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

250 of the Income Tax Act, 1961 [“the Act”] arising out of assessment orders, all dated 28.12.2019 passed u/s 143(3) r.w.s. 153C of the Act pertaining to Assessment Year 2013-14 to 2015-16 respectively. 2. Ld.AR for the assessee filed an application for admission of additional grounds of appeal and contended containing that these additional grounds of appeal

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

250 of the Income Tax Act, 1961 [“the Act”] arising out of assessment orders, all dated 28.12.2019 passed u/s 143(3) r.w.s. 153C of the Act pertaining to Assessment Year 2013-14 to 2015-16 respectively. 2. Ld.AR for the assessee filed an application for admission of additional grounds of appeal and contended containing that these additional grounds of appeal

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

250 of the Income Tax Act, 1961 [“the Act”] arising out of assessment orders, all dated 28.12.2019 passed u/s 143(3) r.w.s. 153C of the Act pertaining to Assessment Year 2013-14 to 2015-16 respectively. 2. Ld.AR for the assessee filed an application for admission of additional grounds of appeal and contended containing that these additional grounds of appeal

AJAY GARG,DEHRADUN vs. ACIT CENTRAL CIRCLE DEHRADUN, DEHRADUN

In the result, appeal of the assessee is partly allowed

sections": [ "147", "143(3)", "144B", "139(1)", "132(4)", "250", "148", "148A", "151", "133(6)", "269SS", "269T", "135A" ], "issues": "Whether the reassessment

RITU SINGHAL,DEHRADUN vs. DCIT/ACIT , CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

250 of the Income Tax Act, 1961 [“the Act"] arising from\nthe assessment order dated 25.01.2024 passed u/s 143(3) of the Act\npertaining to assessment year 2022-23.\n2. Brief facts of the case are that assessee is an individual, filed her\nreturn of income on 30.09.2022, declaring total income of INR\n49,61,640/-. Subsequently, a search

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.

250/- and in terms of CBDT Instruction No.1/2011, the jurisdiction lies with ACIT and not with ITO. However, notice u/s 143(2) was issued by ITO, Ward-1(2), Dehradun. Ld.AR also drew our attention to the fact that assessee since beginning of the proceedings challenged the validity of jurisdiction of the AO in terms of objections filed through online

AKHILESH SINGHAL,RISHIKESH vs. INCOME TAX OFFICER, RISHIKESH

In the result, appeal of the assessee is allowed

4)(1), Rishikesh\nScanned with OKEN Scanne\n14. From the perusal of the above, it is seen that AO has admitted\nthat all the notices including notice u/s 148 were sent at the\naddress i.e.139, Chandreshwar Nagar, Rishikesh, Uttarakhand-\n249201 and at the e-mail ID pandeymahesh600@gmail.com. From\nPage | 7\nITA Nos.64, 78 & 79/DDN/2024\nthe perusal of ITR filed

AKHILESH SINGHAL,RISHIKESH vs. INCOME TAX OFFICER, RISHIKESH

In the result, appeal of the assessee is allowed

4)(1), Rishikesh\nScanned with OKEN Scanne\n14.\nFrom the perusal of the above, it is seen that AO has admitted\nthat all the notices including notice u/s 148 were sent at the\naddress i.e.139, Chandreshwar Nagar, Rishikesh, Uttarakhand-\n249201 and at the e-mail ID pandeymahesh600@gmail.com. From\nPage | 7\nITA Nos.64, 78 & 79/DDN/2024\nthe perusal of ITR filed

ACHARYA BALKRISHNA,HARIDWAR vs. DCIT, DEHRADUN

In the result appeal of the assessee is allowed

Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

250 of the Income Tax Act, 1961 (“the Act”) for Assessment Year 2015-16. 2. Brief facts of the case are that assessee is a resident individual and filed his return of income on 17.03.2016 declaring total income of Rs.97,40,460/. The case of the assessee was reopened u/s 147 of the Act by issue of notice

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

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

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)

reassessment order was passed without complying with the mandatory conditions of 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

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

4 of 10 ITA No.2187/Del/2018 & Sanjay Kumar & Dariyav Singh vs. Pr.CIT Rs.35,08,250/- and consequently claimed deduction u/s 54B of the Act in view of the fact that the assessee had purchased another agricultural land for Rs.80 lacs. The nil capital gain reported by the assessee was accepted by the Ld. A.O. in the re-assessment and concluded

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

4 of 10 ITA No.2187/Del/2018 & Sanjay Kumar & Dariyav Singh vs. Pr.CIT Rs.35,08,250/- and consequently claimed deduction u/s 54B of the Act in view of the fact that the assessee had purchased another agricultural land for Rs.80 lacs. The nil capital gain reported by the assessee was accepted by the Ld. A.O. in the re-assessment and concluded

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 :

4. On the facts and circumstances of the case, Ld. CIT(A) has erred in affirming the jurisdiction of the AO under section 147 ignoring that the AO has not followed the mandatory provisions of section 147 to 151 (both inclusive) of the Income Tax Act, 1961. 5. On the facts and circumstances of the case, the assessment order

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 :

4. On the facts and circumstances of the case, Ld. CIT(A) has erred in affirming the jurisdiction of the AO under section 147 ignoring that the AO has not followed the mandatory provisions of section 147 to 151 (both inclusive) of the Income Tax Act, 1961. 5. On the facts and circumstances of the case, the assessment order

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 :

4. On the facts and circumstances of the case, Ld. CIT(A) has erred in affirming the jurisdiction of the AO under section 147 ignoring that the AO has not followed the mandatory provisions of section 147 to 151 (both inclusive) of the Income Tax Act, 1961. 5. On the facts and circumstances of the case, the assessment order

NAMITA AGRAWAL,UTTRAKHAND vs. DCIT, CENTRAL CIRCLE, DEHRADUN, INCOME TAX OFFICE ,DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2019-20] Namita Agrawal, Vs Dcit, 36/1, E C Road, Dehradun, Central Circle, Uttarakhand-248001 Dehradun Pan-Afspa0668P Appellant Respondent Assessee By Shri Anil Jain, Adv. & Shri Naman Jain, Adv. Revenue By Shri S.K.Chaterjee, Cit. Dr Date Of Hearing 09.07.2025 Date Of Pronouncement 09.07.2025 Order

250 of the Income Tax Act, 1961 [“the Act”] arising from the 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 the case of the assessee was re- opened based on the documents found and seized, during the course of search carried

BHOPAL SINGH CHAUDHARY,DEHRADUN vs. ITO SRINAGAR, SRINAGAR GARHWAL

Bench: Shri Mahavir Singh & Shri Manish Agarwal

250 of the Income Tax Act, 1961 [“the Act”] arising out of assessment order, both dated 02.09.2021 passed u/s 147 of the Act pertaining to Assessment Year 2017-18 and penalty u/s 270A of the Act respectively. 2. Since both the appeals are related to one assessee and against the additions made in reassessment order and consequent levy of penalty