M/S MADHYA PRADESH MADHYAM,BHOPAL vs. THE ACIT, BHOPAL

In the result, both the appeals of the assessee i

Bench: Shri Kul Bharat & Shri Manish Borad

reassessment under sub-section (3) of section 92CD;] (c) an order made under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections 91[***] 92[except an order referred to in sub-section (12) of section

AGROH INFRASTRUCTURE DEVELOPERS P LTD,MHOW vs. PR CIT CENTRAL CIRCLE BHOPAL, BHOPAL

In the result, appeal of assessee is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Agroh Infrastructure Pr. Cit (Central) Developers Pvt. Ltd. Bhopal Aqua Point, A.B.Road, Vs. Umaria, Mhow, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaeca 2752 L Assessee By Shri Manish Mittal, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 10.04.2023 Date Of Pronouncement 11.04.2023

reassessment order. Page 13 of 16 Agroh Infrstructure Developers P. Ltd. Page 14 of 16 3(xv) We are unable to agree. We are unable to agree as Paragraph 15 of the Alagendran Finance case makes it clear that when a notice under Section

THE DCIT CENTRAL-(1), INDORE vs. M/S AYUSH AJAY CONSTRUCTION PVT. LTD. , INDORE

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyanii.T(Ss).A. Nos.14 To 16/Ind/2018 (Assessment Years: 2007-08 To 2009-10)

reassessment made under section 153A of the Act is annulled in appeal or any other proceeding. 16. section 153A bears

SANJEEV AGRAWAL ,BHOPAL vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL-2, BHOPAL

Appeal is allowed

16,58781601\nless - first installonen가\n= Spopopoor\n4/10 13/05/2016\nBalance Receivable\n= 11,58,78,160r\nless - Second Installment\nupto 11/08/2016\nAlready paid to Kriplaniti\n= 325,00000\nBalance Payable 01/10 11/08/2016.\n= 270,00,000 -\n(Installment Amont - 595popoor)\nBalance\n= 5,63,78,160-\nlese - Third Installment.\nupto 11/11/2016\nAlredry Paid to Kiblaniti\n= 3,25,00000r

SHRI NARAYAN DAS TOLANI,BHOPAL vs. THE ITO 3(1), BHOPAL

In the result, the appeal of the assessee on this ground is allowed

Bench: Shri C. M. Garg & Shri O.P. Meena

Section 150 of the Act is not applicable in respect of the assessment year in which the assessment, reassessment or Page 13 of 16

SANDHYA SINGH ,BHOPAL vs. ITO (2)(3), BHOPAL

In the result, the appeal of the assessee in ITA No

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year:2014-15 Sandhya Singh Nfac, 121, Rohit Nagar, New Delhi बनाम/ Bawadia Kala, Vs. Bhopal (Assessee/Appellant) (Revenue/Respondent) Pan: Aycps9215K Assessee By Shri Gagan Tiwari & Ms. Priyal Jain, Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 19.03.2026 Date Of Pronouncement 17.04.2026

reassessment scheme by amending sections 147 to 151 of the Act by inserting a new section 148A of the Act with effect from 1-4-2021. The Hon’ble Supreme Court in the case of Union of India vs Ashish Agarwal reported in 138 taxmann.com 64 (SC) dated 4-5-2022 held that any notice served post

SHRI VIKRAM SINGH PUAR SON & LR OF LATE TUKOJI ROA PUAR,DEWAS vs. THE PR. CIT-1, BHOPAL

The appeal of the assessee is hereby allowed

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2011-12 Vikram Singh Paur, Pr. Cit Son & Legal Heir Of Late Shri Bhopal बनाम/ Tukoji Rao Puar Vs. Dewas (Appellant) (Revenue ) P.A. No.Agdpp8186B Appellant By Shri Girish Agrawal, Ca Revenue By Shri S.B. Prasad, Cit-Dr Date Of Hearing: 27.01.2020 Date Of Pronouncement: 20 .05.2020 आदेश / O R D E R Per Kul Bharat, J.M: This Appeal By The Assessee Is Directed Against Order Of Pr. Cit, Bhopal Dated 18.03.2016 For The Assessment Year

reassessment proceedings and same cannot be made applicable for revisional proceedings as contemplated under section 263 [In favour of assessee] 6. Assessee submits that the invalidity of passing of an order in the name of deceased assessee, Late Shri Tukoji Rao Puar even when the fact of death was informed cannot be rectified under the provisions of section 154. Reliance

