RADHESHYAM AGARWAL,BHOPAL vs. THE PCIT, CENTRAL, BHOPAL , BHOPAL

148A(d) issued to the\nassessee after obtaining the prior approval of the PCIT (Central),\nBhopal.\n7. In response to this notice, the assessee, vide acknowledgement\nno.601395070290422, filed his ITR on 29.04.2022 for the year\nunder consideration declaring total income of Rs.1,00,50,700/-\n(inclusive of the income of Rs.73,00,000/-surrendered during\nsurvey proceedings). Subsequently, notice

ANIL DHAKAD,INDORE vs. AASST. COMMISSIONER OF INCOME TAX, CENTRAL-I, INDORE, INDORE

In the result, all four appeals of the assessee are allowed

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

148A of the Act against M/s Amir Brothers. Once the Cheque entries are accepted as receipt from the same source and same nature of income then the cash entries in respect of the Dewas account cannot be treated differently. At the first instance the assessee in the statement recorded u/s 132(4) explained the nature and sources of these cash

ANIL DHAKAD,INDORE vs. ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL-I, INDORE, INDORE

In the result, all four appeals of the assessee are allowed

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

148A of the Act against M/s Amir Brothers. Once the Cheque entries are accepted as receipt from the same source and same nature of income then the cash entries in respect of the Dewas account cannot be treated differently. At the first instance the assessee in the statement recorded u/s 132(4) explained the nature and sources of these cash

ANIL DHAKAD,INDORE vs. ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL-I, LOCATION

In the result, all four appeals of the assessee are allowed

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

148A of the Act against M/s Amir Brothers. Once the Cheque entries are accepted as receipt from the same source and same nature of income then the cash entries in respect of the Dewas account cannot be treated differently. At the first instance the assessee in the statement recorded u/s 132(4) explained the nature and sources of these cash

ANIL DHAKAD,INDORE vs. ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL-I, INDORE, INDORE

In the result, all four appeals of the assessee are allowed

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

148A of the Act against M/s Amir Brothers. Once the Cheque entries are accepted as receipt from the same source and same nature of income then the cash entries in respect of the Dewas account cannot be treated differently. At the first instance the assessee in the statement recorded u/s 132(4) explained the nature and sources of these cash

MANISH KUMAR AGRAWAL,NEEMUCH vs. NFAC,DELHI, DELHI

Appeal is allowed for statistical purpose

68 of Income Tax Act, 1961.\n2.That on the facts and in the circumstances of the case Ld. CIT(A) while passing the impugned order arbitrarily chose to ignore the written submissions and all the documentary evidences produced by the appellant during the course of first appellate proceedings and passed the impugned order in a casual and arbitrary manner

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

148A have not been complied with.] 10.3 Once the A.O has not alleged what information or material fact necessary for the assessment was not disclosed by the assessee then the reopening of the assessment for these Page 17 of 57 Prataap Snacks Limited ITA Nos.370 to 374 & C.O No.6 & 7 assessment years falls in the category of change of opinion

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

148A have not been complied with.] 10.3 Once the A.O has not alleged what information or material fact necessary for the assessment was not disclosed by the assessee then the reopening of the assessment for these Page 17 of 57 Prataap Snacks Limited ITA Nos.370 to 374 & C.O No.6 & 7 assessment years falls in the category of change of opinion

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

148A have not been complied with.] 10.3 Once the A.O has not alleged what information or material fact necessary for the assessment was not disclosed by the assessee then the reopening of the assessment for these Page 17 of 57 Prataap Snacks Limited ITA Nos.370 to 374 & C.O No.6 & 7 assessment years falls in the category of change of opinion

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

148A have not been complied with.] 10.3 Once the A.O has not alleged what information or material fact necessary for the assessment was not disclosed by the assessee then the reopening of the assessment for these Page 17 of 57 Prataap Snacks Limited ITA Nos.370 to 374 & C.O No.6 & 7 assessment years falls in the category of change of opinion

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

148A have not been complied with.] 10.3 Once the A.O has not alleged what information or material fact necessary for the assessment was not disclosed by the assessee then the reopening of the assessment for these Page 17 of 57 Prataap Snacks Limited ITA Nos.370 to 374 & C.O No.6 & 7 assessment years falls in the category of change of opinion

