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

250(6) of the Income-tax Act, 1961 („Act‟), on the following grounds: Initiation of reassessment proceedings 1. The learned CIT(A) has erred in law and in fact, by dismissing the claim of the Appellant that the reassessment proceedings were initiated under section 147 of the Act without having any fresh material on record and using section 147

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

250(6) of the Income-tax Act, 1961 („Act‟), on the following grounds: Initiation of reassessment proceedings 1. The learned CIT(A) has erred in law and in fact, by dismissing the claim of the Appellant that the reassessment proceedings were initiated under section 147 of the Act without having any fresh material on record and using section 147

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

250(6) of the Income-tax Act, 1961 („Act‟), on the following grounds: Initiation of reassessment proceedings 1. The learned CIT(A) has erred in law and in fact, by dismissing the claim of the Appellant that the reassessment proceedings were initiated under section 147 of the Act without having any fresh material on record and using section 147

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

250(6) of the Income-tax Act, 1961 („Act‟), on the following grounds: Initiation of reassessment proceedings 1. The learned CIT(A) has erred in law and in fact, by dismissing the claim of the Appellant that the reassessment proceedings were initiated under section 147 of the Act without having any fresh material on record and using section 147

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

250(6) of the Income-tax Act, 1961 („Act‟), on the following grounds: Initiation of reassessment proceedings 1. The learned CIT(A) has erred in law and in fact, by dismissing the claim of the Appellant that the reassessment proceedings were initiated under section 147 of the Act without having any fresh material on record and using section 147

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 :

4. On the facts and circumstances of the case, Ld. CIT(A) has erred in affirming the jurisdiction of the AO under section 147 ignoring that the AO has not followed the mandatory provisions of section 147 to 151 (both inclusive) of the Income Tax Act, 1961. 5. On the facts and circumstances of the case, the assessment order

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 :

4. On the facts and circumstances of the case, Ld. CIT(A) has erred in affirming the jurisdiction of the AO under section 147 ignoring that the AO has not followed the mandatory provisions of section 147 to 151 (both inclusive) of the Income Tax Act, 1961. 5. On the facts and circumstances of the case, the assessment order

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 :

4. On the facts and circumstances of the case, Ld. CIT(A) has erred in affirming the jurisdiction of the AO under section 147 ignoring that the AO has not followed the mandatory provisions of section 147 to 151 (both inclusive) of the Income Tax Act, 1961. 5. On the facts and circumstances of the case, the assessment order

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

In the result, appeal of the assessee is partly allowed

250 dated\n24.10.2024 erred in not deleting the impugned addition amounting to Rs\n54,94,750 which impugned addition is \"arbitrarily\" made/sustained as\napparently there is no valid legal justification/basis for the same.”\n5. Ground of appeal No.(A) raised by the assessee is general in\nnature, needs no separate adjudication hence, dismissed.\n6. Ground of appeal

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)

reassessment order was passed without complying with the mandatory conditions of section 147 to 151 of Income Tax Act, 1961. 2. That in any case and in any view of the matter, Ld. Pr. CIT has erred in law in assuming jurisdiction and passing the impugned order u/s 263, is bad in law and against the facts and circumstances

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)

250 of the Income Tax Act, 1961 (“the Act”) for Assessment Year 2015-16. 2. Brief facts of the case are that assessee is a resident individual and filed his return of income on 17.03.2016 declaring total income of Rs.97,40,460/. The case of the assessee was reopened u/s 147 of the Act by issue of notice u/s

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

4 of 10 ITA No.2187/Del/2018 & Sanjay Kumar & Dariyav Singh vs. Pr.CIT Rs.35,08,250/- and consequently claimed deduction u/s 54B of the Act in view of the fact that the assessee had purchased another agricultural land for Rs.80 lacs. The nil capital gain reported by the assessee was accepted by the Ld. A.O. in the re-assessment and concluded u/s

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

4 of 10 ITA No.2187/Del/2018 & Sanjay Kumar & Dariyav Singh vs. Pr.CIT Rs.35,08,250/- and consequently claimed deduction u/s 54B of the Act in view of the fact that the assessee had purchased another agricultural land for Rs.80 lacs. The nil capital gain reported by the assessee was accepted by the Ld. A.O. in the re-assessment and concluded u/s

AKHILESH SINGHAL,RISHIKESH vs. INCOME TAX OFFICER, RISHIKESH

In the result, appeal of the assessee is allowed

4)(1), Rishikesh\nScanned with OKEN Scanne\n14. From the perusal of the above, it is seen that AO has admitted\nthat all the notices including notice u/s 148 were sent at the\naddress i.e.139, Chandreshwar Nagar, Rishikesh, Uttarakhand-\n249201 and at the e-mail ID pandeymahesh600@gmail.com. From\nPage | 7\nITA Nos.64, 78 & 79/DDN/2024\nthe perusal of ITR filed

RITU SINGHAL,DEHRADUN vs. DCIT/ACIT , CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

u/s 69A of the Act.\n10. The Ld.AR for the assessee filed a written submission in support\nof her claim. The relevant contents of written submission are\nreproduced as under:-\nGround No. 4 & 5 - Addition of Rs. 4,87,000/-\n1) The Ld. CIT (Appeal) has sustained the Ld. AO's adhoc, biased and baseless addition\nof the official cash

AKHILESH SINGHAL,RISHIKESH vs. INCOME TAX OFFICER, RISHIKESH

In the result, appeal of the assessee is allowed

4)(1), Rishikesh\nScanned with OKEN Scanne\n14.\nFrom the perusal of the above, it is seen that AO has admitted\nthat all the notices including notice u/s 148 were sent at the\naddress i.e.139, Chandreshwar Nagar, Rishikesh, Uttarakhand-\n249201 and at the e-mail ID pandeymahesh600@gmail.com. From\nPage | 7\nITA Nos.64, 78 & 79/DDN/2024\nthe perusal of ITR filed

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

250 of the Income Tax Act, 1961 [“the Act”] arising from the 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 the case of the assessee was re- opened based on the documents found and seized, during the course of search carried

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/-.

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