BHANIYAWALA KISAAN SEWA SAHKARI SAMITI LIMITED,DEHARADUN vs. THE INCOME TAX OFFICER, WARD-1(1)(2), DEHRADUN

In the result, appeal filed by the assessee is dismissed

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

disallowed deduction u/s 80P of the Income Tax Act 1961 on the ground that the assessee has not filed its income return and also not considered that the assessee is co- operative society. 4. That on the facts and in circumstances of the case the Ld. CIT(A) has erred not considering Income Tax Return submitted during the assessment proceeding

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

disallowing deduction u/s 80IC/Chapter VI-A of the Act. 4. On the facts and circumstances of the case and in law, the Ld. AO/DRP have failed to appreciate that to invoke the provisions of Section 92BA, existence of any 'arrangement' to ‘more than ordinary profits’ between the Appellant and its Associate Enterprise (“AE”) need to be established under the provisions

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

disallowing deduction u/s 80IC/Chapter VI-A of the Act. 4. On the facts and circumstances of the case and in law, the Ld. AO/DRP have failed to appreciate that to invoke the provisions of Section 92BA, existence of any 'arrangement' to ‘more than ordinary profits’ between the Appellant and its Associate Enterprise (“AE”) need to be established under the provisions

ACIT, CIRCLE- 3, NAINITAL vs. KUMAON MANDAL VIKAS NIGAM LTD., NAINITAL

In the result, both appeals of the Revenue are partly allowed as above

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Disallowance of interest under section 14A. (v) Taxability of contract receipt of Rs.8,19,265/- on accrual basis 4. The facts of the case giving rise to these appeals are that the assessee, a Government Corporation, filed its Income Tax Returns (hereinafter, the ‘ITR’) of AYs 2012-13 and 2013-14 declaring tentative losses of (-) Rs.76,05,926/- and (-) Rs.20

ACIT, NAINITAL vs. M/S. KUMAON MANDAL VIKAS NIGAM LTD., NAINITAL

In the result, both appeals of the Revenue are partly allowed as above

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Disallowance of interest under section 14A. (v) Taxability of contract receipt of Rs.8,19,265/- on accrual basis 4. The facts of the case giving rise to these appeals are that the assessee, a Government Corporation, filed its Income Tax Returns (hereinafter, the ‘ITR’) of AYs 2012-13 and 2013-14 declaring tentative losses of (-) Rs.76,05,926/- and (-) Rs.20

G & T RESOURCES (EUROPE) LTD.,NEW DELHI vs. ADIT, DEHRADUN

In the result, the appeal of the assessee is allowed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 5553/Del/2012 : Asstt. Year: 2004-05 G&T Resources (Europe) Ltd., Vs Adit, C/O F-04 & 05, Triveni Commercial International Taxation, Complex, Sheikh Sarai, Phase-I, Dehradun New Delhi-110017 (Appellant) (Respondent) Pan No. Aabcg9877F Assessee By : None Revenue By : Sh. T. S. Mapwal, Sr. Dr Date Of Hearing: 25.04.2022 Date Of Pronouncement: 29.04.2022 Order Per Dr. B. R. R. Kumar: The Present Appeal Has Been Filed By The Assessee Against The Order Passed By The Ao U/S 143(3) Of The Income Tax Act, 1961 Dated 23.11.2006. 2. The Assessee Has Raised Revised Grounds Of Appeal: “1. That, On The Facts & In The Circumstances Of The Case & In Law, The Learned Ao Has Erred On Facts & In Law In Initiating Proceedings Under Section 148 Read Together With Section 147 Of The Income 1Ax Act, 1961. 2. That In The Absence Of Any New Facts, Other Than The Ones Already On Record Based On Which The Assessment Order Was Passed, Initiating Proceedings Under Section 148 After Expiry Of Four Years Are Bad In Law & Void Abinitio. 3. That, The Learned Ao Having Considered The Facts, Applied The Spirit Of The Boards Instructions As Contained In Notification 1767 In A Speaking Assessment Order Erred In Initiating Proceedings Under Section 148 After The Expiry Of Four Years Merely Because In A Subsequent

142 or section 148 or to disclose 5 G & T Resources (Europe) Ltd. fully and truly all material facts necessary for his assessment, for that assessment year: Provided further that nothing contained in the first proviso shall apply in a case where any income in relation to any asset (including financial interest in any entity) located outside India, chargeable

INCOME TAX OFFICER, WARD-1(1)(3), DEHRADUN, AAYKAR BHAWAN, SUBHASH ROAD, DEHRADUN vs. UTTARAKHAND PURV SAINIK KALYAN NIGAM LIMITED, STATION SUB AREA

In the result, appeal of the assessee is allowed

Bench: Sh. Yogesh Kumar U.S. & Sh. Manish Agarwal

disallowed and added back to its total income.” 4. Aggrieved by the assessment order dated 30.03.2017, Assessee preferred an Appeal before the ld. CIT(A). The ld. CIT(A) vide order dated 27.01.2024,allowed the appeal of the assessee.As against the order of the ld. CIT(A), Assessee preferred the present appeal. 5. The ld. DR submitted that

