ITO, WARD-2(3)(1), KANPUR, KANPUR vs. KHANNA SALES (INDIA) PVT. LTD., KANPUR

In the result, the appeal of the Revenue is dismissed

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2017-18 Ito, Vs. Khanna Sales (India) Pvt. Ltd., Ward-2(3)(1), Kanpur 54/34, Nayaganj, Kanpur Pan: Aabck4442N (Appellant) (Respondent) Assessee By: Sh. Swarn Singh, C.A. Revenue By: Sh. Amit Kumar, Addl. Cit Dr Date Of Hearing: 20.11.2025 Date Of Pronouncement: 16.02.2026 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Revenue Against The Orders Of The Ld. Cit(A), Nfac Wherein The Ld. Cit(A) Has Allowed The Appeal Of The Assessee Against The Orders Of The Ld. Ao Passed Under Section 143(3) For The A.Y. 2017- 18 On 29.12.2019. The Grounds Of The Appeal Are As Under: - “1- Ld. Cit (A) Has Erred In Law & Facts By Not Appreciating The Pattern Of Cash Sales Discussed By The Assessing Officer In Detail In His Order Which Shows A Substantial Jump Of 38% Of Total Sales In The Month Of October, 2016 I.E. The Period Immediately Prior To Demonetization In November, 2016. Cash Sales Before & After This Period Is Negligible. 2. That The Appellant Craves Leave To Add Or Amend Any One Or More Of The Grounds Of Appeal As Stated Above As & When Need For Doing So May Arise. 3. Ld. Cit(A) Has Erred In Law & Facts In Deleting The Addition Of 3 Rs. 2,64.19.000/- On Account Of Cash Deposits U/S 68 Of The Income Tax Act 1961. 4. Ld. Cit(A) Has Erred In Law & Facts By Not Appreciating That U/S 68 The Ao Is Not Required To Reject The Books Of Accounts. The Only Requirement Is That, If The Explanation Offered By The Assessee Is Not, In The Opinion Of The Assessing Officer Satisfactory, The Sum (Cash Sales) So Credited Can Be Charged To Income-Tax As The Income Of The Assessee Of That Previous Year.”

deposit cash at regular intervals of substantial amounts. Thus, the contention that assessee had substantial cash in hand was not acceptable and only Rs. 19,00,000/- of the amount of Rs. 2,83,19,000/- was explained. Therefore, he disallowed

LALJI YADAV,LUCKNOW vs. INCOME TAX OFFICER- 6(2), LUCKNOW

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

disallowed agricultural income. The CIT(A) upheld these additions. The assessee failed to provide explanations or evidence for the deposits and agricultural income.", "held": "The Tribunal condoned the delay in filing the appeal. It noted the assessee's non-cooperation and failure to provide explanations for huge cash

PAPPU SONKAR,LUCKNOW vs. ITO-3(3), LUCKNOW-NEW

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

Bench: Shri Kul Bharat & Shri Anadee Nath Misshraassessment Year: 2017-18 Pappu Sonkar Ito-3(3) V. 538/2/220, Tirveni Nagar, Lucknow New-226001. Sitapur Road, Near Devki Hospital, Lucknow-226020. Pan:Czcps8771H (Appellant) (Respondent) Appellant By: Shri Ashwani Jaiswal, C.A. Respondent By: Shri Sunil Kumar Rajwanshi, Addl. Cit(Dr) Date Of Hearing: 10 12 2024 Date Of Pronouncement: 13 12 2024 O R D E R

cash deposits. The Assessing Officer made assessment u/s 144 of the Act thereby assessing the income at Rs.3,03,18,775/-. Aggrieved by this, the assessee preferred an appeal before the Ld. CIT(A) who also dismissed the appeal. Now, the assessee is in appeal before this Tribunal. 3. Apropos to the grounds of appeal, the Ld. Counsel

