NEERAJ SINGHAL,DEHRADUN vs. DCIT ACIT CEN CIR , DDN , DEHRADUN

In the result, the appeal of the assessee is allowed

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh(Through Video Conferencing) Neeraj Singhal, Vs. Dcit/Acit, Haripur, Kalsi, Dehradun, Central Circle, Uttarakhand Dehradun (Appellant) (Respondent) Pan: Apzps7059D Assessee By : Shri Harshit Gupta, Ca Revenue By: Shri S. K. Chaterjee, Cit Dr Date Of Hearing 19/03/2025 Date Of Pronouncement 09/04/2025

disallowed u/s 40A(3) of the Act by drawing a presumption that the loose sheet represents payments made by the assessee. But ultimately the addition was made u/s 69C of the Act without providing any opportunity of being heard to the assessee to explain as to why section

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/-.

section 69C without disputing the corresponding sale transactions which are borne out of the very same purchases. 11. In the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in confirming action of the Ld. AO in levying interest u/s 234A/B/C/D of the Act. 12. In the facts and circumstances of the case

M/S. NANAK CHAND ASSOCIATES,NEW DELHI vs. ITO, NEW DELHI

In the result appeal of the assessee is partly allowed

Bench: SHRI ANUBHAV SHARMA (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

69C of the Act in the hands of the assessee. As no explanation was tendered by the assessee thus the AO has made the addition of Rs. 30.00 lacs by treating the same as unexplained expenditure. Before ld. CIT(A) assessee claimed that these amounts were given by Shri Madan Lal who was financer of the partners of the assessee

DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE), DEHRADUN, DEHRADUN vs. STONEFIELD CONSTRUCTION, DEHRADUN, DEHRADUN

In the result, appeal of the Revenue is partly allowed

69C by alleging purchases from Two parties as bogus amounting to INR 33,24,865/-; (b) Disallowance u/s 40a(ia) of INR 16,18,500/-; (c) Disallowance u/s 40A(3) of the Act INR 30,000/- 3. Besides this, AO treated the income declared in the return of income filed at INR 3.89 crores on account of difference in survey