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. (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 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

SIME DARBY ENGINEERING SDN BHD,GURGAON vs. DCIT (INTERNATIONAL TAXATION), CIRCLE-2, 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

SIME DARBY ENGINEERING SDNBHD,MALAYSIA 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

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

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

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

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the [Principal Commissioner or] Commissioner under sub-section (12) of section 144BA." The Tribunal while quashing the assessment order had relied upon its earlier decision in Navin Jain and Others (Supra) wherein a detailed discussion has been made with

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

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

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the [Principal Commissioner or] Commissioner under sub-section (12) of section 144BA." The Tribunal while quashing the assessment order had relied upon its earlier decision in Navin Jain and Others (Supra) wherein a detailed discussion has been made with

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

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

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the [Principal Commissioner or] Commissioner under sub-section (12) of section 144BA." The Tribunal while quashing the assessment order had relied upon its earlier decision in Navin Jain and Others (Supra) wherein a detailed discussion has been made with

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

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

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the [Principal Commissioner or] Commissioner under sub-section (12) of section 144BA." The Tribunal while quashing the assessment order had relied upon its earlier decision in Navin Jain and Others (Supra) wherein a detailed discussion has been made with

RAJU VERMA,DEHRADUN vs. DCIT, DEHRADUN

In the result, the appeal of the assessee is allowed

Bench: SHRI ANUBHAV SHARMA (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the [Principal Commissioner or Commissioner] under sub-section (12) of Section 144-BA." Raju Verma vs. DCIT 11. A plain reading of the aforesaid provision evinces an uncontrived position of law that the approval under Section 153D

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN, CROSS ROAD vs. RAJU VERMA, CURZON ROAD

In the result, the appeal of the assessee is allowed

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the [Principal Commissioner or Commissioner) under sub-section (12) of Section 144-BA." 11 A plain reading of the aforesaid provision evinces an uncontrived position of law that the approval under Section 153D

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN, CROSS ROAD vs. RAJU VERMA, CURZON ROAD, DALANWALA

In the result, the appeal of the assessee is allowed

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the [Principal Commissioner or Commissioner) under sub-section (12) of Section 144-BA." 11 A plain reading of the aforesaid provision evinces an uncontrived position of law that the approval under Section 153D

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

35,000 on account of alleged cash paid for the purchase of plot, without confronting the seized material and any corroborative material and not providing the same with the copies of the statements recorded and also failed to provide cross examination of the person whose statement is recorded inspite of repeated request made during the assessment. 6. The order

SMT. SAPNA GUPTA,HARIDWAR vs. THE PRINCIPAL COMMISSIONER OF INCOEM TAX, DEHRADUN

In the result, the appeal of the assessee is dismissed

Bench: Shri Saktijit Dey & Shri M. Balaganeshassessment Year: 2009-10 Smt. Sapna Gupta, Vs The Pr. Cit, 299, Awas Vikas Colony, Dehradun. Vivek Vihar, Haridwar – 249 407, Uttarakhand. Pan: Acspg4083D (Appellant) (Respondent) Assessee By : Shri Rohit Jain, Advocate & Ms Deepashri Rao, Ca Revenue By : Shri N.S. Jangpangi, Cit, Dr Date Of Hearing : 27.04.2023 Date Of Pronouncement : 08.06.2023 Order Per M. Balaganesh, Am: This Appeal In Ita No.16/Ddn/2021 For Ay 2009-10 Arises Out Of The Order Of The Pr. Commissioner Of Income Tax (Appeals), Dehradun, [Hereinafter Referred To As „Ld. Pcit‟, In Short] In Din & Order No. Itba/Rev/F/Rev5/2020- 21/1031815348(1) Dated 27.03.2021 Against The Order Of Assessment Passed U/S 148/147 R.W.S. 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As „The Act‟) Dated 26Th/28Th December, 2018 By The Ld. Assessing Officer, Ward 1(3)(3), Haridwar (Hereinafter Referred To As „Ld. Ao‟). 2. The Only Issue To Be Decided In This Appeal Is As To Whether The Ld. Pcit Was Justified In Invoking Revisionary Jurisdiction U/S 263 Of The Act In Respect Of Disallowance Of Purchases Of Rs 33,35,500/- In The Facts & Circumstances Of The Instant Case.

35,500/- in the facts and circumstances of the instant case. 3. The assessee has raised the following grounds of appeal before us :- “1. That on the facts and circumstances of the case and in law, the impugned order dated 27.03.2021 passed by the Principal Commissioner of Income-tax (PCIT), under section 263 of the Income

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

Bench: Shri Mahavir Singh & Shri Manish Agarwal

section 56(2) of the Act, the assessee should be taxed in the hands of the assessee as Income from other sources and which has escaped assessment. Accordingly, case was re-opened u/s 147 of the Act after obtaining approval from the competent authority and in terms of the reassessment order dated 02.09.2021, AO has made the addition towards

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

Bench: Shri Mahavir Singh & Shri Manish Agarwal

section 56(2) of the Act, the assessee should be taxed in the hands of the assessee as Income from other sources and which has escaped assessment. Accordingly, case was re-opened u/s 147 of the Act after obtaining approval from the competent authority and in terms of the reassessment order dated 02.09.2021, AO has made the addition towards

ABHISHEK AGARWAL,DEHRADUN vs. ITO, W01(1)(1), DEHRADUN

In the result, both the appeals filed by the assessee stands partly allowed for statistical purposes

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalita No.104/Ddn/2025 (Assessment Year 2015-16) Abhishek Agarwal, Income Tax Officer, Near Town Area Office, Ward-1(1)(1), Doiwala, Distt Dehradun, Vs. Dehradun. Uttarakhand-248140. Pan-Alzpa7733L (Appellant) (Respondent) Assessee By Shri Rajiv Sahni, Ca Department By Shri A.S. Rana, Sr. Dr Date Of Hearing 08/09/2025 Date Of Pronouncement 12/09/2025

1 Mah LJ 503 to grant condonation for a delay of 425 days. The operative part of the observations of the Hon'ble Bombay High Court are the real test for sound exercise of discretion by the High Court in this regard is not the physical running of time as such but the test is whether by the reason