M/S. R.B. ENTERPRISES,DEHRADUN vs. DCIT, DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra(Through Video Conferencing)

section 147 of Income Tax Act, 1961 (Negi) Dy. Commissioner of Income Tax Central Circle, Dehra Dun 3.4 Adjudication of the grounds of appeal requires perusal of bare facts, which are as follows: 4 | P a g e ITA Nos.3500 & 3501/Del/2017 and i. The appellant is a registered partnership firm, engaged in the business of development, purchase and sale

M/S. R.B. ENTERPRISES,DEHRADUN vs. DCIT, DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra(Through Video Conferencing)

section 147 of Income Tax Act, 1961 (Negi) Dy. Commissioner of Income Tax Central Circle, Dehra Dun 3.4 Adjudication of the grounds of appeal requires perusal of bare facts, which are as follows: 4 | P a g e ITA Nos.3500 & 3501/Del/2017 and i. The appellant is a registered partnership firm, engaged in the business of development, purchase and sale

MASCOT FASTNERS PRIVATE LIMITED,UTTARAKHAND vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI, -

In the result, the appeal of the assessee is hereby allowed

Bench: Shri M. Balaganesh & Shri Satbeer Singh Godara(Through Video Conferencing) M/S. Mascot Fastners Pvt. Vs. National Faceless Ltd, Assessment Centre, Plot No. B-155, Eldeco, Sidcul, Delhi Industrial Park, Sitarganj, Udham Singh Nagar, 262 403 (Appellant) (Respondent) Pan: Aabcm4504H Assessee By : Shri Atul Ninawat, Partner Revenue By: Shri A. S. Rana, Sr. Dr Date Of Hearing 18/03/2025 Date Of Pronouncement 02/04/2025

u/s 80 IC in respect of sale of scrap and job work. 6. The Ld. CIT(A) has erred on facts in stating that no disclosure of the process of generation of scrap was made so as to work out whether the scrap was generated from his eligible manufacturing business or not. 7. The above grounds are all independent

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

28-Chakrata Road, Dehradun Dehradun Vs. PAN-AWKPS 6026L (Appellant) (Respondent) Appellant by Dr. Rakesh Gupta and Mr. Sherey Jain, Advocates Respondent by Mr. N.S.Jangpangi, CIT-DR Date of Hearing 23/06/2023 Date of Pronouncement 28/06/2023 ORDER (A) Both the appeals by Assessee are filed against the separate orders of Learned Principal Commissioner of Income Tax, Page

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

28-Chakrata Road, Dehradun Dehradun Vs. PAN-AWKPS 6026L (Appellant) (Respondent) Appellant by Dr. Rakesh Gupta and Mr. Sherey Jain, Advocates Respondent by Mr. N.S.Jangpangi, CIT-DR Date of Hearing 23/06/2023 Date of Pronouncement 28/06/2023 ORDER (A) Both the appeals by Assessee are filed against the separate orders of Learned Principal Commissioner of Income Tax, Page

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

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. (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 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

SIME DARBY ENGINEERING SDN BHD,GURGAON vs. DCIT (INTERNATIONAL TAXATION), CIRCLE-2, 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

SIME DARBY ENGINEERING SDNBHD,MALAYSIA 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

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

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

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

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