SMT. SAPNA GUPTA,HARIDWAR vs. THE PRINCIPAL COMMISSIONER OF INCOEM TAX, DEHRADUN

In the result, the appeal of the assessee is dismissed

Bench: Shri Saktijit Dey & Shri M. Balaganeshassessment Year: 2009-10 Smt. Sapna Gupta, Vs The Pr. Cit, 299, Awas Vikas Colony, Dehradun. Vivek Vihar, Haridwar – 249 407, Uttarakhand. Pan: Acspg4083D (Appellant) (Respondent) Assessee By : Shri Rohit Jain, Advocate & Ms Deepashri Rao, Ca Revenue By : Shri N.S. Jangpangi, Cit, Dr Date Of Hearing : 27.04.2023 Date Of Pronouncement : 08.06.2023 Order Per M. Balaganesh, Am: This Appeal In Ita No.16/Ddn/2021 For Ay 2009-10 Arises Out Of The Order Of The Pr. Commissioner Of Income Tax (Appeals), Dehradun, [Hereinafter Referred To As „Ld. Pcit‟, In Short] In Din & Order No. Itba/Rev/F/Rev5/2020- 21/1031815348(1) Dated 27.03.2021 Against The Order Of Assessment Passed U/S 148/147 R.W.S. 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As „The Act‟) Dated 26Th/28Th December, 2018 By The Ld. Assessing Officer, Ward 1(3)(3), Haridwar (Hereinafter Referred To As „Ld. Ao‟). 2. The Only Issue To Be Decided In This Appeal Is As To Whether The Ld. Pcit Was Justified In Invoking Revisionary Jurisdiction U/S 263 Of The Act In Respect Of Disallowance Of Purchases Of Rs 33,35,500/- In The Facts & Circumstances Of The Instant Case.

disallowance of alleged bogus purchases from M/s Meet Enterprises was, in any case, extensively examined during the course of original as well as reassessment proceedings and the same was, therefore, outside the scope of revisionary jurisdiction under section 263 of the Act. 2.3. That the PCIT failed to appreciate that the issue of „alleged bogus purchases made from M/s Meet

PSB PAPERS PRIVATE LIMITED,U.S. NAGAR vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX , BAREILLY

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

3) of the Act on 28.06.2018 determining the total income of the assessee at Rs.1,62,15,717/- after making disallowance on account of packing expenses in the sum of Rs.4,08,837/-. In the said assessment order, learned Assessing Officer had mentioned the fact that along with notice under section 142

M/S THDC INDIA LIMITED, RISHIKESH,RISHIKESH vs. PCIT, DEHRADUN, DEHRADUN

In the result, appeal of the assessee is partly allowed

142(1) alongwith\nquestionnaire were issued from time to time which were duly replied by\nthe assessee. After considering the submissions made alongwith\nrequisite documents and details filed by the assessee, total income of\nthe assessee stood assessed at INR 12,08,85,53,720/- vide order dated\n27.09.2022 passed u/s 143(3) r.w.s. 144B of the Act.\n3. Against

PURAN SINGH NEGI,HALDWANI vs. THE ASSIST COMMISSIONER OF INCOME TAX , NANITAL

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

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.I.T.A. No. 33/Ddn/2020 (A.Y 2016-17)

disallowing Rs 2,41,874, as the amount had not been received as Salary in advance, but was a lumpsum settlement for the future service, under a Voluntary Separation Scheme, to relieve all the permanent employees of the Company,( severing the employer employee relationship) approved by the Govt, of India 2.2 The Scheme was not voluntary, since there was included

SHRI VIBHU GROVER,KOTDWARA vs. PCIT, DEHRADUN

In the result appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalvibhu Grover, Pcit, M/S Grover Sales Corporation, Dehradun. Garage Road, Kotdwara, Vs. Pauri-246169 Pan:Agdpg5842R (Appellant) (Respondent) Assessee By Shri Anil Jain, Adv. Department By Shri S.K. Chaterjee, Cit-Dr

142(1) dated 14.03.2022 by the AO wherein again AO has asked to provide the details of the transactions carried with these three persons namely Sh. Manoj Kumar, Dayanand Parasar and Sh. Pawan Mishra during the previous year under appeal and never referred to any transaction with M/s Shri Ganpati Enterprises. He thus, submitted that AO has made proper

SAURAV MALIK,DEHRADUN vs. INCOME TAX OFFICER, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2017-18] Saurav Malik Vs Ito 100/2, Bell Road Clement Town 15A, Subhash Road, Near Hilton School, Dehradun Uttarakhand Uttarakhand-248002 Pan-Bdypm6527J Appellant Respondent Assessee By Shri Rajiv Sahini, Ca Revenue By Shri A.S. Rana, Sr. Dr Date Of Hearing 09.10.2025 Date Of Pronouncement 24.12.2025

