AKHILESH SINGHAL,RISHIKESH vs. INCOME TAX OFFICER, RISHIKESH

In the result, appeal of the assessee is allowed

penalty levied u/s 271(1)(b) were deemed non-est and quashed.", "result": "Allowed", "sections": [ "271(1)(b)", "148", "147", "144

AKHILESH SINGHAL,RISHIKESH vs. INCOME TAX OFFICER, RISHIKESH

In the result, appeal of the assessee is allowed

u/s 148 and subsequent notices were not served on the assessee at the correct address or email ID. Consequently, the penalty levied for non-compliance was deleted.", "result": "Allowed", "sections": [ "271(1)(b)", "148", "147", "144

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]

144 r.w.s 144B of the Act and the remaining two appeals in ITA Nos. 78 & 79/DDN/2024 are filed by the assessee against 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

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 :

144 of the Paper Book filed before us. Ld.AR submits that re-opening done on the basis of borrowed satisfaction without in any manner making any inquiries or investigation thus, the proceedings initiated u/s 148 deserves to be ITA Nos.90, 95 & 104/DDN/2024 hold bad in law. For this, he placed reliance on the judgements of Hon’ble Delhi High Court

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 :

144 of the Paper Book filed before us. Ld.AR submits that re-opening done on the basis of borrowed satisfaction without in any manner making any inquiries or investigation thus, the proceedings initiated u/s 148 deserves to be ITA Nos.90, 95 & 104/DDN/2024 hold bad in law. For this, he placed reliance on the judgements of Hon’ble Delhi High Court

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 :

144 of the Paper Book filed before us. Ld.AR submits that re-opening done on the basis of borrowed satisfaction without in any manner making any inquiries or investigation thus, the proceedings initiated u/s 148 deserves to be ITA Nos.90, 95 & 104/DDN/2024 hold bad in law. For this, he placed reliance on the judgements of Hon’ble Delhi High Court

GUNJAN JAISWAL,HALDWANI vs. ITO, WARD-2(1)(1), HALDWANI

In the result, the Appeals of the Assessee are partly allowed for

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

144 and Section 144B of the Income Tax Act, 1961 ('Act' for short) by making an addition of Rs. 1,22,00,000/- u/s 69A of the Act. Consequent to the said assessment order, an order of penalty also came to be passed u/s 271

GUNJAN JAISWAL,HALDWANI vs. ITO, HALDWANI

In the result, the Appeals of the Assessee are partly allowed for

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

144 and Section 144B of the Income Tax Act, 1961 ('Act' for short) by making an addition of Rs. 1,22,00,000/- u/s 69A of the Act. Consequent to the said assessment order, an order of penalty also came to be passed u/s 271

AJAY PUNDIR,VILLAGE KIRSALI vs. COMMISSIONER OF INCOME TAX APPEALS, DELHI

In the result, the Appeals of the Appellant are partly allowed for

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

144 r.w. Section 1444B of the Income Tax Act, 1961 ('Act' for short) by making certain additions. Ajay Pundir Vs. CIT(A) Consequent to the assessment order an order of penalty also came to be passed on15/09/2022 u/s 271

AJAY PUNDIR,VILLAGE KIRSALI vs. COMMISSIONER OF INCOME TAX APPEALS, DELHI

In the result, the Appeals of the Appellant are partly allowed for

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

144 r.w. Section 1444B of the Income Tax Act, 1961 ('Act' for short) by making certain additions. Ajay Pundir Vs. CIT(A) Consequent to the assessment order an order of penalty also came to be passed on15/09/2022 u/s 271

JASPAL SINGH,DEHRADUN vs. ITO WARD1(1)(2) DEHRADUN, DEHRADUN

In the result, the Appeal of the Assessee in ITA No

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

144 r.w. Section 1444B of the Income Tax Act, 1961 ('Act' for short) by making certain additions. Jaspal Singh Vs. ITO Consequent to the assessment order an order of penalty also came to be passed on 26/08/2024 u/s 271

JASPAL SINGH,DEHRADUN vs. ITO WARD 1(1)(2), DEHRADUN

In the result, the Appeal of the Assessee in ITA No

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

144 r.w. Section 1444B of the Income Tax Act, 1961 ('Act' for short) by making certain additions. Jaspal Singh Vs. ITO Consequent to the assessment order an order of penalty also came to be passed on 26/08/2024 u/s 271

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

In the result, appeal of the assessee is partly allowed

144 (SC) CIT v. Birla Gwalior (P) Ltd. [1973]\n89 ITR 266 (SC) Morvi Industies Ltd. v. CIT [1971] 82 ITR 835 (SC) Poona\nElectric Supply Company Ltd. v. CIT [1965] 57 ITR 521 (SC) H.M. Kashiparekh\n& Co. Ltd. v. CIT [1960] 39 ITR 706 (Bombay) State Bank of Travencore v. CIT\n[1986] 24 Taxman 337/158

