SOCIETY FOR ADVANCEMENT IN EDUCATION,MUSSOORIE vs. ITO EXEMPTION WORD DEHRADUN, DEHRADUN

In the result, appeals of the assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

u/s. 147, was clearly unsustainable-On such consideration, both Appellate authorities interfered into matter- o error was committed warranting reconsideration-As far as explanation to S. 151, brought into force by Finance Act, 2008 was concerned, same only pertained to issuance of notice and not with regard to manner of recording satisfaction- Amended provision did not help Revenue-No question

SOCIETY FOR ADVANCEMENT IN EDUCATION,MUSSOORIE vs. ITO EXEMPTION DEHRADUN, DEHRADUN

In the result, appeals of the assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

u/s. 147, was clearly unsustainable-On such consideration, both Appellate authorities interfered into matter- o error was committed warranting reconsideration-As far as explanation to S. 151, brought into force by Finance Act, 2008 was concerned, same only pertained to issuance of notice and not with regard to manner of recording satisfaction- Amended provision did not help Revenue-No question

SOCIETY FOR ADVANCEMENT IN EDUCATION,MUSSOORIE vs. ITO EXEMPTION WORD DEHRADUN, DEHRADUN

In the result, appeals of the assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

u/s. 147, was clearly unsustainable-On such consideration, both Appellate authorities interfered into matter- o error was committed warranting reconsideration-As far as explanation to S. 151, brought into force by Finance Act, 2008 was concerned, same only pertained to issuance of notice and not with regard to manner of recording satisfaction- Amended provision did not help Revenue-No question

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 :

151 of the Act in the case of the assessee, ld. PCIT contradicted from his statement made before the Hon’ble Settlement Commission. 12. In the last, Ld.AR submits that Hon’ble Settlement Commission while disposing the petition filed by Shri Amit Sharma had not taken any contrary view on the entries found noted at pages

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 :

151 of the Act in the case of the assessee, ld. PCIT contradicted from his statement made before the Hon’ble Settlement Commission. 12. In the last, Ld.AR submits that Hon’ble Settlement Commission while disposing the petition filed by Shri Amit Sharma had not taken any contrary view on the entries found noted at pages

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 :

151 of the Act in the case of the assessee, ld. PCIT contradicted from his statement made before the Hon’ble Settlement Commission. 12. In the last, Ld.AR submits that Hon’ble Settlement Commission while disposing the petition filed by Shri Amit Sharma had not taken any contrary view on the entries found noted at pages

M/S. UTTARAKHAND PURV SAINIK KALYAN NIGAM LTD.,DEHRADUN vs. ITO, DEHRADUN

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

section 148, need not issue such notice himself." 8. In view of the aforesaid explicit provision of the Act, we find that prior sanction of approval u/s 151 of the Act from the competent authority is mandatory before the reopening of assessment. As it has been duly confirmed that no approval U/s 151 of the Act is on record

M/S. UTTARAKHAND PURV SAINIK KALYAN NIGAM LTD.,DEHRADUN vs. ITO, DEHRADUN

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

section 148, need not issue such notice himself." 8. In view of the aforesaid explicit provision of the Act, we find that prior sanction of approval u/s 151 of the Act from the competent authority is mandatory before the reopening of assessment. As it has been duly confirmed that no approval U/s 151 of the Act is on record

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

In the result, appeal of the assessee is partly allowed

151.]”\n12.\nFrom the perusal of the provisions of section 148A, it is clearly\nprovided in sub-section (a) that before issue of notice u/s 148, AO should\nconduct enquiry with the prior to approval of the specified authority with\nrespect to information suggest the income chargeable has escaped\nassessment. In the instant case, from the perusal of the notice

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)

u/s 147 is itself is bad in law as the reason recorded would not have led to the formation of belief of escapement of income. (b) That impugned reassessment order was passed without complying with the mandatory conditions of section 147 to 151

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.

147 r.w.s 143(3) of the Act is erroneous and prejudicial to the interests of Revenue on the issue of alleged bogus „purchases‟ made from one M/s Meet Enterprises. 2 2.1. That the PCIT exceeded his jurisdiction in setting aside the reassessment order on the issue of alleged bogus „purchases‟ from M/s Meet Enterprises, despite the fact that the issue

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)

151 of the Act, copy of the same is placed at PB pages- 13-17. Thereafter, the re-assessment proceedings were completed, and order was passed u/s 147 r.w.s. 144B of the Act wherein additions of Rs. 50.00 lacs u/s 68 as unexplained cash credits and Rs. 1,25,000/- as unexplained expenditure u/s 69C for obtaining such loan were

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