142(1) alongwith questionnaire issued from time to time. In response, assessee furnished the required information/documents. Thereafter, AO passed the assessment order dated 05.11.2019 u/s 143(3) of the Act assessing total income of assessee at INR 90,89,685/- by holding the cash credited in his bank accounts as his undisclosed income u/s 69A of the Act. 3. Against

M/S. UTTARAKHAND PURV SAINIK KALYAN NIGAM LTD.,DEHRADUN vs. ITO, DEHRADUN

In the result, the appeal of the assessee is dismissed

Bench: Shri Anubhav Sharma & Shri Brajesh Kumar Singh[Assessment Year: 2013-14] M/S Uttrakhand Purv Ito,Ward-2(5), Sainik Kalyan Nigam Ltd. Aayakar Bhawan,13-A, Subhash (Upnl) Vs Road, Dehradun Uttrakhand- Station Sub Area, Garhi 248003 Cantt, Dehradun-248003 Pan-Aaacu7129D Assessee Revenue Assessee By Shri Tarandeep Singh, Adv. Revenue By Shri Amar Pal Singh, Sr. Dr Date Of Hearing 31.01.2025 Date Of Pronouncement 19.03.2025

3)/147 dated 25/02/2015 is merely 'change in opinion'. The action of the Ld. Assessing Officer u/s 148 of the Income Tax Act, 1961 was wholly unreasonable, uncalled for and bad in law. 5. That the levy of interest under section 234A/B/C and 234D is erroneous and deserves to be deleted. 6. That the intention of penalty proceedings

CHERRIE GEMS PRIVATE LIMITED ,ROORKEE vs. COMMISSIONER OF INCOME TAX(APPEALS), NFAC, DELHI

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

Bench: BEFORESHRI VIKAS AWASTHY (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)

disallowance of cash deposit of Rs 19,79,000 into bank during demonetization period since this amount has been deposited out of sale proceeds of jewelry and garments. 5. That on the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in the addition made by the Ld. AO solely on the basis

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

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

3-On facts and circumstances of the case and in law,\nwhether the CIT (A) is justified in deleting the addition of Rs.1,49,480/-\nmade by the AO on account of disallowance of the exempt agricultural\nincome claimed by the assessee without appreciating the fact that the\nAO has clearly held in the assessment order that the assessee

KEVIN INTERNATIONAL,HARIDWAR vs. DCIT, CIRCLE HARIDWAR, HARIDWAR

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Us(Through Video Conferencing) M/S. Kevin International, Vs. Dy. Cit, C/O. Balesh Bhargava-Adv, Circle, Haridwar 56, Niranajani Akhara, Mayapur, Haridwar (Appellant) (Respondent) Pan: Aajfk4514C

section 80IC of the I.T. Act 1961 and produced all the relevant documents in support of its claim. 4. That Ld. Authorities below are not justified in disallowing the claim of deprecation f Rs. 3,82,226/- on the fixed assets purchased during the year and also on fixed assets purchased in previous years and confirming the same and ignoring

ATUL KUMAR AGRAWAL,MANPUR ROAD, KASHIPUR vs. NATIONAL E-ASSESSMENT CENTRE, NEW DELHI

In the result, appeal of the assessee is partly allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year: 2018-19] Mr. Atul Kumar Agarwal Vs National Prop.M/S. R.K. Industries, E-Assessment Centre, Manpur Road, Kashipur, New Delhi U.S. Nagar, Uttarakhand- 244713 Pan-Aaopa9970H Appellant Respondent Assessee By Shri Deepak Joshi,Adv. & Shri Rudra Pratab, Adv. Revenue By Shri Amar Pal Singh, Sr.Dr Date Of Hearing 13.11.2025 Date Of Pronouncement 16.01.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 04.12.2024 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Nfac/2017-18/10235798 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 15.03.2023 Passed U/S 147 R.W.S. 144B Of The Act Pertaining To Assessment Year 2018-19. 2. Brief Facts Of The Case Are That Assessee Filed His Return Of Income On 15.08.2018, Declaring Total Income At Inr 5,81,560/-. The Case Of The Assessee Was Re-Opened U/S 147 Of The Act. Accordingly, Notice U/S 148 Was Issued On 30.03.2022, In Response To Which The Assessee Filed Return Of Income On 03.05.2022, Declaring Same Income As Was Declared In The Return Filed U/S 139(1) Of The Act. Thereafter Notice U/S 143(2) Of The Act Was Issued Followed By Notices U/S 142(1) Alongwith Questionnaires. In Response Filed Replies From Time To Time. After Considering The Submissions Made By The Assessee, Ao Completed The Assessment Vide Order Dated 15.03.2023 Passed U/S 147 R.W.S. 144B Of The Act Wherein The Total Income Was Assessed At Inr 54,23,320/-.

142(1) alongwith questionnaires. In response filed replies from time to time. After considering the submissions made by the assessee, AO completed the assessment vide order dated 15.03.2023 passed u/s 147 r.w.s. 144B of the Act wherein the total income was assessed at INR 54,23,320/-. 3. Against the said order, assessee filed an appeal before