MOHAN PAL,HALDWANI, NAINITAL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HALDWANI, ACIT-DCIT, CENTRAL CIRCLE, HALDWANI

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

reassess all the six AYs' years immediately preceding the assessment correlatable to the search year or the "relevant assessment year" as defined in terms of Explanation 1 of Section 153A. The said approach is clearly unsustainable and contrary to the consistent line struck by the precedents noticed above. 6. The Hon’ble Jurisdictional Delhi High Court in the case

MOHAN PAL,HALDWANI, NAINITAL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HALDWANI, ACIT - DCIT, CENTRAL CIRCLE, HALDWANI

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

reassess all the six AYs' years immediately preceding the assessment correlatable to the search year or the "relevant assessment year" as defined in terms of Explanation 1 of Section 153A. The said approach is clearly unsustainable and contrary to the consistent line struck by the precedents noticed above. 6. The Hon’ble Jurisdictional Delhi High Court in the case

MOHAN PAL,HALDWANI, NAINITAL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HALDWANI, ACIT - DCIT, CENTRAL CIRCLE, HALDWANI

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

reassess all the six AYs' years immediately preceding the assessment correlatable to the search year or the "relevant assessment year" as defined in terms of Explanation 1 of Section 153A. The said approach is clearly unsustainable and contrary to the consistent line struck by the precedents noticed above. 6. The Hon’ble Jurisdictional Delhi High Court in the case

SHRI KRISHNA EDUCATIONAL TRUST,KURUKSHETRA vs. DCIT CENTRAL CIRCLE, DEHRADUN

In the result, all the appeals of the assessee are allowed

4) It is not open to the Revenue to advance an argument or file an appeal contrary to the circulars." 25. For all of the aforementioned reasons, the Court finds that the ITAT has correctly set out the legal position while holding that the requirement of prior approval of the superior officer before an order of assessment or reassessment

SHRI KRISHNA EDUCATIONAL TRUST,KURUKSHETRA vs. DCIT CENTRAL CIRCLE, DEHRADUN

In the result, all the appeals of the assessee are allowed

4) It is not open to the Revenue to advance an argument or file an appeal contrary to the circulars." 25. For all of the aforementioned reasons, the Court finds that the ITAT has correctly set out the legal position while holding that the requirement of prior approval of the superior officer before an order of assessment or reassessment

SHRI KRISHNA EDUCATIONAL TRUST,KURUKSHETRA vs. DCIT CENTRAL CIRCLE, DEHRADUN

In the result, all the appeals of the assessee are allowed

4) It is not open to the Revenue to advance an argument or file an appeal contrary to the circulars." 25. For all of the aforementioned reasons, the Court finds that the ITAT has correctly set out the legal position while holding that the requirement of prior approval of the superior officer before an order of assessment or reassessment

SHRI KRISHNA EDUCATIONAL TRUST,KURUKSHETRA vs. DCIT CENTRAL CIRCLE, DEHRADUN

In the result, all the appeals of the assessee are allowed

4) It is not open to the Revenue to advance an argument or file an appeal contrary to the circulars." 25. For all of the aforementioned reasons, the Court finds that the ITAT has correctly set out the legal position while holding that the requirement of prior approval of the superior officer before an order of assessment or reassessment

SHRI GANGA RAM ADWANI,RISHIKESH vs. DCIT, RISHIKESH

In the result the appeal filed by the assessee is allowed

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastavaasstt. Year 2008-09

132(4) stated that the Farm House land situated at Jwalapur, Haridwar was sold for total consideration of Rs. 2.06 8 Ganga Ram Adwani vs DCIT crores (including cash received from the purchasers over and above the amount mentioned in the registered deed dated 07.04.2007). From these facts, the AO held that it was evidently clear that the assessee

SSGR HOSPITAL AND RESEARCH CENTRE PRIVATE LIMITED,HALDWANI vs. DCIT/ACIT, CENTAL CIRCLE, HALDWANI, HALDWANI

In the result, appeals of the Assessee in ITA Nos

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

4. Brief facts of the case are that, a search and seizure operation u/s 132 of the Income Tax Act, 1961 ('Act' for short) was carried out at M/s SSGR Hospital and Research Centre Pvt. Ltd. "Group of cases", Haldwani and other premises on 04.01.2018. As per the A.O., certain Incriminating documents were found and seized during search and seizure

SSGR HOSPITAL & RESEARCH CENTRE PRIVATE LIMITED,HALDWANI vs. DC/ACIT, CENTRAL CIRLCE, HALDWANI

In the result, appeals of the Assessee in ITA Nos

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

4. Brief facts of the case are that, a search and seizure operation u/s 132 of the Income Tax Act, 1961 ('Act' for short) was carried out at M/s SSGR Hospital and Research Centre Pvt. Ltd. "Group of cases", Haldwani and other premises on 04.01.2018. As per the A.O., certain Incriminating documents were found and seized during search and seizure