RANJEET SINGH,LUCKNOW vs. D/ACIT-4, LUCKNOW

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

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2017-18 Ranjeet Singh, Vs. The Dcit / Acit-4, 459, Ameer Nagar, Aishbagh, Lucknow-226001 Lucknow-226004 Pan: Afsps0877G (Appellant) (Respondent) Assessee By: Sh. Rakesh Garg, Advocate Revenue By: Sh. Amit Kumar, Dr Date Of Hearing: 23.07.2025 Date Of Pronouncement: 16.10.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac Dated 22.03.2024, Wherein The Ld. Cit(A) Has Dismissed The Appeals Of The Assessee Against The Orders Of The Ld. Assessing Officer Passed On 21.12.2019. The Grounds Of Appeal Are As Under: - “01. Because The Cit(A) Has Erred On Facts & In Law In Upholding An Addition Of Rs.31,90,000/- Being Cash Deposited In Bank During Demonetization Period As Unexplained, The Same Is Contrary To Facts, Bad In Law, Be Deleted. 02. Because The Entire Cash Deposited In Bank Is Part Of The Sale Proceeds & Realization Of Debts, The Addition Made Is Purely On Suspicions & Surmises, Such Addition Is Contrary To Facts, Bad In Law, Be Deleted. 03. Because There Being No Change In The Method Of Accounting Regularly Followed By The Assessee & The Same Having Being Consistently Accepted, The Books Of Account Having Not Been Rejected, The Stock Tally Not Disputed, The Accounts Being Tax Audited, There Was No Reason For The Ao To Disbelieve The Cash Deposited In The Bank Treating The Same As Unexplained, The Addition Of Rs.31,90,000/- Upheld By The Cit(A) Be Deleted. 04. Because The Amount Of Rs.31,90,000/- Being Cash Deposited In Bank Being Part Of Sale Proceeds & Cash Receipts Already Charged To Revenue For The Purposes Of Computation Of Income, Separate Addition Of The Same Has Resulted Into Double Taxation, Not Permitted By Law, The Addition Made Be Deleted.

cash deposited in bank as unexplained, the same be deleted. 06. Because the CIT(A) has erred on facts and in law in upholding the addition of Rs. 13,82,437/-, being 25% of the entire indirect expenses debited to P&L Account on adhoc basis without pointing out any defect in the same which disallowance

SHRI PANKAJ VERMA,LUCKNOW vs. DCIT, RANGE-1, LUCKNOW

In the result, I.T.A. No.390/Lkw/2020 is partly allowed while I

deposited in cash in the bank during this period or uptill\n08/11/2016, where he had further received Rs.10,22,089/- from debtors.\nTherefore, it was submitted that he had necessary cash in hand to make the\ndeposit of Rs.1,35,00,000/- into the said account. Learned A.R. also invited\nour attention to page 97 of his paper book which

PRECIOUS BJUILDTECH PRIVATE LIMITED,BAREILLY vs. PCIT, , BAREILLY

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

Bench: Shri Kul Bharat & Shri Nikhil Choudharyआयकर अपील सं/ Ita No.66/Lkw/2022 ननिाारण वर्ा/ Assessment Year: 2017-18 Precious Buildtech Pvt Ltd V. Pcit Harmony Apartment, Adiacent Income Tax Department, To Bedi International School, Bareilly-243001. Dental College Road, Pilibhit Bypass Road, Bareilly-243001. Pan:Aagcp1255R अपीलार्थी/(Appellant) प्रत्यर्थी/(Respondent) अपीलार्थी कक और से/Appellant By: Shri Rakesh Garg, Adv प्रत्यर्थी कक और से /Respondent By: Shri Mazhar Akram, Cit(Dr) सुनवाई कक तारीख / Date Of Hearing: 24 07 2025 घोर्णा कक तारीख/ Date Of 30 09 2025 Pronouncement: आदेश / O R D E R

deposits during demonetization period as inflated cash balance in cash book appears to fail the tests of both genuineness and human probabilities. The AO should have placed is reliance-on. The case of Sumati Dayal Vs CIT (214 ITR 801) wherein the Apex court. propounded the principle of human probabilities and applying it in that case held that whether apparent

