GOMESH DWIVEDI,PADRA vs. ITO-REWA, DISTRICT REWA (MP), REWA

In the result, ITA Nos. 15 & 16/JAB/2024 are held to be allowed for statistical purposes

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharyita Nos.15 & 16/Jab/2024 A.Ys. 2012-13 & 2013-14 Gomesh Dwivedi, Vs. Income Tax Officer, Ward No.3, Durga Nagar Padra Huzur Rewa, M.P. Rewa, M.P. Pan:Akcpd5536A (Appellant) (Respondent)

147 were initiated by issue of notice under section 148 on the grounds that the assessee had invested Rs.23,42,857/- in the part purchase of agricultural lands situated at Chourahata, Rewa alongwith Sh. Dileep Kumar Rajwani and five other persons. In response to the notice under section 148, the assessee filed a letter in which it was submitted, that

RAJENDRA SAHU,KATNI vs. INCOME TAX OFFICER-1, , KATNI

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

section 147 r.w.s. 144 r.w.s. 144B of the Income Tax Act on 26.03.2022. The grounds of appeal are as under:- “(1) The order passed by the Ld CIT (A) is bad in law and facts, void ab initio and without jurisdiction. (2) The Ld CIT (A) erred in law and facts of the case in sustaining the order, when notice

RENU ANANDANI,JABALPUR vs. NFAC, NFAC, DELHI

In the result, the appeal is allowed for statistical purposes

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

147 r.w.s. 143(3) and an addition of Rs. 22,16,080/- was made, which included an addition of Rs. 21,72,628/- on account of bogus short term capital loss on sale of shares. Subsequently, this assessment order was set aside by the ld. PCIT-1, Jabalpur under section 263 of the Act on the grounds that the assessee

SANJAY KUMAR AGRAWAL ,SATNA vs. ASST. COMMISSIONER OF INCOMETAX CIRCLE, SATNA

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

Bench: Shri Kul Bharat & Shri, Nikhil Choudharyassessment Year: 2016-17 Sanjay Kumar Agarwal V. Acit Circle Satna Blooms Campus, Nh-75, Panna Aayakar Bhawan, Civil Road, Satna (Mp)-485001. Lines, Satna, Mp-485001. Tan/Pan:Ackpa2596H (Appellant) (Respondent) Appellant By: Shri Sanjay Mishra, Adv Respondent By: Shri N. M. Prasad, Sr. Dr-1 Date Of Hearing: 19 08 2025 Date Of Pronouncement: 21 08 2025 O R D E R

147 read with Section 144B of the Income Tax Act, 1961, on 30.03.2022, assessing the income at Rs. 42,56,500/-. This included an addition of Rs. 26,29,800/- under Section 68 of the Act, treating the sale consideration of shares as unexplained cash credit. 4. The AO also rejected the Appellant’s claim of exemption under Section

RJKUMAR VALECHA L/H OF LATE SHRI GHANSHYAM DAS VALECHA,JABALPUR vs. DCIT CIRCLE 2(1), JABAPUR

Bench: Shri Kul Bharat & Shri, Anadee Nath Misshraassessment Year: 2012-13 Rajkumar Valecha L/H Of Late V. Dcit Circle-2(1) Shri Ghanshyam Das Valecha Annexue Building Napier S-736/1-4 Mahavir Complex, Town-482001. Russal Chowk-482001. Pan:Abjpv5609E (Appellant) (Respondent) Appellant By: Shri G. N. Purohit, Sr. Advocate Respondent By: Shri Rahul Padha, Jc-2 Date Of Hearing: 11 02 2026 Date Of Pronouncement: 27 02 2026 O R D E R

147 read with section 144B of the Income Tax Act on 25/10/2021 is barred by limitation in view of the section 153(2) ought to have been completed before 31/03/2021. The assessment order should be quashed. 4. The learned AO as well as CIT(A) has failed to appreciate that proviso added in section 50(c) w.e.f 01/04/2017 is clarificatory

