EKSHAD AHAMAD PATODI,U S NAGAR vs. ACIT(OSD), WARD-2(3)(5), KHATIMA

In the result, the Appeal filed by the assessee is allowed

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar Us

section 271(l)(c) is one such provision. With calamitous, albeit commercial, consequences, the provision is mandatory and brooks no trifling with or dilution. For a further precedential prop, we may refer to Rajesh Kumar v. CIT[74], in which the Apex Court has quoted with approval its earlier judgment in State of Orissa v. Dr. Binapani Dei[ 75]. According

DCIT, CENTRAL CIRCLE, DEHRADUN vs. SWARNGANGA CONSTRUCTION P.LTD, BHILWARA

In the result, both the appeals of the revenue are allowed for statistical purposes

Bench: Shri R.K. Panda & Shri V.P. Rao

section 144 and penalty order u/s. 271(1)(c) of the Act respectively for the assessment year 2012-13. 2. In the quantum appeal, the assessee raised following grounds : “1. On facts and circumstances of the case and in law, the Ld. CIT(A) erred in condoning the delay of more than 2 years merely on ground that the erstwhile

AKHILESH SINGHAL,RISHIKESH vs. INCOME TAX OFFICER, RISHIKESH

In the result, appeal of the assessee is allowed

section 148(1), it is mandatory that notice u/s\n148 should be served on the assessee. As observed above, in the\ninstant case, the AO despite of having information of the correct\naddress and correct email id had served the notice u/s 148 as well\nas subsequent notices on the incorrect address and further the\nemail ID which notice

ADIT, DEHRADUN vs. M/S. M.I. OVERSEAS LTD., NOIDA

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

271 (1) (c) and Section 271B of the act. As the learned assessing officer has merely initiated the penalty proceedings, these grounds of appeal are premature and therefore dismissed. 59. In the result, appeal filed by the assessee in ITA number 3072/del/2012 for assessment year 2009 – 10 is partly allowed. Assessment year 2010-11 60. Assessee, as well

ADIT (INTERNATIONAL TAXATION), DEHRADUN vs. M/S. M.I, OVERSEAS LTD., MUMBAI

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

271 (1) (c) and Section 271B of the act. As the learned assessing officer has merely initiated the penalty proceedings, these grounds of appeal are premature and therefore dismissed. 59. In the result, appeal filed by the assessee in ITA number 3072/del/2012 for assessment year 2009 – 10 is partly allowed. Assessment year 2010-11 60. Assessee, as well

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

271 (1) (c) and Section 271B of the act. As the learned assessing officer has merely initiated the penalty proceedings, these grounds of appeal are premature and therefore dismissed. 59. In the result, appeal filed by the assessee in ITA number 3072/del/2012 for assessment year 2009 – 10 is partly allowed. Assessment year 2010-11 60. Assessee, as well

ADIT (INTERNATIONAL TAXATION), DEHRADUN vs. M/S. M.I, OVERSEAS LTD., MUMBAI

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

271 (1) (c) and Section 271B of the act. As the learned assessing officer has merely initiated the penalty proceedings, these grounds of appeal are premature and therefore dismissed. 59. In the result, appeal filed by the assessee in ITA number 3072/del/2012 for assessment year 2009 – 10 is partly allowed. Assessment year 2010-11 60. Assessee, as well

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

271 (1) (c) and Section 271B of the act. As the learned assessing officer has merely initiated the penalty proceedings, these grounds of appeal are premature and therefore dismissed. 59. In the result, appeal filed by the assessee in ITA number 3072/del/2012 for assessment year 2009 – 10 is partly allowed. Assessment year 2010-11 60. Assessee, as well

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

271 (1) (c) and Section 271B of the act. As the learned assessing officer has merely initiated the penalty proceedings, these grounds of appeal are premature and therefore dismissed. 59. In the result, appeal filed by the assessee in ITA number 3072/del/2012 for assessment year 2009 – 10 is partly allowed. Assessment year 2010-11 60. Assessee, as well

MI OVERSEAS LTD.,NEW DELHI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

271 (1) (c) and Section 271B of the act. As the learned assessing officer has merely initiated the penalty proceedings, these grounds of appeal are premature and therefore dismissed. 59. In the result, appeal filed by the assessee in ITA number 3072/del/2012 for assessment year 2009 – 10 is partly allowed. Assessment year 2010-11 60. Assessee, as well

AKHILESH SINGHAL,RISHIKESH vs. INCOME TAX OFFICER, RISHIKESH

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode]

penalty order, both dated 07.09.2022 passed u/s 271(1)(b) of the Act for Assessment Years 2014-15 & 2015-16 respectively. ITA Nos.64, 78 & 79/DDN/2024 2. As these three appeals are having the issues which are inter- linked, inter-connected and this fact has been admitted by both the parties during the course of hearing before us, therefore, all three

AKHILESH SINGHAL,RISHIKESH vs. INCOME TAX OFFICER, RISHIKESH

In the result, appeal of the assessee is allowed

section 148(1), it is mandatory that notice u/s\n148 should be served on the assessee. As observed above, in the\ninstant case, the AO despite of having information of the correct\naddress and correct email id had served the notice u/s 148 as well\nas subsequent notices on the incorrect address and further the\nemail ID which notice

ITO, WARD- 2(5), DEHRADUN vs. UTTRAKHAND POORV SAINIK KALYAN NIGAM LTD., DEHRADUN

In the result, appeal of the Revenue is dismissed

Bench: Sh. Anil Chaturvedi & Sh. Challa Nagendra Prasad

271(1)(c) of the Act on the denial of claim of exemption u/s 10(26BBB) of the Act. We find that CIT(A) while deleting the penalty has given a finding that the claim of deduction was not on account of malafide intention to deliberately conceal its income or was a case of furnishing inaccurate particulars

