ADIT (INTERNATIONAL TAXATION), DEHRADUN vs. M/S. M.I, OVERSEAS LTD., MUMBAI

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

147 as a substitute to section 143(2) of the Act and without having any valid „reason to believe‟ that income of the Appellant has escaped assessment. Taxability of revenues from offshore supply of imported material 2. The learned CIT(A) has erred in holding that revenues received by the Appellant from offshore supply of imported material amounting

MI OVERSEAS LTD.,NEW DELHI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

147 as a substitute to section 143(2) of the Act and without having any valid „reason to believe‟ that income of the Appellant has escaped assessment. Taxability of revenues from offshore supply of imported material 2. The learned CIT(A) has erred in holding that revenues received by the Appellant from offshore supply of imported material amounting

ADIT, DEHRADUN vs. M/S. M.I. OVERSEAS LTD., NOIDA

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

147 as a substitute to section 143(2) of the Act and without having any valid „reason to believe‟ that income of the Appellant has escaped assessment. Taxability of revenues from offshore supply of imported material 2. The learned CIT(A) has erred in holding that revenues received by the Appellant from offshore supply of imported material amounting

ADIT (INTERNATIONAL TAXATION), DEHRADUN vs. M/S. M.I, OVERSEAS LTD., MUMBAI

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

147 as a substitute to section 143(2) of the Act and without having any valid „reason to believe‟ that income of the Appellant has escaped assessment. Taxability of revenues from offshore supply of imported material 2. The learned CIT(A) has erred in holding that revenues received by the Appellant from offshore supply of imported material amounting

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

147 as a substitute to section 143(2) of the Act and without having any valid „reason to believe‟ that income of the Appellant has escaped assessment. Taxability of revenues from offshore supply of imported material 2. The learned CIT(A) has erred in holding that revenues received by the Appellant from offshore supply of imported material amounting

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.

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 and 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

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

147. If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may, subject to the provisions of sections 148 to 153, assess or reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course

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

Bench: Shri Mahavir Singh & Shri Manish Agarwal

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

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

Bench: Shri Mahavir Singh & Shri Manish Agarwal

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

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

income of the assessee. 6. Before the Ld. CIT(A) apart from challenging the addition on merit, the assessee also challenged the validity of reassessment proceedings. However, the Ld. CIT(A) was not satisfied with the arguments advanced by the assessee 9 Ganga Ram Adwani vs DCIT and upheld the validity of reassessment proceedings as well as the addition

METRO FROZEN FRUIT & VEGETABLES PVT. LTD.,ROORKEE vs. DCIT, CIRCLE, HARIDWAR

In the result, the appeal of the assessee is party allowed

Bench: Shri R.K. Panda & Shri N. K. Choudhry[Assessment Year: 2009-10] Metro Frozen Fruits & Dcit, Vegetables Pvt. Ltd. Circle Haridwar, Plot No.22, Rajpur, Vs Uttarakhan Bhagwanpur, Roorkee, Uttrakhand Pan-Aaecm4521F Assessee Revenue Assessee By Sh. Piyush Kuchhal, Fca Revenue By Ms. Poonam Sharma Cit-Dr Date Of Hearing 23.02.2022 Date Of Pronouncement 08.03.2022 Order Per R.K. Panda, Am, This Appeal Filed By The Assessee Is Directed Against The Order Dated 24.01.2019 Of The Learned Cit(A), Dehradun, Relating To Assessment Year 2009-10. 2. The Grounds Raised By The Assessee Are As Under:-

u/s 147 of the Act are illegal and liable to be quashed. 3 7. On the facts and circumstances of the case, the learned CIT(A) has erred, both on facts and in law, in ignoring the fact that the initiation of reassessment proceedings are bad in law as the same amounts to change of opinion of AO only

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 :

Income Tax Act, 1961. 5. On the facts and circumstances of the case, the assessment order as affirmed by the CIT(A) is illegal and void-ab-initio as the approval granted u/s 151 is illegal and mechanical in nature. 6. On the facts and circumstances of the case, Ld. CIT(A) has erred both in law as well

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 :

Income Tax Act, 1961. 5. On the facts and circumstances of the case, the assessment order as affirmed by the CIT(A) is illegal and void-ab-initio as the approval granted u/s 151 is illegal and mechanical in nature. 6. On the facts and circumstances of the case, Ld. CIT(A) has erred both in law as well

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 :

Income Tax Act, 1961. 5. On the facts and circumstances of the case, the assessment order as affirmed by the CIT(A) is illegal and void-ab-initio as the approval granted u/s 151 is illegal and mechanical in nature. 6. On the facts and circumstances of the case, Ld. CIT(A) has erred both in law as well

M/S PARASNATH FUELS (P) LTD.,DEHRADUN vs. DCIT, DEHRADUN

In the result, appeal of the assessee stands partly allowed for statistical purposes

