KULDEEP GUPTA,DEHRADUN vs. DCIT, DEHRADUN

In the result, the appeal of the assessee is allowed

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2019-20] Kuldeep Gupta Vs Dcit 80/1, Saraswati Soni Marg, Central Circle Dehradun, Uttarakhand Dehradun Pan-Brgpg6310R Uttarakhand Appellant Respondent Appellant By Shri Gaurav Gupta Respondent By Ms. Poonam Sharma, Cit Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 17.11.2025 By Ld. Commissioner Of Income Tax (A), Noida [“Ld.Cit(A)”] In Appeal No.Cit(Appeals), Nodia-3/10047/2018-19 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 06.03.2024 Passed U/S 147 Of The Act Pertaining To Assessment Year 2019-20. 2. Brief Facts Of The Case Are That Based On The Documents Found During The Course Of Search Carried Out In The Case Of Shri Krishna Sharma & Smt. Sheetal Sharma On 02.02.2022, Case Of The Assessee Was Re-Opened U/S 147 Of The Act, Since As Per Seized Documents Titled As Page 6 & 7 Of Annexure A-2, It Is Found That Assessee Has Purchased Property Alongwith His Brother, Shri Gaurav Gupta For Which Payments Of Inr 15 Lakhs Was Made Though Cheque & Inr 12.50 Lakhs Was Paid In Cash. Accordingly, Ao Passed The Reassessment Order Dated 06.03.2024 U/S 147 By Making Addition Of Inr 6.25 Lakhs Being Assessee’S Share Of 50% In The Cash Payment As Undisclosed Investment U/S 69B R.W.S. 115Bb Of The Act & The Total Income Was Assessed At Inr 9,74,850/-.

reassessment order dated 06.03.2024 u/s 147 by making addition of INR 6.25 Lakhs being assessee’s share of 50% in the cash payment as undisclosed investment u/s 69B r.w.s. 115BB of the Act and the total income was assessed at INR 9,74,850/-. 3. Against the said order, assessee filed appeal before Ld.CIT(A) who vide impugned order dated

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

natural justice. 2. That having regard to facts and circumstances of the case, Ld. Pr. CIT has erred in law and on facts in holding as under:- • That the assessee has not complied with the conditions enumerated for claiming deduction u/s 54B of the I.T. Act. • That the issue of said deduction has not been examined while completing

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

natural justice. 2. That having regard to facts and circumstances of the case, Ld. Pr. CIT has erred in law and on facts in holding as under:- • That the assessee has not complied with the conditions enumerated for claiming deduction u/s 54B of the I.T. Act. • That the issue of said deduction has not been examined while completing

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/-.

reassessment proceedings without providing any opportunity of cross examination of the witnesses/statements of the third party relied upon by the Ld. AO and thus violating the principle of natural justice

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 :

natural justice as no adequate opportunity of being heard and opportunity of cross- examining the persons upon whose statement the AO relied upon was provided to the assessee. 7. On the facts and circumstances of the case, Ld. CIT(A) has erred both in law as well as on facts in affirming the order of the AO ITA Nos.90

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 :

natural justice as no adequate opportunity of being heard and opportunity of cross- examining the persons upon whose statement the AO relied upon was provided to the assessee. 7. On the facts and circumstances of the case, Ld. CIT(A) has erred both in law as well as on facts in affirming the order of the AO ITA Nos.90

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 :

natural justice as no adequate opportunity of being heard and opportunity of cross- examining the persons upon whose statement the AO relied upon was provided to the assessee. 7. On the facts and circumstances of the case, Ld. CIT(A) has erred both in law as well as on facts in affirming the order of the AO ITA Nos.90

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)

natural justice. 2. That having regard to facts & circumstances of the case, Ld. Pr. CIT has erred in law and on facts in holding as under:- That the assessee has not complied with the conditions enumerated • for claiming deduction u/s 54B of the I.T. Act. That the issue of said deduction has not been examined while • completing the reassessment

SIME DARBY ENGINEERING SDNBHD,MALAYSIA vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION ) CIRCLE-1, DEHRADUN

In the result, appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Justice of India for constituting appropriate Bench to consider the issues which arises in those matters afresh. However, in the present proceedings, the Assessee has not cited or relied upon on the Judgment of Hon'ble High Court of Judicature at Bombay in the case of Shelf Drilling Ron Tappmeyer Ltd. (supra) on the other hand Assessee relied