ITO, WARD- 2(5), DEHRADUN vs. UTTRAKHAND POORV SAINIK KALYAN NIGAM LTD., DEHRADUN

In the result, appeal of the Revenue is dismissed

Bench: Sh. Anil Chaturvedi & Sh. Challa Nagendra Prasad

271(1)(c) of the Act on the denial of claim of exemption u/s 10(26BBB) of the Act. We find that CIT(A) while deleting the penalty has given a finding that the claim of deduction was not on account of malafide intention to deliberately conceal its income or was a case of furnishing inaccurate particulars

SMT. NIDHI YADAV,DEHRADUN vs. ITO- W-2(1)(4),, RUDRAPUR

In the result, the assessee’s appeal is allowed for statistical purposes

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraita No.115/Ddn/2024, A.Y. 2013-14 Ita No.117/Ddn/2024, A.Y. 2015-16 Nidhi Yadav, Vs. Income Tax Officer, B-801, Forest Residency, Ward 2(1)(4), Dehradun, Uttarakhand Income Tax Office, Pin Code: 248014 Rudrapur, Uttarakhand Pan: Acapy5157E (Respondent) Appellant By Sh. Mohit Dev, Ca Respondent By Sh. Amarpal Singh, Sr. Dr Date Of Hearing 06/05/2025 Date Of Pronouncement 31/07/2025 Order Per Avdhesh Kumar Mishra, Am Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

section 69A of the Act as under: “5.1 The assessee is maintained two bank accounts, viz. bank account no. 11272281273 with SBI & 1074010105062236 with PNB. It is gathered from the bank accounts of the assessee maintained with SBI and PNB that the total credits in these two bank accounts are at Rs. 12,55,235/-. Whereas, the assessee has declared

MRS. NIDHI YADAV,DEHRADUN vs. ITO, RUDRAPUR

In the result, the assessee’s appeal is allowed for statistical purposes

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraita No.115/Ddn/2024, A.Y. 2013-14 Ita No.117/Ddn/2024, A.Y. 2015-16 Nidhi Yadav, Vs. Income Tax Officer, B-801, Forest Residency, Ward 2(1)(4), Dehradun, Uttarakhand Income Tax Office, Pin Code: 248014 Rudrapur, Uttarakhand Pan: Acapy5157E (Respondent) Appellant By Sh. Mohit Dev, Ca Respondent By Sh. Amarpal Singh, Sr. Dr Date Of Hearing 06/05/2025 Date Of Pronouncement 31/07/2025 Order Per Avdhesh Kumar Mishra, Am Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

section 69A of the Act as under: “5.1 The assessee is maintained two bank accounts, viz. bank account no. 11272281273 with SBI & 1074010105062236 with PNB. It is gathered from the bank accounts of the assessee maintained with SBI and PNB that the total credits in these two bank accounts are at Rs. 12,55,235/-. Whereas, the assessee has declared

SH.SANJAY RAWAT,,DEHRADUN vs. ACIT, CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] Ita Nos.90, 95 & 104/Ddn/2024 [Assessment Years : 2015-16, 2013-14 & 2013-14] Sanjay Rawat Vs Acit 18S Ats Colony, Central Circle Sahastradhara Road, Dehradun, Dehradun, Uttarakhand-248001 Uttarakhand Pan-Ahopr5244E Appellant Respondent Assessee By Shri Ajay Wadhwa, Adv. Shri Shivam Garg, Adv. & Shri Raghav Sharma, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 11.02.2026 Order Per Manish Agarwal, Am :

271(1(c) of the Act for AY 2013-14 respectively. ITA Nos.90, 95 & 104/DDN/2024 2. At the time of hearing, it was stated that the issues involved in all the captioned appeals are common, interlinked and arising as a result of survey action thus, all these appeals have been heard together and adjudicated by this common order. First

SANJAY RAWAT,DEHRADUN vs. ACIT CENTRAL CRICLE, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] Ita Nos.90, 95 & 104/Ddn/2024 [Assessment Years : 2015-16, 2013-14 & 2013-14] Sanjay Rawat Vs Acit 18S Ats Colony, Central Circle Sahastradhara Road, Dehradun, Dehradun, Uttarakhand-248001 Uttarakhand Pan-Ahopr5244E Appellant Respondent Assessee By Shri Ajay Wadhwa, Adv. Shri Shivam Garg, Adv. & Shri Raghav Sharma, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 11.02.2026 Order Per Manish Agarwal, Am :

271(1(c) of the Act for AY 2013-14 respectively. ITA Nos.90, 95 & 104/DDN/2024 2. At the time of hearing, it was stated that the issues involved in all the captioned appeals are common, interlinked and arising as a result of survey action thus, all these appeals have been heard together and adjudicated by this common order. First

SANJAY RAWAT,DEHRADUN vs. ACIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] Ita Nos.90, 95 & 104/Ddn/2024 [Assessment Years : 2015-16, 2013-14 & 2013-14] Sanjay Rawat Vs Acit 18S Ats Colony, Central Circle Sahastradhara Road, Dehradun, Dehradun, Uttarakhand-248001 Uttarakhand Pan-Ahopr5244E Appellant Respondent Assessee By Shri Ajay Wadhwa, Adv. Shri Shivam Garg, Adv. & Shri Raghav Sharma, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 11.02.2026 Order Per Manish Agarwal, Am :

271(1(c) of the Act for AY 2013-14 respectively. ITA Nos.90, 95 & 104/DDN/2024 2. At the time of hearing, it was stated that the issues involved in all the captioned appeals are common, interlinked and arising as a result of survey action thus, all these appeals have been heard together and adjudicated by this common order. First