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]

2) of section 260A. (4) Where the order of 29[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the order of the Appellate Tribunal, as the case may be, referred to in sub-section (1) is not in conformity with the final decision on the question of law in the other case, as and when such order is received

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]

31. In view of the split verdict, Larger Bench reference, interim restraint on citation, grant of leave in Roca Bathroom, and absence of any binding jurisdictional precedent, the Revenue respectfully submits that deferral of adjudication on the limitation issue is the most appropriate course. The Revenue reiterates its reservation to address all other issues on merits separately at the appropriate

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]

31. In view of the split verdict, Larger Bench reference, interim restraint on citation, grant of leave in Roca Bathroom, and absence of any binding jurisdictional precedent, the Revenue respectfully submits that deferral of adjudication on the limitation issue is the most appropriate course. The Revenue reiterates its reservation to address all other issues on merits separately at the appropriate

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]

31. In view of the split verdict, Larger Bench reference, interim restraint on citation, grant of leave in Roca Bathroom, and absence of any binding jurisdictional precedent, the Revenue respectfully submits that deferral of adjudication on the limitation issue is the most appropriate course. The Revenue reiterates its reservation to address all other issues on merits separately at the appropriate

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]

31. In view of the split verdict, Larger Bench reference, interim restraint on citation, grant of leave in Roca Bathroom, and absence of any binding jurisdictional precedent, the Revenue respectfully submits that deferral of adjudication on the limitation issue is the most appropriate course. The Revenue reiterates its reservation to address all other issues on merits separately at the appropriate

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]

31. In view of the split verdict, Larger Bench reference, interim restraint on citation, grant of leave in Roca Bathroom, and absence of any binding jurisdictional precedent, the Revenue respectfully submits that deferral of adjudication on the limitation issue is the most appropriate course. The Revenue reiterates its reservation to address all other issues on merits separately at the appropriate

BR ASSOCIATES ,UTTARAKAHAND vs. ACIT , RISHIKESH

In the result, the appeal of the assessee is allowed and the assessment order is quashed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2016-17] M/S. B R Associates Vs Acit Jolly Grant, Circle-1(4)(1) Bhaniyawala, Dehradun, Rishikesh, Uttarakhand-248140 Uttarakhand-249201 Pan-Aaqfb6241E Appellant Respondent Assessee By Shri Kanwal K.Juneja, Ca Revenue By Shri A.S.Rana, Sr.Dr Date Of Hearing 10.12.2025 Date Of Pronouncement 18.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 08.07.2025 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Cit(A), Dehradun/10296/2018-19 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 28.12.2018 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2016-17. 2. Brief Facts Of The Case Are That The Assessee Is An Individual & Filed Its Return Of Income On 08.10.2016 Declaring Total Income At Inr 46,02,250/-. The Case Was Selected For Scrutiny Under Cass & The Notice Was Issued By Ito, Ward-1(2), Dehradun Thereafter, The Case Was Transferred To Dcit, Circle-1(1)(1), Dehradun. Thereafter, Various Notices Were Issued & Replies Were Filed By The Assessee. After Considering The Submissions, Total Income Was Assessed At Inr 1,93,96,755/- By Making Addition Of Inr 55.00 Lakhs Towards Bogus Advances & Inr 14,13,600/- As Deemed Income & Further Disallowance Of Expenses Of Inr 78,80,905/- Was Made.

31-1-2011 References have been received by the Board from a large number of taxpayers, especially from mofussil areas, that the existing monetary limits for assigning cases to ITOs and DCs/ACs is causing hardship to the taxpayers, as it results in transfer of their cases to a DC/AC who is located in a different station, which increases their cost

BABU LAL PATWARI ,UTTARAKHAND vs. DCIT CIRCLE-2(1)(), UTTARAKHAND

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

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

2) of Before expiry of four Joint the old regime years from the end of the Commissioner relevant assessment year Section 151(1) of After expiry of four years from Principal Chief Commissioner or the old regime the end of the relevant Chief Commissioner or Principal assessment years Commissioner or Commissioner Section 151(i) of the Three years or less

SH. ASHOK KUMAR,HARIDWAR vs. ITO, HARIDWAR

In the result, the appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalashok Kumar, Assessment Unit, 19, Sitapur Mazara, Jwalapur, Income Tax Haridwar, Uttarakhand-249407 Vs. Department. Pan-Btupk9604E (Appellant) (Respondent) Assessee By Shri Pankaj Goel, Adv. Department By Shri A. S. Rana, Sr. Dr Date Of Hearing 08/09/2025 Date Of Pronouncement 17/09/2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (‘The Ld. Cit(A)’ For Short) In Appeal No. Nfac/2014-15/10271519 Dated 10.04.2025 For Assessment Year 2015-16. 2. Brief Facts Of The Case Are That The Assessee Is An Agriculturist Having No Any Other Source Of Income Than Agricultural Income. Since, The Income From Agricultural Operations Is Exempt From Tax, He Was Not Obliged To File The Return Of Income. The Assessing Officer Based On The Information That Assessee Has Deposited A Sum Of Rs.76,00,000/- In Zila Sahkari Bank Ltd., Initiated Reassessment Proceedings In The Case Of Assessee By Recording Reasons That Income To The Extent Of Rs.76,00,000/- Has Escaped Assessment In The Order Passed U/S 148A(D) Of The Act. Accordingly, Notices U/S 148 Was Issued On 26.03.2022. In Response To Which Assessee Filed Return Of Income On 12.04.2022 Ashok Kumar Vs. Ito Declaring Total Income Of Rs.10,00,000/- From Agriculture Activity & Claimed The Same As Exempt From Tax. The Assessing Officer Passed The Reassessment Order Wherein He Has Made The Additions On Account Of Agriculture Income Of Rs.10,00,000/- By Treating The Same As Income From Other Sources & Further Made Additions Of Rs.76,00,000/- Being Cash Deposited During Demonetization As Unexplained Money U/S 69A Of The Act. The Ao Further Made Additions Of Rs.2,67,195/- As Against Nil Income Declared Towards Bank Interest.

