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 :

natural justice as no adequate opportunity of being heard and opportunity of cross- examining the persons upon whose statement the AO relied upon was provided to the assessee. 7. On the facts and circumstances of the case, Ld. CIT(A) has erred both in law as well as on facts in affirming the order of the AO ITA Nos.90

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 :

natural justice as no adequate opportunity of being heard and opportunity of cross- examining the persons upon whose statement the AO relied upon was provided to the assessee. 7. On the facts and circumstances of the case, Ld. CIT(A) has erred both in law as well as on facts in affirming the order of the AO ITA Nos.90

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)

natural justice. 2. That having regard to facts & circumstances of the case, Ld. Pr. CIT has erred in law and on facts in holding as under:- That the assessee has not complied with the conditions enumerated • for claiming deduction u/s 54B of the I.T. Act. That the issue of said deduction has not been examined while • completing the reassessment u/s

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

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 is not sustainable on legal and factual grounds. 3. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action

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

natural justice. 2. That having regard to facts and circumstances of the case, Ld. Pr. CIT has erred in law and on facts in holding as under:- • That the assessee has not complied with the conditions enumerated for claiming deduction u/s 54B of the I.T. Act. • That the issue of said deduction has not been examined while completing

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

natural justice. 2. That having regard to facts and circumstances of the case, Ld. Pr. CIT has erred in law and on facts in holding as under:- • That the assessee has not complied with the conditions enumerated for claiming deduction u/s 54B of the I.T. Act. • That the issue of said deduction has not been examined while completing

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 was assessed at INR 20,88,840/-. 3. Against the said order, assessee filed appeal before Ld. CIT(A) who vide impugned order dated 28.11.2025, dismissed the appeal

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 was assessed at INR 9,14,880/-. 3. Against the said order, assessee filed appeal before Ld. CIT(A) who vide impugned order dated 15.01.2026, dismissed the appeal

KULDEEP GUPTA,DEHRADUN vs. DCIT, DEHRADUN

In the result, the appeal of the assessee is allowed

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2019-20] Kuldeep Gupta Vs Dcit 80/1, Saraswati Soni Marg, Central Circle Dehradun, Uttarakhand Dehradun Pan-Brgpg6310R Uttarakhand Appellant Respondent Appellant By Shri Gaurav Gupta Respondent By Ms. Poonam Sharma, Cit Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 17.11.2025 By Ld. Commissioner Of Income Tax (A), Noida [“Ld.Cit(A)”] In Appeal No.Cit(Appeals), Nodia-3/10047/2018-19 Passed 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 Property Alongwith His Brother, Shri Gaurav Gupta For Which Payments Of Inr 15 Lakhs Was Made Though Cheque & Inr 12.50 Lakhs Was Paid In Cash. Accordingly, Ao Passed The Reassessment Order Dated 06.03.2024 U/S 147 By Making Addition Of Inr 6.25 Lakhs Being Assessee’S Share Of 50% In The Cash Payment As Undisclosed Investment U/S 69B R.W.S. 115Bb Of The Act & The Total Income Was Assessed At Inr 9,74,850/-.

reassessment order dated 06.03.2024 u/s 147 by making addition of INR 6.25 Lakhs being assessee’s share of 50% in the cash payment as undisclosed investment u/s 69B r.w.s. 115BB of the Act and the total income was assessed at INR 9,74,850/-. 3. Against the said order, assessee filed appeal before Ld.CIT(A) who vide impugned order dated

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

In the result, appeal of the assessee is partly allowed

natural justice. Moreover, the AO has failed to consider the\nreply filed by the assessee in response to notice issued u/s 148A(b) of the\nAct. Hon'ble Rajsthan High Court in the case of R.K. Buildcreations (Pvt.)\nLtd. vs. ITO reported in [2024] 462 ITR 478 (Raj) has held as under:-\n“It is mandatory

