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

151 ITD 79 (Del) does not apply at all. Even in that decision, also it has been stated that this is not an offshore supply as title to the goods have passed in India and not outside India. Further decision of the honourable High Court in ITA number 64 of 2014 does not deal with supply of goods. The honourable

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

151 ITD 79 (Del) does not apply at all. Even in that decision, also it has been stated that this is not an offshore supply as title to the goods have passed in India and not outside India. Further decision of the honourable High Court in ITA number 64 of 2014 does not deal with supply of goods. The honourable

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

151 ITD 79 (Del) does not apply at all. Even in that decision, also it has been stated that this is not an offshore supply as title to the goods have passed in India and not outside India. Further decision of the honourable High Court in ITA number 64 of 2014 does not deal with supply of goods. The honourable

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

151 ITD 79 (Del) does not apply at all. Even in that decision, also it has been stated that this is not an offshore supply as title to the goods have passed in India and not outside India. Further decision of the honourable High Court in ITA number 64 of 2014 does not deal with supply of goods. The honourable

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

151 ITD 79 (Del) does not apply at all. Even in that decision, also it has been stated that this is not an offshore supply as title to the goods have passed in India and not outside India. Further decision of the honourable High Court in ITA number 64 of 2014 does not deal with supply of goods. The honourable

BABU LAL PATWARI ,UTTARAKHAND vs. DCIT CIRCLE-2(1)(), UTTARAKHAND

In the result, the appeal filed by the assessee is allowed

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

u/s 151 dated 31.03.2021 was accorded by the PCIT, Bareilly and as per the records available, the requisite document its unsigned. A copy of the RTI application and reply of the same is placed on record. 7. In view of his submissions, ld. AR pleaded that on the ground of approval from specified authority alone the notice under Section

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

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

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

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

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

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

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

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

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

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

1) and sub-section (2), the Principal Chief Commissioner or the Chief Commissioner or the Principal Commissioner or the Commissioner the Joint Commissioner, as the case may be, being satisfied on the reasons recorded by the Assessing Officer about fitness of a case for the issue of notice under section 148, need not issue such notice himself." 8. In view

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

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

1) and sub-section (2), the Principal Chief Commissioner or the Chief Commissioner or the Principal Commissioner or the Commissioner the Joint Commissioner, as the case may be, being satisfied on the reasons recorded by the Assessing Officer about fitness of a case for the issue of notice under section 148, need not issue such notice himself." 8. In view

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