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

35,834/- shown by the appellant during the year under consideration as under: Operating Receipts S.No. Particulars Amount (Rs.) 1 Advertisement (Rozgar Aur Nirman) 23680953 2 Sale of Newpaper (Rozgar Aur Nirman) 15536473 ITA 280 of 2014 and ITA 692 of 2013 7 MP Madhyam 3 Sale of Books: R.K. Laxman Rs.13440 Images of MP Rs. 14175 Corporate Book

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

35 Sandhya Singh ITA No. 585/Ind/2025 – AY 2014-15 mentioned notice issued under Section 148 of the Act dated 31/03/2021 would be treated as notice under Section 148A(b) of the Act and re-assessment proceedings initiated by issuing fresh notice u/s 148 of the Act after following due procedure for Α.Υ.2017-18.” 6. On a specific query

BARKHA KHANDELWAL,AGGRIEVED ASSESSEE,INDORE vs. INCOME TAX OFFICER-3(1),INDORE, INDORE

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanismt. Barkha Khandelwal Ito -3(1) Aggrieved Assesse Indore 1108, Pinnacle D Dreams, Tower -1 Vs. Near Bhawan Prominent School Pipliyakumar, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Ajnpk4150B Assessee By Shri Rakesh Gupta, Ar Revenue By Shri Ram Kumar Yadav, Cit-Dr Date Of Hearing 12.09.2024 Date Of Pronouncement 20 .09.2024

reassessment order dated 15.12.2019 is bad in Page 2 of 13 ITANo.85/Ind/2024 Barkha Khandelwal law inter alia for the reason that DIN number was not mentioned on the same and mandatory requirement of CBDT circular No. 19/2019 dated 14.08.2019 have not been complied with as is must as held in the judgements of CIT (International Taxation) vs. Brandix Mauritius Holdings

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

35, 82, M/s. Sanwaria Agroil Ltd. / I.T.A. No. 620/Ind/2013 /A.Y.:07-08 Page 3 of 34 306/-. The original assessment under section 143 (3) was completed vide order dated 30-10-2009 determining total income at Rs. 8, 76, 15, 740/-. Subsequently the case was reopened under section 147 by issuing notice under section 148 on 29-09-2011, after

SANDHYA SINGH,ROHIT NAGAR, BHOPAL vs. ITO 2(3) BHOPAL, AAYKAR BHAWAN, BHOPAL

In the result, the appeal is allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

reassessment notice was invalid in law in view of the amended provisions applicable from 01.04.2021, and alleged violation of principles of natural justice on the ground that the assessment was completed under section 144 without properly considering her submissions. On merits, the assessee disputed the addition of ₹3,62,68,600/- under section 69A, reiterating that one of the bank

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

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

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

INDIRA BAI JINDAL,KHARGONE vs. INCOME TAX OFFICER, NFAC

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

35,00,000/- as unexplained money and ₹1,05,000/- as unexplained expenditure, and the Assessing Officer also initiated penalty proceedings under section 271(1)(c) and section 271F of the Act. 4. Aggrieved by the assessment order, the assessee preferred an appeal before the Ld. CIT(Appeals) raising multiple grounds. Grounds of Appeal

DEPUTY COMMISSIONER OF INCOME TAX -5(1), INDORE vs. M/S SUNDERDEEP CONSTRUCTIONS PVT. LTD. , INDORE

In the result both the appeals of the revenue vide ITA No

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Borad

35-A, Dindayal Upadhyay Nagar, Indore : Respondent PAN : AAACU2189B Revenue by Shri Lal Chand, CIT Assessee by S/Shri Girish Agrawal, Vijay Bansal & Ms. Nisha Lahoti, ARs Date of Hearing 16.02.2021 Date of Pronouncement 09.03.2021 O R D E R PER MANISH BORAD, A.M The above captioned appeals filed at the instance of the Revenue pertaining to Assessment Year

DEPUTY COMMISSIONER OF INCOME TAX -5(1), INDORE vs. M/S SUNDERDEEP CONSTRUCTIONS PVT. LTD. , INDORE

In the result both the appeals of the revenue vide ITA No

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Borad

35-A, Dindayal Upadhyay Nagar, Indore : Respondent PAN : AAACU2189B Revenue by Shri Lal Chand, CIT Assessee by S/Shri Girish Agrawal, Vijay Bansal & Ms. Nisha Lahoti, ARs Date of Hearing 16.02.2021 Date of Pronouncement 09.03.2021 O R D E R PER MANISH BORAD, A.M The above captioned appeals filed at the instance of the Revenue pertaining to Assessment Year

INCOME TAX OFFICER , RAISEN, RAISEN vs. LATE SUDHA AGRAWAL TH. L/H MANMOHAN AGRAWAL, RAISEN

Appeal is dismissed and assessee’s cross-

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniincome-Tax Officer, Late Smt. Sudha Agrawal, बनाम/ Raisen (L/H: Manmohan Agrawal) Vs. 19/1, Shreeji Enterprise, Near Sbi, Sagar Road, Yashwant Nagar, M.P. (Pan: Abfpa4355G) (Revenue/Appellant) (Assessee/Respondent)

reassessment. A notice issued under Section 148 of the Act against a dead person is invalid, unless the legal representative submits to the jurisdiction of the Assessing Officer without raising any objection." Consequently, in view of the above, a reopening notice under Section 148 of the Act, 1961 issued in the name of a deceased assessee is null and void

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

reassessment order u/s 147 r.w. section 144B on 28.03.2022 as under: “The assessee, NARENDRA KUMAR AGRAWAL, had filed his return of income for the AY 2016- 17 declaring total income of Rs. 5,35

RNG CONSTRUCTION CO,MANDIDEEP vs. ADDL.,JT.,DY.,ASSTT.ITO, BHOPAL

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

reassessment order passed by AO u/s 148 because no new facts surfaced regarding the subject Service Tax of Rs. 8,32,158/- sought to be disallowed u/s.43B as these facts were already fully disclosed and were available on record of the department in the Tax Audit Report. 3. That, on the facts and circumstances of the case

SHRIMATI SHARDA KASLIWAL,INDORE vs. ASSISTANT COMMISSIONER OF INCOME TAX- CENTRAL (I), INDORE, INDORE

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Borad

reassessment or re-computation, as the case may be, shall, after the exclusion of the period under subsection (4) of section 245HA, be not less than one year; and where such period of limitation is less than one year, it shall be deemed to have been extended ,to one year; and for the purposes of determining the period of limitation

MANOJ KASLIWAL,INDORE vs. ASSISTANT COMMISSIONER OF INCOME TAX- CENTRAL (1), INDORE, INDORE

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Borad

reassessment or re-computation, as the case may be, shall, after the exclusion of the period under subsection (4) of section 245HA, be not less than one year; and where such period of limitation is less than one year, it shall be deemed to have been extended ,to one year; and for the purposes of determining the period of limitation