RAJ BALA MITTAL,HARDWAR vs. ITO, WARD-3, HARDWAR

In the result, the appeal of the assessee is allowed

Bench: Him For Examination

133(6) of the Act or issuing summons to the lender under section 131 of the Act for recording the statement on oath from the lender. Instead, learned Assessing Officer completely shifted the onus on the assessee to produce the party before him for examination. We are unable to comprehend ourselves to accept this behavior of learned Assessing Officer

REENA VERMA,HARIDWAR vs. ITO, WARD-1(3)(5), ROORKEE

In the result, the appeal of the assessee stands partly allowed as above

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

133(6) of the Act of when as a matter-of-fact M/s India Glycols Ltd have been accepted as such. 4. That the authorities below have framed the impugned order without granting sufficient proper opportunity to the appellant company and therefore the same are contrary to principle of natural justice and hence vitiated. 5. That the learned Commissioner

SIDHARTH BUILDWELL LLP,DEHRADUN vs. ACIT, C- 1(2)(1), DEHRADUN

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

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmansidharth Buildwell Llp Vs. Acit, 1, Darshiningate, Kanwali, Circle 1(2)(1), Kanwali B.O. Dehradun Haripuram, Dehradun Pan: Acufs6966M (Appellant) (Respondent) Assessee By: Ms. Komal Sachev, Ca Revenue By: Sh. A.S.Rana, Sr. Dr Date Of Hearing: 14.01.2026 Date Of Order : 27.02.2026 Order Per S. Rifaur Rahman: The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Ld. Cit(A)”, For Short] Dated 07.06.2024 For The Assessment Year 2017-18. 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income On 07.11.2017 Declaring Income At Rs. 95,08,920/- For Assessment Year 2017- 18. The Case Was Selected For Complete Scrutiny Through Cass With The Reasons “Higher Turnover Reported In Service Tax Return As Compared To Itr, Large Increase In Unsecured Loans During The Year, Real Estate Business

Section 68 incorrectly invoked. 4. Appellant not at Fault For the Parties Not Responding To Notices Issued U/S 133(6

JCIT(OSD), CIRCLE 111, DEHRADUN, SUBHASH ROAD vs. M/S SURYANCHAL FURNITECH, BAHADRABAD INDUSTRIAL AREA, HARIDWAR

Appeal is partly allowed

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 82/Ddn/2025 : Asstt. Year: 2017-18 Jcit(Osd), Vs M/S Suryanchal Furnitech, Circle-111, F-104, Bahadrabad Industrial Dehradun-248001 Area, Haridwar-249402 (Appellant) (Respondent) Pan No. Abofs3475L Assessee By : Sh. Himanshu Sharma, Adv. Revenue By : Sh. A. S. Rana, Sr. Dr Date Of Hearing: 15.01.2026 Date Of Pronouncement: 21.01.2026 Order Per Satbeer Singh Godara: This Revenue’S Appeal For Assessment Year 2017-18, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1074074259(1) Dated 05.03.2025, In Proceedings U/S 143(3) Of The Income Tax Act, 1961. 2. Heard Both The Parties At Length. Case File Perused.

133(6) delivered on mail. Accordingly, the AO held that the appellant has failed to substantiate that cash was received from M/s A.K. Enterprises and M/s Manoj Enterprise and they had worth to pay such a large amount of Rs. 2,78,62,397/- in cash. Therefore, addition of Rs. 2,78,62,397/- was made to the income

MOHAN PAL,HALDWANI, NAINITAL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HALDWANI, ACIT - DCIT, CENTRAL CIRCLE, HALDWANI

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

68. The jurisdictional AO would have to firstly be satisfied that the material received is likely to have a bearing on or impact the total income of years or years which may form part of the block of six or ten AYs' and thereafter proceed to place the assessee on notice under Section 153C. The power to undertake such

MOHAN PAL,HALDWANI, NAINITAL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HALDWANI, ACIT-DCIT, CENTRAL CIRCLE, HALDWANI

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

68. The jurisdictional AO would have to firstly be satisfied that the material received is likely to have a bearing on or impact the total income of years or years which may form part of the block of six or ten AYs' and thereafter proceed to place the assessee on notice under Section 153C. The power to undertake such

MOHAN PAL,HALDWANI, NAINITAL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HALDWANI, ACIT - DCIT, CENTRAL CIRCLE, HALDWANI

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

68. The jurisdictional AO would have to firstly be satisfied that the material received is likely to have a bearing on or impact the total income of years or years which may form part of the block of six or ten AYs' and thereafter proceed to place the assessee on notice under Section 153C. The power to undertake such

PAL MINERAL INDUSTRIES (P) LIMITED,HALDWANI vs. DC/ACIT, CENTRAL CIRCLE, HALDWANI, HALDWANI

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

6. Heard the contentions of both parties at length and perused the material available on record. From the perusal of the satisfaction note placed before us, it is observed that AO while initiating the proceedings u/s 153C had recorded his satisfaction which is undated, had not bifurcated the income year-wise and further no satisfaction with reference to “bearing

PAL MINERAL INDUSTRIES (P) LIMITED,HALDWANI vs. DC/ACIT, CENTRAL CIRCLE, HALDWANI, HALDWANI

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

6. Heard the contentions of both parties at length and perused the material available on record. From the perusal of the satisfaction note placed before us, it is observed that AO while initiating the proceedings u/s 153C had recorded his satisfaction which is undated, had not bifurcated the income year-wise and further no satisfaction with reference to “bearing