2) of section 148 mandates reasons for issuance of notice by the Assessing Officer and sub-section (1) thereof mandates service of notice to the assessee before the Assessing Officer proceeds to assess, reassess or recompute escaped income. Section 147 mandates recording of reasons to believe by the Assessing Officer that the income chargeable to tax has escaped assessment

SHRI VIBHU GROVER,KOTDWARA vs. PCIT, DEHRADUN

In the result appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalvibhu Grover, Pcit, M/S Grover Sales Corporation, Dehradun. Garage Road, Kotdwara, Vs. Pauri-246169 Pan:Agdpg5842R (Appellant) (Respondent) Assessee By Shri Anil Jain, Adv. Department By Shri S.K. Chaterjee, Cit-Dr

2 to Section 263 of the Act, brought in place by the Finance Act, 2015. The said amendment markedly specifies various conditions to exercise the authority vested in the Commissioner under Section 263 of the Act, leaving no ambiguity in the interpretation of the said provision. 31. In view of the aforesaid, the appeal preferred by the Revenue is dismissed

INCOME TAX OFFICER, WARD-1(1)(3), DEHRADUN, AAYKAR BHAWAN, SUBHASH ROAD, DEHRADUN vs. UTTARAKHAND PURV SAINIK KALYAN NIGAM LIMITED, STATION SUB AREA

In the result, appeal of the assessee is allowed

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

31, 2007. The appellant originally did not file its return of income for the AY 2015-16 within the due date u/s 139(1). Thereafter, a notice u/s 148 of the I.T Act, 1961 dated 29.08.2016 was issued to the appellant as it was noticed by the AO that the appellant in the earlier years was claiming exemption

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)

section 147 to 151 of Income Tax Act, 1961. 2. That in any case and in any view of the matter, Ld. Pr. CIT has erred in law in assuming jurisdiction and passing the impugned order u/s 263, is bad in law and against the facts and circumstances of the case. Since the above grounds are purely legal and does

M/S. R.B. ENTERPRISES,DEHRADUN vs. DCIT, DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra(Through Video Conferencing)

section 147 of Income Tax Act, 1961 (Negi) Dy. Commissioner of Income Tax Central Circle, Dehra Dun 3.4 Adjudication of the grounds of appeal requires perusal of bare facts, which are as follows: 4 | P a g e ITA Nos.3500 & 3501/Del/2017 and i. The appellant is a registered partnership firm, engaged in the business of development, purchase and sale

DCIT, CENTRAL CIRCLE, DEHRADUN vs. R.B. ENTERPRISES, DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra(Through Video Conferencing)

section 147 of Income Tax Act, 1961 (Negi) Dy. Commissioner of Income Tax Central Circle, Dehra Dun 3.4 Adjudication of the grounds of appeal requires perusal of bare facts, which are as follows: 4 | P a g e ITA Nos.3500 & 3501/Del/2017 and i. The appellant is a registered partnership firm, engaged in the business of development, purchase and sale

M/S. R.B. ENTERPRISES,DEHRADUN vs. DCIT, DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra(Through Video Conferencing)

section 147 of Income Tax Act, 1961 (Negi) Dy. Commissioner of Income Tax Central Circle, Dehra Dun 3.4 Adjudication of the grounds of appeal requires perusal of bare facts, which are as follows: 4 | P a g e ITA Nos.3500 & 3501/Del/2017 and i. The appellant is a registered partnership firm, engaged in the business of development, purchase and sale

SWAMI DARSHANAND INSTITUTE OF MANAGEMENT AND TECHNOLOGY,HARIDWAR vs. ITO, W-1(3)(1), HARIDWAR

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalswami Darshanand Institute Of Income Tax Officer, Management & Technology, Ward-1(3)(1), Gurukul Mahavidyalaya, Vs. Haridwar. P.O. Gurukul Kangi, Jwalpur, Haridwar-249407. Pan:Aalas6789G (Appellant) (Respondent) Assessee By Shri Shalil Agarwal, Sr. Adv. & Shri Salies Gupta, Adv. & Shri Uma Shankar, Adv. Department By Shri Amar Pal Singh, Jcit-Dr Date Of Hearing 11.09.2025 Date Of Pronouncement 05.12.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (‘The Cit(A) In Short) Passed U/S 250 Of The Income Tax Act, 1961, Dated 19.05.2025 For Assessment Year 2015-16. 2. Brief Facts Of The Case Are That The Assessee Is A Society Engaged In Imparting Education. The Ao Based On The Information That Assessee Has Deposited Cash Of Rs.93,10,000/- In The Saving Bank Account Maintained With A Central Bank Of India Which Is Not Declared & Thus Case Was Reopened By Issue Of Notice U/S 148 Of The Act. Thereafter, Submissions Were Made By The Assessee Wherein It Is Claimed That This Account Pertained To Other Society & All The Deposits Are Duly

2. That the learned Commissioner of Income Tax (Appeals) has further erred both in law and on facts in upholding the initiation of proceedings under section 147 of the Act, in as much as, the instant reassessment proceedings were without satisfying the statutory pre-conditions as envisaged under the Act. 2.1 That the learned Commissioner of Income Tax (Appeals