NATIONAL OIL WELL VARCO PTE. LTD (FORMERLY KNOWN AS VARCO INTERNATIONAL PTE. LTD),MAHARASHTRA vs. THE DEPUTY DIRECTOR OF INCOME TAX CIRCLE-1( INTERNATIONAL TAXATION ), DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Justice of India for constituting appropriate Bench to consider the issues which arises in those matters afresh. However, in the present proceedings, the Assessee has not cited or relied upon on the Judgment of Hon'ble High Court of Judicature at Bombay in the case of Shelf Drilling Ron Tappmeyer Ltd. (supra) on the other hand Assessee relied

SIME DARBY ENGINEERING SDN BHD,DELHI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRCLE-1, DEHRADUN

In the result, appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Justice of India for constituting appropriate Bench to consider the issues which arises in those matters afresh. However, in the present proceedings, the Assessee has not cited or relied upon on the Judgment of Hon'ble High Court of Judicature at Bombay in the case of Shelf Drilling Ron Tappmeyer Ltd. (supra) on the other hand Assessee relied

NATIONAL OILWELL VARCO PTE. LTD.,MUMBAI vs. DCIT (INTERNATIONAL TAXATION), CI9RCLE-2, DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Justice of India for constituting appropriate Bench to consider the issues which arises in those matters afresh. However, in the present proceedings, the Assessee has not cited or relied upon on the Judgment of Hon'ble High Court of Judicature at Bombay in the case of Shelf Drilling Ron Tappmeyer Ltd. (supra) on the other hand Assessee relied

NATIONAL OILWELL VARCO PTE. LTD.,MUMBAI vs. DCIT (INTERNATIONAL TAXATION), DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Justice of India for constituting appropriate Bench to consider the issues which arises in those matters afresh. However, in the present proceedings, the Assessee has not cited or relied upon on the Judgment of Hon'ble High Court of Judicature at Bombay in the case of Shelf Drilling Ron Tappmeyer Ltd. (supra) on the other hand Assessee relied

NATIONAL OILWELL VARCO PTE LTD.,MUMBAI vs. DCIT (INTERNATIONAL TAXATION), DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Justice of India for constituting appropriate Bench to consider the issues which arises in those matters afresh. However, in the present proceedings, the Assessee has not cited or relied upon on the Judgment of Hon'ble High Court of Judicature at Bombay in the case of Shelf Drilling Ron Tappmeyer Ltd. (supra) on the other hand Assessee relied

NATIONAL OILWELL VARCO PTE. LTD. (FORMERLY KNOWN AS VARCO INTERNATIONAL PTE LTD.),MUMBAI vs. DCIT (INTERNATIONAL TAXATION), CIRCLE-2, DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Justice of India for constituting appropriate Bench to consider the issues which arises in those matters afresh. However, in the present proceedings, the Assessee has not cited or relied upon on the Judgment of Hon'ble High Court of Judicature at Bombay in the case of Shelf Drilling Ron Tappmeyer Ltd. (supra) on the other hand Assessee relied

SIME DARBY ENGINEERING SDN BHD,GURGAON vs. DCIT (INTERNATIONAL TAXATION), CIRCLE-2, DEHRADUN

In the result, appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Justice of India for constituting appropriate Bench to consider the issues which arises in those matters afresh. However, in the present proceedings, the Assessee has not cited or relied upon on the Judgment of Hon'ble High Court of Judicature at Bombay in the case of Shelf Drilling Ron Tappmeyer Ltd. (supra) on the other hand Assessee relied

NAINITAL DISTRICT CO-OPERATIVE BANK,HALDWANI vs. DCIT, CIRCLE-1, HALDWANI

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

natural justice. 5. We have heard the Ld. DR and perused the materials available on record. The assessee is a regional rural bank and had filed its return of income for the A.Y. 2011- 12 on 30.09.2011 in the status of Co-Operative Society by declaring income of Rs. 7,05,06,267/-. The assessee filed a revised return

NAINITAL DISTRICT CO-OPERATIVE BANK,HALDWANI vs. ACIT, CIRCLE-1, HALDWANI

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

natural justice. 5. We have heard the Ld. DR and perused the materials available on record. The assessee is a regional rural bank and had filed its return of income for the A.Y. 2011- 12 on 30.09.2011 in the status of Co-Operative Society by declaring income of Rs. 7,05,06,267/-. The assessee filed a revised return