ATUL KUMAR AGRAWAL,MANPUR ROAD, KASHIPUR vs. NATIONAL E-ASSESSMENT CENTRE, NEW DELHI

In the result, appeal of the assessee is partly allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year: 2018-19] Mr. Atul Kumar Agarwal Vs National Prop.M/S. R.K. Industries, E-Assessment Centre, Manpur Road, Kashipur, New Delhi U.S. Nagar, Uttarakhand- 244713 Pan-Aaopa9970H Appellant Respondent Assessee By Shri Deepak Joshi,Adv. & Shri Rudra Pratab, Adv. Revenue By Shri Amar Pal Singh, Sr.Dr Date Of Hearing 13.11.2025 Date Of Pronouncement 16.01.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 04.12.2024 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Nfac/2017-18/10235798 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 15.03.2023 Passed U/S 147 R.W.S. 144B Of The Act Pertaining To Assessment Year 2018-19. 2. Brief Facts Of The Case Are That Assessee Filed His Return Of Income On 15.08.2018, Declaring Total Income At Inr 5,81,560/-. The Case Of The Assessee Was Re-Opened U/S 147 Of The Act. Accordingly, Notice U/S 148 Was Issued On 30.03.2022, In Response To Which The Assessee Filed Return Of Income On 03.05.2022, Declaring Same Income As Was Declared In The Return Filed U/S 139(1) Of The Act. Thereafter Notice U/S 143(2) Of The Act Was Issued Followed By Notices U/S 142(1) Alongwith Questionnaires. In Response Filed Replies From Time To Time. After Considering The Submissions Made By The Assessee, Ao Completed The Assessment Vide Order Dated 15.03.2023 Passed U/S 147 R.W.S. 144B Of The Act Wherein The Total Income Was Assessed At Inr 54,23,320/-.

147 r.w.s. 144B of the Act wherein the total income was assessed at INR 54,23,320/-. 3. Against the said order, assessee filed an appeal before Ld. CIT(A) who vide order dated 04.12.2024, dismissed the appeal of the assessee. 4. Aggrieved by the order of Ld. CIT(A), assessee is in appeal before the Tribunal by taking following

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.

natural justice; and (b) first disposing off the legal objections by passing a separate speaking order, is illegal and bad in law. 2. That on the facts and circumstances of the case and in law, the PCIT erred in holding that the re-assessment order dated 28.12.2018, passed under section 147 r.w.s 143(3) of the Act is erroneous

AKHILESH SINGHAL,RISHIKESH vs. INCOME TAX OFFICER, RISHIKESH

In the result, appeal of the assessee is allowed

147 r.w.s. 144\nr.w.s 144B of the Act and the remaining two appeals in ITA Nos. 78\n& 79/DDN/2024 are filed by the assessee against penalty order,\nboth dated 07.09.2022 passed u/s 271(1)(b) of the Act for\n Assessment Years 2014-15 & 2015-16 respectively.\nPage | 1\n2. As these three appeals are having the issues which

AKHILESH SINGHAL,RISHIKESH vs. INCOME TAX OFFICER, RISHIKESH

In the result, appeal of the assessee is allowed

147 r.w.s. 144\nr.w.s 144B of the Act and the remaining two appeals in ITA Nos. 78\n& 79/DDN/2024 are filed by the assessee against penalty order,\nboth dated 07.09.2022 passed u/s 271(1)(b) of the Act for\n Assessment Years 2014-15 & 2015-16 respectively.\nPage | 1\nITA Nos.64, 78 & 79/DDN/2024\n2. As these three appeals are having

AKHILESH SINGHAL,RISHIKESH vs. INCOME TAX OFFICER, RISHIKESH

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode]

147 r.w.s. 144 r.w.s 144B of the Act and the remaining two appeals in ITA Nos. 78 & 79/DDN/2024 are filed by the assessee against penalty order, both dated 07.09.2022 passed u/s 271(1)(b) of the Act for Assessment Years 2014-15 & 2015-16 respectively. ITA Nos.64, 78 & 79/DDN/2024 2. As these three appeals are having the issues which

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]

147 taxmann.com 224 (SC) (Annexure-C). The grant of leave signifies that the issue is admitted for final adjudication, and the correctness of the Madras High Court judgment stands squarely under scrutiny. The order granting leave does not affirm the High Court's view, nor does it declare law. Once leave is granted, the High Court judgment loses finality

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]

147 taxmann.com 224 (SC) (Annexure-C). The grant of leave signifies that the issue is admitted for final adjudication, and the correctness of the Madras High Court judgment stands squarely under scrutiny. The order granting leave does not affirm the High Court's view, nor does it declare law. Once leave is granted, the High Court judgment loses finality

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]

147 taxmann.com 224 (SC) (Annexure-C). The grant of leave signifies that the issue is admitted for final adjudication, and the correctness of the Madras High Court judgment stands squarely under scrutiny. The order granting leave does not affirm the High Court's view, nor does it declare law. Once leave is granted, the High Court judgment loses finality

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]

147 taxmann.com 224 (SC) (Annexure-C). The grant of leave signifies that the issue is admitted for final adjudication, and the correctness of the Madras High Court judgment stands squarely under scrutiny. The order granting leave does not affirm the High Court's view, nor does it declare law. Once leave is granted, the High Court judgment loses finality