THE ACIT,CENTRAL CIRCLE-1, BHOPAL, BHOPAL vs. DB POWER LTD, BHOPAL

Appeal is dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Db Power Limited, Acit, Central Circle-1, बनाम/ Office Block, 1A, Bhopal Vs. Db City Park, 5Th Floor, Corporate Block, Opp. M.P. Nagar Zone-1, Arera Hills, Bhopal (Pan:Aaccd5475F) (Assessee/Appellant) (Revenue/Respondent) Acit, Central Circle-1, M/S Db Power Limited, बनाम/ Bhopal Office Block, 1A, Vs. Db City Park, 5Th Floor, Corporate Block, Opp. M.P. Nagar Zone-1, Arera Hills, Bhopal (Pan:Aaccd5475F) (Revenue/Appellant) (Assessee/Respondent)

reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course of the proceedings under this section, or recompute the loss or the depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in this section and in sections

DB POWER LTD,BHOPAL vs. THE ACIT,CENTRAL CIRCLE-1, BHOPAL, BHOPAL

Appeal is dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Db Power Limited, Acit, Central Circle-1, बनाम/ Office Block, 1A, Bhopal Vs. Db City Park, 5Th Floor, Corporate Block, Opp. M.P. Nagar Zone-1, Arera Hills, Bhopal (Pan:Aaccd5475F) (Assessee/Appellant) (Revenue/Respondent) Acit, Central Circle-1, M/S Db Power Limited, बनाम/ Bhopal Office Block, 1A, Vs. Db City Park, 5Th Floor, Corporate Block, Opp. M.P. Nagar Zone-1, Arera Hills, Bhopal (Pan:Aaccd5475F) (Revenue/Appellant) (Assessee/Respondent)

reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course of the proceedings under this section, or recompute the loss or the depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in this section and in sections

NILIMA KOTHARI,INDORE vs. THE INCOME TAX OFFICER, NATIONAL FACELESS ASSTT. CENTRE, INDORE

In the result appeal of the assessee is allowed as per terms indicated above

Bench: Shri Manish Boradsmt. Neelima Kothari, Income Tax Officer, 601, N.R.K. Villas, Delhi Vs. 22/2 Manoramaganj, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Adnpk7832J Assessee By Shri S.S. Deshpande, Ar Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 08.08.2024 Date Of Pronouncement 20.09.2024

16-17, AY 17-18: Fresh notice under section 148 can be issued in these cases, with the approval of the specified authority, under clause (a) of sub-section (1) of new section 149 of the Act, since they are within the period of three years from the end of the relevant assessment year. Specified authority under section

M/S. SANWARIA AGROILS LIMITED,BHOPAL vs. THE ACIT 1(1), BHOPAL

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

Bench: Shri Chandra Mohan Garg & Shri O.P.Meena

16-02-2012, the perusal of the same shows that the same were recorded on 23-11-2011. Therefore, it was contended that the reasons were recorded after issue of notice under section 148 for the assessment, and, therefore, the reassessment

