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

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

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

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

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

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

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

reassess the income in respect of any issue, which has escaped assessment, and such issue comes to his notice subsequently in the course of the proceedings under this section, notwithstanding that the reasons for such issue have not been included in the reasons recorded under sub-section (2) of section 148. Explanation 4.—For the removal of doubts

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

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

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

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. (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

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]

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

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 :

1,55,00,000/- made by the AO has failed to appreciate that statements/documents must be read in whole and not in piecemeal. 11. That appellant craves leave to add, alter, modify or to amend any ground of appeal before or at the time of hearing.” The Ground of appeal No.2 is not pressed hence, dismissed. 7. In respect

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 :

1,55,00,000/- made by the AO has failed to appreciate that statements/documents must be read in whole and not in piecemeal. 11. That appellant craves leave to add, alter, modify or to amend any ground of appeal before or at the time of hearing.” The Ground of appeal No.2 is not pressed hence, dismissed. 7. In respect

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 :

1,55,00,000/- made by the AO has failed to appreciate that statements/documents must be read in whole and not in piecemeal. 11. That appellant craves leave to add, alter, modify or to amend any ground of appeal before or at the time of hearing.” The Ground of appeal No.2 is not pressed hence, dismissed. 7. In respect

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