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]

reassessment cannot be read into Section 144C more particularly when the provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the proceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels appearing for the respondent(s)/assessees that the outer time limit under Section

DCIT, CIRCLE- I, INTERNATIONAL TAXATION, DEHRADUN vs. EXPRESS DRILLING SYSTEMS LLC, DEHRADUN

In the result, cross objection filed by the assessee is partly

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshआ.अ.सं/.I.T.A No.6114/Del/2017 िनधा"रणवष"/Assessment Year: 2009-10 बनाम Dcit, Express Drilling Circle-1, Vs. Systems Llc, International Taxation, C/O Nangia & Co., 1St Floor, Ida, 46, Dehradun, Uttarakhand. E.C. Road, Dehradun, Uttarakhand. Pan No.Aabce6891R अपीलाथ" Appellant ""यथ"/Respondent & Cross Objection No. 13/Del/2018 (In I.T.A No.6114/Del/2017) िनधा"रणवष"/Assessment Year: 2009-10 बनाम Express Drilling Systems Llc, Dcit, Vs. C/O Nangia & Co., Circle-1, 1St Floor, Ida, 46, International Taxation, E.C. Road, Dehradun, Dehradun, Uttarakhand. Uttarakhand. Pan No. Aabce6891R अपीलाथ" Appellant ""यथ"/Respondent

reassessment order passed by the Assessing Officer with the prior approval of the Principal Commissioner or Commissioner as provided in sub-section (12) of section 144BA. (15) For the purposes of this section,— (a) "Dispute Resolution Panel" means a collegiums comprising of three Principal Commissioners or Commissioners of Income-tax constituted by the Board for this purpose; (b) "eligible assessee

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]

reassessment cannot be read into Section 144C more particularly when the provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the proceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels appearing for the respondent(s)/assessees that the outer time limit under Section

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]

reassessment cannot be read into Section 144C more particularly when the provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the proceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels appearing for the respondent(s)/assessees that the outer time limit under Section

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]

reassessment cannot be read into Section 144C more particularly when the provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the proceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels appearing for the respondent(s)/assessees that the outer time limit under Section

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]

reassessment cannot be read into Section 144C more particularly when the provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the proceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels appearing for the respondent(s)/assessees that the outer time limit under Section

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]

reassessment cannot be read into Section 144C more particularly when the provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the proceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels appearing for the respondent(s)/assessees that the outer time limit under Section

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

21 “Because on the facts and circumstances of the case and in law, the Ld. CIT(A) erred in upholding the validity of the proceedings under Section 153C, falling to appreciate that the Assessing Officer recorded a consolidated Satisfaction Note for multiple Assessment Years (AY 2011-1240 16) instead of recording satisfaction for each Assessment Year separately. Ground

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

21 “Because on the facts and circumstances of the case and in law, the Ld. CIT(A) erred in upholding the validity of the proceedings under Section 153C, falling to appreciate that the Assessing Officer recorded a consolidated Satisfaction Note for multiple Assessment Years (AY 2011-1240 16) instead of recording satisfaction for each Assessment Year separately. Ground

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

21 “Because on the facts and circumstances of the case and in law, the Ld. CIT(A) erred in upholding the validity of the proceedings under Section 153C, falling to appreciate that the Assessing Officer recorded a consolidated Satisfaction Note for multiple Assessment Years (AY 2011-1240 16) instead of recording satisfaction for each Assessment Year separately. Ground

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

21 to 22, we find that there is no mention of any firm named as M/s Shri Ganpati 5 IT No.110/DDN/2024 Shri Vibhu Grover vs. PCIT Enterprises with whom alleged transactions of Rs.6.00 lacs is stated to be made by the assessee of bogus accommodation entry. The AO in his wisdom made all the necessary enquiries with respect

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.

5. Heard both the parties and perused the materials available on record. At the outset, the claim of the AR of the assessee was that the case of the assessee was reopened after passing order u/s 148A(d) of the Act dated 26.03.2022 wherein it was held that assessee had deposited cash in the bank account of Ashok Kumar

SHRI SHAHAZAD 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

5 | P a g e ITA No. 1570, 1572 & 1574/Del/2015 No.2430/Del/2015 order dated 20.05.2016 by returning following findings :- “7. On having gone through the decisions cited above especially the decision of Amritsar Bench in the case of ITO vs. Arun Kumar Kapoor (supra), we find that in that case as in the present case before us, reassessment was initiated

SHRI AZAD 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

5 | P a g e ITA No. 1570, 1572 & 1574/Del/2015 No.2430/Del/2015 order dated 20.05.2016 by returning following findings :- “7. On having gone through the decisions cited above especially the decision of Amritsar Bench in the case of ITO vs. Arun Kumar Kapoor (supra), we find that in that case as in the present case before us, reassessment was initiated

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

5 | P a g e ITA No. 1570, 1572 & 1574/Del/2015 No.2430/Del/2015 order dated 20.05.2016 by returning following findings :- “7. On having gone through the decisions cited above especially the decision of Amritsar Bench in the case of ITO vs. Arun Kumar Kapoor (supra), we find that in that case as in the present case before us, reassessment was initiated

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)

21-03-2016 was not maintainable and an invalid re-assessment cannot be set aside u/s 263 of the Act. 4. That the appellant craves the leave to add, amend, modify, delete any of the grounds of appeal before or at the time of hearing and all the above grounds are without prejudice to each other. 3. The assessee

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

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

21 cases for various assessment years on a single day is the subject matter of dispute before us. Further, section 153D of the Act provides that approval has to be granted for each of the assessment year whereas, in the instant case, the Ld. Addl.CIT has granted a single approval for all assessment years put together. We find that

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

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

21 cases for various assessment years on a single day is the subject matter of dispute before us. Further, section 153D of the Act provides that approval has to be granted for each of the assessment year whereas, in the instant case, the Ld. Addl.CIT has granted a single approval for all assessment years put together. We find that