G & T RESOURCES (EUROPE) LTD.,NEW DELHI vs. ADIT, DEHRADUN

In the result, the appeal of the assessee is allowed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 5553/Del/2012 : Asstt. Year: 2004-05 G&T Resources (Europe) Ltd., Vs Adit, C/O F-04 & 05, Triveni Commercial International Taxation, Complex, Sheikh Sarai, Phase-I, Dehradun New Delhi-110017 (Appellant) (Respondent) Pan No. Aabcg9877F Assessee By : None Revenue By : Sh. T. S. Mapwal, Sr. Dr Date Of Hearing: 25.04.2022 Date Of Pronouncement: 29.04.2022 Order Per Dr. B. R. R. Kumar: The Present Appeal Has Been Filed By The Assessee Against The Order Passed By The Ao U/S 143(3) Of The Income Tax Act, 1961 Dated 23.11.2006. 2. The Assessee Has Raised Revised Grounds Of Appeal: “1. That, On The Facts & In The Circumstances Of The Case & In Law, The Learned Ao Has Erred On Facts & In Law In Initiating Proceedings Under Section 148 Read Together With Section 147 Of The Income 1Ax Act, 1961. 2. That In The Absence Of Any New Facts, Other Than The Ones Already On Record Based On Which The Assessment Order Was Passed, Initiating Proceedings Under Section 148 After Expiry Of Four Years Are Bad In Law & Void Abinitio. 3. That, The Learned Ao Having Considered The Facts, Applied The Spirit Of The Boards Instructions As Contained In Notification 1767 In A Speaking Assessment Order Erred In Initiating Proceedings Under Section 148 After The Expiry Of Four Years Merely Because In A Subsequent

139 or in response to a notice issued under sub-section (1) of section 142 or section 148 or to disclose 5 G & T Resources (Europe) Ltd. fully and truly all material facts necessary for his assessment, for that assessment year: Provided further that nothing contained in the first proviso shall apply in a case where any income in relation

ARJUN SINGH SAHI,DEHRADUN vs. DCIT/ACIT CEN CIR DDN, DEHRADUN

Appeal is allowed

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman(Through Video Conferencing) Assessment Year: 2017-18 Sh. Arjun Singh Sahi, Vs. Dcit/Acit, Aayakar Bhawan, Central Circle, 13A-Subhash Road, Dehradun Uttarakhand Pan :Axjps5225P (Appellant) (Respondent) Assessee By Sh. Mukesh Kudiyal, Adv. Department By Sh. A.S. Rana, Sr. Dr

139(5) of the Act on 08.09.2017. The Assessing Officer thereafter issued section 153A notice to him on 16.10.2018 which stood dropped on 05.07.2019. There is further no dispute that the Assessing Officer thereafter served him the impugned reopening notice under section 148 on 14.10.2019 which finally culminated in his reassessment

SHRI PRITPAL SINGH,DEHRADUN vs. THE ASSISTANT COMMISSIONER OF INCOME TAX , CIRCLE-2, DEHRADUN

In the result, the appeal of the Assessee is allowed

Bench: Sh. C. N. Prasad & Shri M. Balaganesh(Through Video Conferencing) Shri Pritpal Singh, Vs. Acit, 71, Guru Road, Circle-2, Dehradun Dehradun (Appellant) (Respondent) Pan: Ahkps3632F Assessee By : Shri Savyasachi Kumar Sahai, Adv Revenue By: Shri Amar Singh Rana, Sr. Dr Date Of Hearing 22/08/2023 Date Of Pronouncement 15/09/2023

139(5) of the Act expired on 31.03.2016, hence, the AO treated the manual revised return filed on 29.11.2016 as non est. Later in order to regularise the said revised return, a notice u/s 148 of the Act was issued by the ld AO on 02.12.2016. The Assessee submitted that the revised return filed on 29.11.2016 may be treated

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

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

139. Section 153D of the Act relevant for our purposes is to be noted "Prior approval necessary for assessment in cases of search or requisition. 153D.-No order of assessment or reassessment shall be passed by an Assessing Officer below the rank of Joint Commissioner in respect of each assessment year referred to in clause (b) of [sub-section