ACIT, RANGE-1, LUCKNOW vs. SHRI PANKAJ VERMA, LUCKNOW

In the result, I.T.A. No.390/Lkw/2020 is partly allowed while I

deposited in cash in the bank during this period or uptill\n08/11/2016, where he had further received Rs.10,22,089/- from debtors.\nTherefore, it was submitted that he had necessary cash in hand to make the\ndeposit of Rs.1,35,00,000/- into the said account. Learned A.R. also invited\nour attention to page 97 of his paper book which

HARSAHAIMAL SHIAMLAL JEWELLERS PVIVATE LIMITED,BAREILLY vs. PCIT(CENTRAL), BAREILLY

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

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2017-18 Harsahaimal Shiamlal Jewellers Shri Vimalendu Verma, Private Limited, 148, Civil Lines, Vs. Pcit (Central), Lucknow, U.P. Bareilly, U.P.-243001 Pan:Aacch3785L (Appellant) (Respondent) Assessee By: Sh. Rakesh Garg, Adv Revenue By: Sh. S.H. Usmani, Cit Dr Date Of Hearing: 06.08.2024 Date Of Pronouncement: 25.10.2024 O R D E R Per Sh. Nikhil Choudhary: This Is An Appeal Filed Against The Order Under Section 263 Of The Act, Passed By The Ld. Pcit, Central ,Lucknow On 17.02.2022, Setting Aside The Orders Of The Ld. Assessing Officer, Passed Under Section 143(3) Of The Income Tax Act On 29.07.2019. The Grounds Of Appeal Preferred, Are As Under:-

deposit during demonetization period”. The ld. AO records that the assessee furnished computation of income, balance-sheet, income and expenditure account, bank statements, ledger accounts, details of investments, TDS details and other required details of the case from time to time. He further records that, during the course of scrutiny, the assessee furnished the replies to all the queries raised

SITA RAM RASTOGI,LAKHIMPUR KHERI vs. INCOME TAX OFFICER, WARD 3(5),, LAKHIMPUR KHERI

In the result, the appeal of the assessee stands allowed

Bench: Shri. A. D. Jainassessment Year: 2017-18 Sita Ram Rastogi V. The Ito Prop. M/S Shyam Jewellers Ward 3(5) Lakhimpur Kheri Lakhimpur Kheri Tan/Pan:Agapr6341R (Appellant) (Respondent) Appellant By: Shri K. R. Rastogi, C.A. Respondent By: Shri Harish Gidwani, D.R. Date Of Hearing: 05 09 2022 Date Of Pronouncement: 08 09 2022 O R D E R This Is Assessee’S Appeal Against The Order Of The Ld. Cit(A), Nfac, New Delhi, Dated 26.11.2021, For The Assessment Year 2017-18, Raising The Following Grounds Of Appeal: 1. That The Learned Income Tax Officer Made An Addition Of Rs.19,10,000/- As Un Explained Cash Deposit In The Books Maintained By The Assessee Whereas There Is No Such Single Deposit In The Books. 2. That The Additions Of Rs.15,688/- & Rs.5,693/- Have Been Made Without Any Basis Which Are Simply The Guess Work & Therefore Not Justified. 3. That The Learned Income Tax Officer Has Not Pointed Out Any Mistake Or Discrepancy In The Books Of Account As Is Evident From His Order In Paras 3 To 6 & Straight Away Made Up His Mind To Make Addition As Is Evident From His Observation Below Para 6 Of His Order. 4. That The Appellant Had Explained The Availability Of Funds (Old Sbn'S), Which Was Accepted By The Assessing Officer.

deposit on 18.11.2016, was generated in old SBNs during the demonetization period and was illegally accepted by the assessee. 17. In ‘ACIT vs. M/s Hirapanna Jewellers’ (supra), on an identical issue, the ITAT, Visakhapatnam Bench, placing reliance on various judgments of the Hon'ble Supreme Court and High Courts, held that the cash receipts represent the sales which the Page