SHRI RAMESH BATTA,DEHRADUN vs. ACIT, DEHRADUN

In the result, appeal of the Assessee in both the cases are allowed and appeal filed by the Revenue in both the cases are dismissed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalacit, Shri Ramesh Batta Central Circle, 81/210, Kaulagarh Road, Vs. Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Shri Ramesh Batta Dy. Cit, 81/210, Kaulagarh Central Circle, Vs. Road, Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Acit, Shri Ramesh Batta, Central Circle, As Agent Of Smt. Kavita Vs. Dehradun. Ahuja, 81/210, Kaulagarh Road, Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent)

144-BA." 11. A plain reading of the aforesaid provision evinces an uncontrived position of law that the approval under Section 153D of the Act has to be granted for "each assessment year" referred to in clause (b) of sub-section (1) of Section 153A of the Act. It is beneficial to refer to the decision of the High Court

DCIT, DEHRADUN vs. SHRI RAMESH BATTA, DEHRADUN

In the result, appeal of the Assessee in both the cases are allowed and appeal filed by the Revenue in both the cases are dismissed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalacit, Shri Ramesh Batta Central Circle, 81/210, Kaulagarh Road, Vs. Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Shri Ramesh Batta Dy. Cit, 81/210, Kaulagarh Central Circle, Vs. Road, Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Acit, Shri Ramesh Batta, Central Circle, As Agent Of Smt. Kavita Vs. Dehradun. Ahuja, 81/210, Kaulagarh Road, Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent)

144-BA." 11. A plain reading of the aforesaid provision evinces an uncontrived position of law that the approval under Section 153D of the Act has to be granted for "each assessment year" referred to in clause (b) of sub-section (1) of Section 153A of the Act. It is beneficial to refer to the decision of the High Court

SHRI RAMESH BATTA,DEHRADUN vs. ACIT, DEHRADUN

In the result, appeal of the Assessee in both the cases are allowed and appeal filed by the Revenue in both the cases are dismissed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalacit, Shri Ramesh Batta Central Circle, 81/210, Kaulagarh Road, Vs. Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Shri Ramesh Batta Dy. Cit, 81/210, Kaulagarh Central Circle, Vs. Road, Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Acit, Shri Ramesh Batta, Central Circle, As Agent Of Smt. Kavita Vs. Dehradun. Ahuja, 81/210, Kaulagarh Road, Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent)

144-BA." 11. A plain reading of the aforesaid provision evinces an uncontrived position of law that the approval under Section 153D of the Act has to be granted for "each assessment year" referred to in clause (b) of sub-section (1) of Section 153A of the Act. It is beneficial to refer to the decision of the High Court

DCIT, DEHRADUN vs. SH. RAMESH BATTA AS AGENT OF SMT. KAVITA AHUJA, DEHRADUN

In the result, appeal of the Assessee in both the cases are allowed and appeal filed by the Revenue in both the cases are dismissed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalacit, Shri Ramesh Batta Central Circle, 81/210, Kaulagarh Road, Vs. Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Shri Ramesh Batta Dy. Cit, 81/210, Kaulagarh Central Circle, Vs. Road, Dehradun. Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent) Acit, Shri Ramesh Batta, Central Circle, As Agent Of Smt. Kavita Vs. Dehradun. Ahuja, 81/210, Kaulagarh Road, Rajendra Nagar, Dehradun-248001. Pan-Abgpb1527N (Appellant) (Respondent)

144-BA." 11. A plain reading of the aforesaid provision evinces an uncontrived position of law that the approval under Section 153D of the Act has to be granted for "each assessment year" referred to in clause (b) of sub-section (1) of Section 153A of the Act. It is beneficial to refer to the decision of the High Court

PANDITWARI SADHAN SAHKARI SAMITI LIMITED,DEHRADUN vs. INCOME TAX OFFICER, DEHRADUN

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

Bench: Shri M. Balaganesh & Shri Satbeer Singh Godara(Through Video Conferencing)

u/s 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 31.03.2022 by the Assessing Officer, ITO, Ward-1(1)(2), Dehradun (hereinafter referred to as ‘ld. AO’). 2. Identical issues are involved in all these appeals and hence they are taken up together and disposed of by this common order for the sake of convenience

PANDITWARI SADHAN SAHKARI SAMITI LIMITED,DEHRADUN vs. INCOME TAX OFFICER , DEHRADUN

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

Bench: Shri M. Balaganesh & Shri Satbeer Singh Godara(Through Video Conferencing)

u/s 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 31.03.2022 by the Assessing Officer, ITO, Ward-1(1)(2), Dehradun (hereinafter referred to as ‘ld. AO’). 2. Identical issues are involved in all these appeals and hence they are taken up together and disposed of by this common order for the sake of convenience