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

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

139. Section 153D of the Act relevant for our purposes is to be noted "Prior approval necessary for assessment in cases of search or requisition. 153D.-No order of assessment or reassessment shall be passed by an Assessing Officer below the rank of Joint Commissioner in respect of each assessment year referred to in clause (b) of [sub-section

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

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

139. Section 153D of the Act relevant for our purposes is to be noted "Prior approval necessary for assessment in cases of search or requisition. 153D.-No order of assessment or reassessment shall be passed by an Assessing Officer below the rank of Joint Commissioner in respect of each assessment year referred to in clause (b) of [sub-section

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

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

139. Section 153D of the Act relevant for our purposes is to be noted "Prior approval necessary for assessment in cases of search or requisition. 153D.-No order of assessment or reassessment shall be passed by an Assessing Officer below the rank of Joint Commissioner in respect of each assessment year referred to in clause (b) of [sub-section

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

section 147 of the IT Act, 1961. Necessary approval u/s 151(1) of the Act 1961 of the CIT, Dehradun for initiating proceedings u/s 147 has been received vide his office letter F. No. Pr.CIT/DDN/Sct.Appr./148/2014-15/2734 dated 26.03.2015.” 3.1. Thereafter notice u/s 148 was issued on 26th March 2015. The assessee in response to the said notice submitted that

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN vs. M/S. SHARDA EXPORTS, HARIDWAR

In the result, appeal of the Assessee in ITA No

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

139 or in response to a notice issued under sub-section (1) of section 142 or section 148 or to disclose fully and truly all material facts necessary for his assessment, for that assessment year:" 7. The Co-ordinate Bench of the Tribunal in Assessee’s own case for Assessment Year 2005-06 (supra), having similar set of facts

M/S. SHARDA EXPORTS,MEERUT vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the Assessee in ITA No

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

139 or in response to a notice issued under sub-section (1) of section 142 or section 148 or to disclose fully and truly all material facts necessary for his assessment, for that assessment year:" 7. The Co-ordinate Bench of the Tribunal in Assessee’s own case for Assessment Year 2005-06 (supra), having similar set of facts

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN vs. M/S. SHARDA EXPORTS, HARIDWAR

In the result, appeal of the Assessee in ITA No

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

139 or in response to a notice issued under sub-section (1) of section 142 or section 148 or to disclose fully and truly all material facts necessary for his assessment, for that assessment year:" 7. The Co-ordinate Bench of the Tribunal in Assessee’s own case for Assessment Year 2005-06 (supra), having similar set of facts

M/S. SHARDA EXPORTS,MEERUT vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE , DEHRADUN

In the result, appeal of the Assessee in ITA No

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

139 or in response to a notice issued under sub-section (1) of section 142 or section 148 or to disclose fully and truly all material facts necessary for his assessment, for that assessment year:" 7. The Co-ordinate Bench of the Tribunal in Assessee’s own case for Assessment Year 2005-06 (supra), having similar set of facts

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 :

139(1) of the Act, declaring total income of INR 2,96,090/- on 28.09.2015. A survey operation was conducted in the case of Shri Amit Sharma at 06, Shastri Nagar, Haridwar Road, Rishikesh and M/s. Shiva Electricals , Prop. Shri Amit Sharma, 3-New Friend Colony, Bye Pass Road, Dehradun and during the survey, certain loose papers were found

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 :

139(1) of the Act, declaring total income of INR 2,96,090/- on 28.09.2015. A survey operation was conducted in the case of Shri Amit Sharma at 06, Shastri Nagar, Haridwar Road, Rishikesh and M/s. Shiva Electricals , Prop. Shri Amit Sharma, 3-New Friend Colony, Bye Pass Road, Dehradun and during the survey, certain loose papers were found

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 :

139(1) of the Act, declaring total income of INR 2,96,090/- on 28.09.2015. A survey operation was conducted in the case of Shri Amit Sharma at 06, Shastri Nagar, Haridwar Road, Rishikesh and M/s. Shiva Electricals , Prop. Shri Amit Sharma, 3-New Friend Colony, Bye Pass Road, Dehradun and during the survey, certain loose papers were found

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/-.

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

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]

5. That in facts and circumstances of the case, the CIT(A) has not consider the submission and evidence filed before him is unfair and uncalled. 6. That in facts and circumstances of the case, the CIT(A) relied upon the earlier year receipt which was low stating AO has not substantiated with sufficient reason for huge increase in sale