER OF INCOME TAX, DEHRADUN vs. WEATHERFORD OIL TOOLS ME LIMITED, MUMBAI

In the result, Appeals of the Revenue's are dismissed\nOrder pronounced in the open court on\nSd/-\n(MANISH AGARWAL)\nACCOUNΤΑΝΤ ΜΕMBER\nDate: 28

capital tools M.E. Ltd.\nunder the head \"Salaries\".\nThe assessee does not get the benefit of exclusionary clause 2 of sec.\n9(1)(vii) since this activity executing annual maintenance contract and\nconsultancy is not a mining activity and is purely technical service.\nSimilarly, these nature of activities are not covered under provisions of\nsec. 44BB and royalty in nature

SAHKUMBARI ASSOCIATES,DEHRADUN vs. ACIT, CIRCLE-2, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Shri Anil Chaturvedi & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.261/Del/2018 िनधा"रणवष"/Assessment Year: 2014-15 बनाम Sahkumbari Associates, Acit Vs. C/O Matta Garg & Co., Circle-2, 15, Astley Hall, Dehradun. Dehradun, Uttarakhand. Pan No. Aagas1127F अपीलाथ" Appellant ""यथ"/Respondent

Section 143(2) of the Act dated 20.09.2016 title limited scrutiny’ categorically states that the issue of deduction claimed under the head capital gains

KOMA SINGHAL,DEHRADUN vs. DCIT/ACIT CEN CIR, DEHRADUN

In the result, Appeal of the Assessee is allowed

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

143(3) of the Act. 4. Aggrieved by the Assessment order dated 28/12/2022, the Assessee preferred an appeal before the Ld. CIT(A). The Ld. CIT(A) vide order dated 06/02/2025, sustained the partial disallowance of Rs. 3 KomaSinghal 3,00,800/- by partly allowing the Appeal. As against the order of the Ld. CIT(A) dated 06/02/2025, the Assessee