INCOME TAX OFFICER 3(1), BHOPAL, METRO WALK BUILDING vs. RAMESH KUMAR SAHU, LEGAL HEIR OF SMT. RAMPYARI BAI, BHOPAL

In the result appeal of the Revenue is dismissed

Bench: Shri B.M. Biyani & Shri Paresh M Joshiincome Tax Officer 3(1), Ramesh Kumar Sahu बनाम/ Bhopal L/H Of Late Smt. Ram Vs. Pyari Bai, 127 New Market, T.T. Nagar, Bhopal (Pan: Anhps5515N) (Revenue/Appellant) (Assessee/Respondent) Assessee By S/Shri Ashish Goyal & N.D. Patwa, Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 23.07.2025 Date Of Pronouncement 28.07.2025

68,000/- 2.13 That the aforesaid assessment order bears No. ITBA/COM/M/17/2019-20/1023475341(1) and same is dated 29.12.2019 which is hereinafter referred to as the “impugned assessment order”. 2.14 That the assessee being aggrieved by the aforesaid “impugned assessment order” prefers first appeal u/s 246A of the Act before the Ld. CIT(A) who by the “impugned order” has allowed

LATE VINAYAK PURANIK THROUGH LEGAL HEIR YASH PURANIK,INDORE vs. INCOME TAX OFFICER, WARD 3(2), INDORE, INDORE

In the result appeal of the assessee is allowed

Bench: Shri B.M. Biyani & Shri Paresh M Joshilate Vinayak Puranik Income Tax Officer- बनाम/ Through L/H Yash 3(2), Vs. Puranik, Indore 7/4, New Palasia, Indore

68 of the Act. That the aforesaid assessment order is dated 24.12.2018 which is hereinafter referred to as the “impugned assessment order”. 2.2 That the assessee being aggrieved by the aforesaid “impugned assessment order” prefers first appeal u/s 246A of the Act before the Ld. CIT(A) who by the “impugned order” has partly allowed the 1st appeal

RITIKA JAIN,THANE vs. ITO(IT TP), BHOPAL, AAYKAR BHAVAN

Appeal of the assessee is allowed for statistical purpose

Bench: Smt. Annapurna Gupta & Shri Paresh M Joshiritika Jain, Cit (Appeals), बना A-504, Laxmi Residency Chs Nfac, म/ Ltd, Delhi Vs. Opposite Datta Mandir Check Naka, Wagle Estate, Thane

68 of the Act. (b) Ld.AO erred in making addition to the tune of Rs.4,14,000 u/s 69 of the Act without issuing show cause notice. 6) Ld. AO has erred in passing order u/s 148A(d) & issuing notice u/s 148 of L.T.Act, 1961 without appreciating that appellant was not having the jurisdiction for the same in view

ILIYAS,KHARGONE vs. INCOME TAX OFFICER, DELHI

Appeal of the assessee is allowed for statistical purpose

Bench: Smt. Annapurna Gupta & Shri Paresh M Joshiiliyas, Nfac, बनाम/ 56, Khargone Road Bedia, Delhi Vs. Khargone

68 of the IT Act, 1961. However no written submissions were filed in respect of Grounds of Appeal. It is noted that the appeal of the appellant has been dismissed by me for non prosecution in para 6. In view thereof the various grounds raised in appeal have become academic in nature. Grounds of Appeal

SANGITA LALWANI,ITARSI vs. ITO 1, ITARSI, ITARSI

In the result the “Impugned order” is set aside as and by

Bench: Shri B.M. Biyani & Shri Paresh M Joshisangita Lalwani, Ito 1, बनाम/ Gali No.03, Sindhi Colony

Section 253 of the Income Tax Act 1961 (herein after referred to as the Act for the sake of Brevity) before this tribunal as and by way of a second Appeal.The Assessee is aggrieved by the order bearing Number:-ITBA/NFAC/5/250/2025- 26/1081526355(1) dated 07-10-2025 passed by the Ld CIT(A) U/S 250 of the Act, which