SSGR HOSPITAL AND RESEARCH CENTRE PRIVATE LIMITED,HALDWANI vs. DCIT/ACIT, CENTRAL CIRCLE, HALDWANI, HALDWANI

In the result, appeals of the Assessee in ITA Nos

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

4. Brief facts of the case are that, a search and seizure operation u/s 132 of the Income Tax Act, 1961 ('Act' for short) was carried out at M/s SSGR Hospital and Research Centre Pvt. Ltd. "Group of cases", Haldwani and other premises on 04.01.2018. As per the A.O., certain Incriminating documents were found and seized during search and seizure

SSGR HOSPITAL AND RESEARCH CENTRE PRIVATE LIMITED,HALDWANI vs. DCIT/ACIT, CENTRAL CIRCLE, HALDWANI, HALDWANI

In the result, appeals of the Assessee in ITA Nos

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

4. Brief facts of the case are that, a search and seizure operation u/s 132 of the Income Tax Act, 1961 ('Act' for short) was carried out at M/s SSGR Hospital and Research Centre Pvt. Ltd. "Group of cases", Haldwani and other premises on 04.01.2018. As per the A.O., certain Incriminating documents were found and seized during search and seizure

SSGR HOSPITAL AND RESEARCH CENTRE PRIVATE LIMITED ,HALDWANI vs. DCIT/ACIT, CENTRAL CIRCLE,HALDWANI, HALDWANI

In the result, appeals of the Assessee in ITA Nos

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

4. Brief facts of the case are that, a search and seizure operation u/s 132 of the Income Tax Act, 1961 ('Act' for short) was carried out at M/s SSGR Hospital and Research Centre Pvt. Ltd. "Group of cases", Haldwani and other premises on 04.01.2018. As per the A.O., certain Incriminating documents were found and seized during search and seizure

SANJAY BANSAL,DEHRADUN vs. DCIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

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

132 of the Act took place in the business and residential premises of the assessee on 26.04.2012 and DBIT Group of cases. Consequently, notice u/s 153A(1)(a) of the Act was issued on 05.03.2013 and served upon the assessee. In response to the aforesaid notice, assessee furnished return of income on 31.03.2014 declaring total income at Rs.4

SANJAY BANSAL,NEW DELHI vs. DCIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

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

132 of the Act took place in the business and residential premises of the assessee on 26.04.2012 and DBIT Group of cases. Consequently, notice u/s 153A(1)(a) of the Act was issued on 05.03.2013 and served upon the assessee. In response to the aforesaid notice, assessee furnished return of income on 31.03.2014 declaring total income at Rs.4

SANJAY BANSAL,DEHRADUN vs. DCIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

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

132 of the Act took place in the business and residential premises of the assessee on 26.04.2012 and DBIT Group of cases. Consequently, notice u/s 153A(1)(a) of the Act was issued on 05.03.2013 and served upon the assessee. In response to the aforesaid notice, assessee furnished return of income on 31.03.2014 declaring total income at Rs.4

SANJAY BANSAL,DEHRADUN vs. DCIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

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

132 of the Act took place in the business and residential premises of the assessee on 26.04.2012 and DBIT Group of cases. Consequently, notice u/s 153A(1)(a) of the Act was issued on 05.03.2013 and served upon the assessee. In response to the aforesaid notice, assessee furnished return of income on 31.03.2014 declaring total income at Rs.4

SHRI SALIM ALI,DEHRADUN vs. ITO, DEHRADUN

In the result, appeals are partly allowed as indicated above

Bench: Shri Saktijit Dey, Vice- & Shri M. Balaganeshassessment Year: 2007-08 Salim Ali, Vill. Ajabpur Kalan, Versus Income-Tax Officer, Post Ajabpur, Dehradun. Ward 2(1), Dehradun. Pan:Bapba5312H (Appellant) (Respondent) Assessment Year: 2007-08 Azad Ali, Vill. Ajabpur Kalan, Versus Income-Tax Officer, Post Ajabpur, Dehradun. Ward 2(1), Dehradun. Pan:Azvpa8477F (Respondent) (Appellant) Assessment Year: 2007-08 Shahzad Ali, Vill. Ajabpur Kalan, Versus Income-Tax Officer, Post Ajabpur, Dehradun. Ward 2(1), Dehradun. Pan:Azopa9077A (Respondent) (Appellant) Assessees By : Sh. Saurabh Gupta, Ca & Sh. Rishabh Gupta, Ca Revenue By : Sh. A.S. Rana, Cit/Dr Date Of Hearing : 19.06.2023 Date Of Pronouncement: 23.06.2023

132 of the Act was conducted in case of R.B. Enterprises, a firm belonging to Shri Rakesh Batta group, on 04.03.2009. On examination of materials seized, it was found that M/s. R.B. Enterprises had purchased lands from certain persons through registered sale deeds dated 26.12.2006, 06.02.2007 and 12.03.2007 for a total consideration of Rs.52,43,720/-. From the information found