ANURODH SAHU,JABALPUR vs. ITO (IT AND TP), BHOPAL

In the result, the appeal is allowed for statistical purposes

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2018-19 Anurodh Sahu, Vs. Ito (Ft & Tp), 3173, Tulsi Nagar Ranjhi, Jabalpur, Bhopal Madhya Pradesh Pan: Bktps9371L (Appellant) (Respondent) Assessee By: Sh. Anil Agrawal, C.A. Revenue By: Sh. Alok Bhura, Sr. Dr Date Of Hearing: 17.09.2025 Date Of Pronouncement: 28.11.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Income Tax Officer (It & Tp), Bhopal At Jabalpur Dated 16.01.2024 Under Section 147 R.W.S. 144C(13) Of The Income Tax Act For The A.Y. 2018-19. The Grounds Of Appeal Are As Under: - “1. That The Assessment Order Issued By The Learned Assessing Officer On The Basis Of Directions Of Drp Is Unjustified & Base Less On The Basis Of Information & Documents Submitted. 2. That The Learned Assessing Officer Has Never Countered Or Produced Before The Assessee The Source Of Information/ Documents On Basis Of Which The Said Addition Appealed Against Is Made During Whole Assessment Proceedings. 3. That The Learned Assessing Officer Never Questioned The Relevant Sources Of Income Produced & Submitted By The Assessee During The Assessment Proceedings & Brought Nothing On Record To Prove Or Justify The Assessee Having Some Other Source Or Hidden Source Of Income. 4. That The Learned Assessing Officer Has Made The Additions On The Basis Of Incomplete Information Having No Evidence & Based On Surmises On The Directions Given By Drp.

147 r.w.s. 144C(13) of the Income Tax Act for the A.Y. 2018-19. The grounds of appeal are as under: - “1. That the assessment order issued by the Learned Assessing Officer on the basis of directions of DRP is unjustified and base less on the basis of information and documents submitted. 2. That the Learned Assessing Officer has never

CHHAYA MASURKAR,BALAGHAT vs. NATIONAL FACELESS ASSESSMENT CENTER JURISDICTION OFFICER- ITO, BALAGHAT, DELHI

In the result, the appeal of the assessee is dismissed

Bench: Shri Anadee Nath Misshrachhaya Masurkar V. National Faceless 1 Ward No.9 Ram Mandir Road, Assessment Centre Katangi, Madhya Pradesh- Jurisdiction Officer-Ito, 481445. Balaghat Delhi. Tan/Pan:Cakpm8662A (Appellant) (Respondent) Appellant By: Shri Vijay Bagrecha, C.A. Respondent By: Shri Alok Bhura, Sr. Cit(Dr) O R D E R (1). The Present Appeal Has Been Filed By The Assessee Against The Impugned Order Dated 13.02.2024 Order Passed By The Ld. Commissioner Of Income Tax (Appeals) (Hereinafter Referred As To “Cit(A)”)/National Faceless Appeal Centre (Nfac), Delhi, Pertaining To The Assessment Year 2013-14. The Grounds Of Appeal Of The Assessee Are As Under: -

capital gain as added to income of Rs26,49,500/- besides addition of income from other sources of Rs2,00,500 (being difference of cash deposition and full sales consideration). Ld. CIT-A has erred in confirming the assessment order with addition. 7. On facts and in circumstances of the case and in law, Ld. CIT -A erred in having

RAJMATA KAVITESHWARI DEVI,SATNA vs. INCOMETAX OFFICER , SATNA

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

147 of I. T. Act was issued to the assessee. In response to the notice, the assessee filed return of income, declaring Nil income. The dispute in the present case regarding the aforesaid addition of Rs.1,54,80,000/- arose on account of sale of property by the assessee during the year, for sale consideration of Rs.1 crores which

SHRI. NARSINGH RANGA,JABALPUR vs. DCIT, CIRCLE 2(1), JABALPUR

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

Bench: Shri Kul Bharat & Shri, Nikhil Choudharyassessment Year: 2016-17 Shri Narsingh Ranga Dcit, Circle-2(1) V. Sharda Chowk, Nagpur Road, Aaykar Bhawan, Napier Jabalpur, Madhya Pradesh- Town, Jabalpur, Madhya 482001. Pradesh-482001. Pan:Acmpr1917P (Appellant) (Respondent) Appellant By: Shri Sanjay Seth, Ca Respondent By: Shri Alok Bhura, Sr. Cit(Dr) Date Of Hearing: 21 05 2025 Date Of Pronouncement: 11 06 2025 O R D E R

capital gain scheme or not. That as per the provisions of section 54 of the act only says that the assessee should construct the house that does not mean that the construction of house should necessarily be completed within stipulated time is view was been taken by Hon’ble Madhya Pradesh High Court in the case of Smt. Shashi Varma