MAHENDRA KUMAR VERMA,INDORE vs. ITO-4(1), INDORE, INDORE

Bench: Smt. Annapurna Gupta & Shri Paresh M Joshiआयकर अपील सं./I.T.A. No. 482/Ind/2024 (िनधा"रण वष" / Assessment Year : 2013-14) बनाम/ Mahendra Kumar Verma Ito-4(1) Flat No.301, Classic Indore Vs. Dream, 5-6, Paliwal Nagar, Indore (M.P.) -452011 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Acspv2701P (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri S. N. Agrawal & Shri Pankaj Mongra, A.Rs. ""यथ" क" ओर से/Respondent By : Shri Ashish Porwal, Sr.Dr 17/04/2025 Date Of Hearing Date Of Pronouncement 24/06/2025

reassessment proceedings initiated under section 147 of the Income-Tax Act, 1961 even when reopening was done without obtaining proper sanction from the competent authority as mandated by the provisions of section 151 of the Act 6. That on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in confirming the addition

KUNAL VYAS,INDORE vs. ITO 4(1), IND, MAIN BUILDING, INDORE

The appeal of the assessee is allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

16,00,687/- and also failed to establish the identity, genuineness and creditworthiness of the transactions, especially in view of the information regarding MIDN being Kunal Vyas vs. ITO A.Y. 2018-19 part of a benami network. Accordingly, the addition under section 68 of the Act was confirmed. As regards the property purchase, the CIT(Appeals) held that the assessee

NARENDRA KUMAR AGRAWAL,BURHANPUR vs. PCIT INDORE-1, INDORE

In the result, appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaninarendra Kumar Agrawal Pcit (1) 203, Ck Campus Aaykar Bhawan Bahadarpur Road Vs. Indore Burhanpur (Appellant / Assessee) (Respondent/ Revenue) Pan: Adapa0131B Assessee By Shri S.N. Agrawal & Pankaj Mogra, Ars Revenue By Shri Ram Kumar Yadav, Cit-Dr Date Of Hearing 20.08.2024 Date Of Pronouncement 29.08.2024

16 of 27 ITANo.345/Ind/2024 Narendra Kumar Agrawal passed reassessment order u/s 147 r.w. section 144B on 28.03.2022 as under: “The assessee

ABHISHEK DHANOTIA,INDORE vs. INCOME TAX OFFICER- 3(1), INDORE

Bench: Shri Kul Bharatassessment Year: 2010-11

reassess income of such other person in accordance with the provisions of section 153A.” [emphasis supplied] 4. From the above mentioned circular, it is evident that provisions of section 153C are applicable in specific circumstances when any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belong or belongs

ASSISTANT COMMISSIONER OF INCOME TAX - 4(1), INDORE, INDORE vs. PRATAAP SNACKS LIMITED, INDORE

In the result revenue’s appeal is dismissed and assessee’s cross-objection is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

reassessment order passed u/s 147 of the Act. The Cross Objections of the assessee stand disposed off being allowed. Revenue’s Appeal for A.Y. 2012-13, 2013-14, 2017-18, 2020- 21 and 2018-19: 11. Ld. Departmental Representative vehemently argued and submitted that section 80IB(11A) provides for deduction in the case of an undertaking deriving profit from

ASSISSTANT COMMISSIONER OF INCOME TAX - 4(1), INDORE, INDORE vs. PRATAAP SNACKS LIMITED, INDORE

In the result revenue’s appeal is dismissed and assessee’s cross-objection is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

reassessment order passed u/s 147 of the Act. The Cross Objections of the assessee stand disposed off being allowed. Revenue’s Appeal for A.Y. 2012-13, 2013-14, 2017-18, 2020- 21 and 2018-19: 11. Ld. Departmental Representative vehemently argued and submitted that section 80IB(11A) provides for deduction in the case of an undertaking deriving profit from

ASSISSTANT COMMISSIONER OF INCOME TAX - 4(1), INDORE, INDORE vs. PRATAAP SNACKS LIMITED, INDORE

In the result revenue’s appeal is dismissed and assessee’s cross-objection is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

reassessment order passed u/s 147 of the Act. The Cross Objections of the assessee stand disposed off being allowed. Revenue’s Appeal for A.Y. 2012-13, 2013-14, 2017-18, 2020- 21 and 2018-19: 11. Ld. Departmental Representative vehemently argued and submitted that section 80IB(11A) provides for deduction in the case of an undertaking deriving profit from