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalparasnath Fuels Pvt. Ltd., The Dcit, Circle 1(1), 28 Feet Road, Dehradun Vikas Nagar, Vs Dehradun - 248198 Pan-Aaicp2190D Assessee Revenue Assessee By Dr. Rakesh Gupta, Adv., Shri Somil Agarwal, Adv. Revenue By Sh. Amar Pal Singh, Jcit Sr. Dr Date Of Hearing 11.09.2025 Date Of Pronouncement 28.11.2025 Order Per Manish Agarwal, Am, This Appeal Is Filed By The Assessee Against The Order Of The National Faceless Appellate Centre [Cit(A), In Short], Dated 08.10.2024 In Appeal No. Nfac/2016-17/10104734 Arising Out Of The Order Passed U/S 147 Of The Income Tax Act, 1961 (‘The Act’) Dt. 08.10.2024 For Assessment Year 2017-18. 2. The Assessee Has Raised Following Grounds Of Appeal: 1. That Having Regard To The Facts & Circumstances Of The Case, Assumption Of Jurisdiction In Initiating The Proceedings U/S 147 & Passing The Impugned Order U/S 147/144B & That Too Without Complying With Mandatory Conditions U/S 147 To 151A Parasnath Fuels Pvt.Ltd. Vs. Dcit

Income Tax Act, 1961, is bad in law and against the facts and circumstances of the case. 2. That in any case and in any view of the matter, assumption of jurisdiction u/s 147 and passing the impugned order u/s 147/144B, is illegal, bad in law and against the facts and circumstances of the case and the same

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)

additional grounds :- “1. That having regard to the facts and circumstances of the case, Ld. Pr. CIT. has erred in law and on facts in assuming jurisdiction u/s 263 which is bad in law inter alia for this reason that the reassessment order dated 21.03.2016 which is sought to be revised u/s 263 itself was invalid on various grounds

SWATI SHARMA,DEHRADNU vs. DCIT, C.C. DEHRADUN, DEHRADUN

In the result, the appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal[Assessment Year : 2019-20] Swati Sharma Vs Dcit H.No.-262, Sunderwala, Central Circle, Raipur, Dehradun Dehradun Uttarakhand -248001 Uttarakhand Pan-Dknps2561C Appellant Respondent Appellant By Shri Rajiv Sahni, Ca Respondent By Ms. Poonam Sharma, Cit Dr Date Of Hearing 11.03.2026 Date Of Pronouncement 08.04.2026 Order Per Bench: The Present Appeal Is Filed By Assessee Against The Order Dated 28.11.2025 Passed By Ld. Commissioner Of Income Tax (A)-3, Noida [“Ld. Cit(A)”] U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 22.03.2024 Passed U/S 147 Of The Act Pertaining To Assessment Year 2019-20. 2. Brief Facts Of The Case Are That Based On The Documents Found During The Course Of Search Carried Out In The Case Of Shri Krishna Sharma & Smt. Sheetal Sharma On 02.02.2022, Case Of The Assessee Was Re-Opened U/S 147 Of The Act, Since As Per Seized Documents Titled As Page 6 & 7 Of Annexure A-2, It Is Found That Assessee Has Purchased A Property For A Total Consideration Of Inr 47.00 Lacs & Payments Of Inr 32.00 Lacs Was Made Through Cheque & Inr 15.00 Lacs Was Paid In Cash. Accordingly, Ao Passed The Reassessment Order Dated 06.03.2024 U/S 147 By Making Addition Of Inr 15.00 Lacs Being Cash Payment As Undisclosed Investment U/S 69B R.W.S. 115Bb Of The Act & The Total Income Was Assessed At Inr 20,88,840/-.

reassessment order dated 06.03.2024 u/s 147 by making addition of INR 15.00 lacs being cash payment as undisclosed investment u/s 69B r.w.s. 115BB of the Act and the total income

RENUKA GROVER ,DEHRADUN vs. DCIT/ACIT, DEHRADUN

In the result, Appeal of the Assessee is allowed

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal[Assessment Year : 2019-20] Renuka Grover Vs Dcit/Acit 175, Block-Aa, Karanpur, Central Circle, Dehradun Dehradun Uttarakhand-248001 Uttarakhand Pan-Amvpg2702Q Appellant Respondent Appellant By Shri K.K. Juneja, Adv. Respondent By Shri Amar Pal, Singh, Sr. Dr Date Of Hearing 11.03.2026 Date Of Pronouncement 08.04.2026 Order Per Bench: The Present Appeal Is Filed By Assessee Against The Order Dated 15.01.2026 Passed By Ld. Commissioner Of Income Tax (A)-3, Noida [“Ld. Cit(A)”] U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of 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 Based On The Documents Found During The Course Of Search Carried Out In The Case Of Shri Krishna Sharma & Smt. Sheetal Sharma On 02.02.2022, Case Of The Assessee Was Re-Opened U/S 147 Of The Act, Since As Per Seized Documents Titled As Page 6 & 7 Of Annexure A-2, It Is Found That Assessee Has Purchased A Property For A Total Consideration Of Inr 26.00 Lacs & Payments Of Inr 20.00 Lacs Was Made Through Cheque & Inr 6.00 Lacs Was Paid In Cash. Accordingly, Ao Passed The Reassessment Order Dated 06.03.2024 U/S 147 By Making Addition Of Inr 6.00 Lacs Being Cash Payment As Undisclosed Investment U/S 69B R.W.S. 115Bb Of The Act & The Total Income Was Assessed At Inr 9,14,880/-.

reassessment order dated 06.03.2024 u/s 147 by making addition of INR 6.00 lacs being cash payment as undisclosed investment u/s 69B r.w.s. 115BB of the Act and the total income