SHARAD KUMAR AGRAWAL,JABALPUR vs. ITO, CHHATARPUR

In the result, the appeal of the assessee is dismissed

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y.-2012-13 Sharad Kumar Agrawal, Chhatarpur Vs Ito, Chhatarpur Jewellers, Madhya Pradesh Pan:Aaspa9540R (Appellant) (Respondent)

section 147 r.w.s. 143(3) of the Income Tax Act passed on 28.12.2019. The grounds of appeal are as under:- “1. The Id CIT (A) erred in sustaining the order of the AO ignoring the request for confronting the statement of brokers, directors and report of the Investigation wing. 2. The Ld CIT (A) erred in sustaining the order

RITA MANCHANI,JABALPUR vs. ITO WARD 2(1), JABALPUR

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

Bench: Shri Anadee Nath Misshra

147 read with section 144B of the Income Tax Act, 1961 (“the Act” for short) and determined the total income of the assessee at Rs.18,41,770/- by making I.T.A. No.60/JAB/2024 Assessment Year:2013-14 2 addition of Rs.5,53,428/- on account of Short Term Capital Gain

JABALPUR DEVELOPMENT AUTHORITY,JABALPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(1), JABALPUR

In the result, appeals filed by the assessee are partly allowed

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.

capital gains arising on the transfer of property for assessment and that admittedly the assessee had requested the officer to accept the original return as a return filed in response to Section 148 of the Act, we hold that there was total failure on the part of the Revenue from complying with the procedure laid down under Section

JABALPUR DEVELOPMENT AUTHORITY,JABALPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(1), JABALPUR

In the result, appeals filed by the assessee are partly allowed

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.

capital gains arising on the transfer of property for assessment and that admittedly the assessee had requested the officer to accept the original return as a return filed in response to Section 148 of the Act, we hold that there was total failure on the part of the Revenue from complying with the procedure laid down under Section

JABALPUR DEVELOPMENT AUTHORITY,JABALPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(1), JABALPUR

In the result, appeals filed by the assessee are partly allowed

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.

capital gains arising on the transfer of property for assessment and that admittedly the assessee had requested the officer to accept the original return as a return filed in response to Section 148 of the Act, we hold that there was total failure on the part of the Revenue from complying with the procedure laid down under Section

JOINT COMMISSIONER OF INCOME TAX (IN- SITU), CENTRAL CIRCLE, JABALPUR, JABALPUR vs. MANISH KUMAR SAROGI, KATNI

Accordingly, the appeals in I.T.A.No.39/JAB/2023, 21/JAB/2019 and 62/JAB/2019 of the Revenue are dismissed for having become in-fructuous

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.

capital gains arising on the transfer of property for assessment and that admittedly the assessee had requested the officer to accept the original return as a return filed in response to Section 148 of the Act, we hold that there was total failure on the part of the Revenue from complying with the procedure laid down under Section

DEPUTY COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE, JABALPUR vs. SHRI MANISH KUMAR SARAOGI, KATNI

Accordingly, the appeals in I.T.A.No.39/JAB/2023, 21/JAB/2019 and 62/JAB/2019 of the Revenue are dismissed for having become in-fructuous

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.

capital gains arising on the transfer of property for assessment and that admittedly the assessee had requested the officer to accept the original return as a return filed in response to Section 148 of the Act, we hold that there was total failure on the part of the Revenue from complying with the procedure laid down under Section

JABALPUR DEVELOPMENT AUTHORITY,JABALPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(1), JABALPUR

In the result, appeals filed by the assessee are partly allowed

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.

capital gains arising on the transfer of property for assessment and that admittedly the assessee had requested the officer to accept the original return as a return filed in response to Section 148 of the Act, we hold that there was total failure on the part of the Revenue from complying with the procedure laid down under Section

INCOME TAX OFFICER, WARD-1, KATNI, KATNI vs. ADITYA AGRAWAL, KATNI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Kul Bharatassessment Year: 2016-17 Income Tax Officer, Ward-1 V. Aditya Agrawal Near New Collectorate, Jhinjhiri- C/O. Shri Ram Food 483501. Product, Industrial Area Bargawan-483501. Pan:Amepa0405H (Appellant) (Respondent) Appellant By: Shri Rahul Badia, Ca Respondent By: Shri N. M. Prasad, Sr. Dr-1 Date Of Hearing: 18 09 2025 Date Of Pronouncement: 30 09 2025 O R D E R

section 10(38) of Income Tax Act, 1961. It has also not been appreciated by the Ld. CIT(A) that the assessee has failed to furnish Form 10DB as required by the Assessing Officer to establish the payment of Security Transaction Tax which would establish the genuinity of the share transaction. 2. Although the tax effect involved in this case