MOHAMMAD MOIN,KANPUR vs. CIT(A), NFAC, KANPUR

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

Bench: Shri Anadee Nath Misshramohammad Moin V. National E-Assessment A-25, New Sabji Mandi, Centre Chakarpur, Kanpur-208002. Delhi. Pan: Afopm8226M (Appellant) (Respondent) Appellant By: None Respondent By: Shri Amit Kumar, Cit(Dr) O R D E R

disallowance in the hand of agents/customers u/d 40A (3) of the Act and due to non submission of confirmed copy of account with PAN. It is also pertinent to note that the learned AO had accepted the deposits of cash

PRADEEP KUMAR,LUCKNOW vs. ACIT-1, LUCKNOW

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

Bench: Shri G. D. Padamahshali & Shri Subhash Malguriaassessment Year: 2017-18 Pradeep Kumar V. The Acit-1 A-1/46, Vikas Khand Lucknow Gomti Nagar Lucknow Pan:Ablpk8392B (Appellant) (Respondent) Appellant By: Shri Vijay Prakash Agrawal, Adv. Respondent By: Shri Sanjeev Krishna Sharma, D.R. Date Of Hearing: 10 07 2024 Date Of Pronouncement: 04 09 2024 O R D E R

cash deposit is not from books. The addition u/s 68 can be made only for credit entries from the books of account. 4. The learned Assessing Officer and learned CIT (Appeals) failed to appreciate that the quantum of sales claimed by the Appellant was also supported purchases, stock, VAT Return, audit report etc. 5. The order of the learned Assessing

ROHILKHAND EDUCATIONAL CHARITABLE TRUST,BAREILLY vs. DCIT, CENTRAL CIRCLE, BAREILLY

In the result, both appeals of the assessee in ITA No

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos.181 & 182/Lkw/2024 A.Ys.2017-18 & 2018-19 Rohilkhand Educational Vs. Dcit, Charitable Trust, Bareilly Central Circle, Bareilly Pan: Aaatr6902J (Appellant) (Respondent) Assesseeby: Sh. Rakesh Garg, Adv Revenue By: Sh. S.H. Usmani, Cit Dr Date Of Hearing: 14.08.2025 Date Of Pronouncement: 22.09.2025 O R D E R Per Bench: [ These Two Appeals Have Been Filed By The Assessee Against The Separate Orders Of The Ld. Cit(A)-3, Lucknow Dated 19.03.2024 & 22.03.2024, Passed Under Section 250 Of The Income Tax Act, 1961, For The A.Ys. 2017-18 & 2018-19, Dismissing The Appeals Of The Assessee Against Orders Passed By The Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961. The Grounds Of Appeal Are As Under:- “(1).That The Ld. Authorities Below Have Erred In Law As Well As On Facts In Not Considering The Fact That In The Alleged Assessment Order, The Columns Of Name Of Assessee, Pan, Asst Year, Date Of Assessment & Section Under Which Passed, Are Blank. (2)That The Ld. Authorities Below Have Erred In Law As Well As On Facts In Treating The Demand As Valid Which Was Not Computed On The Basis Of Orderthat May Not Be Termed To Be An Order Under Section 143(3). (3) That A Demand Of Tax As Computed In The Computation Sheet Is Without Jurisdiction Void-Ab-Inito & Is Liable To Be Annulled. (4) That The Ld. Authorities Below Have Erred In Law As Well As On Facts In Confirming The Addition Of Rs. 736591857/-Comprising  Corpus Donation Aggregating To Rs 7,68,95,000/-, A.Ys. 2017-18 & 2018-19

cash deposited during the demonetization period had rightly been added back to the income of the assessee. On the disallowance

GURDAS MAL ARORA,KANPUR vs. THE A O CIRCLE-1(2)(1), KANPUR

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

Bench: Shri Kul Bharat & Shri Anadee Nath Misshragurdas Mal Arora V. The Assessing Officer, 21/L/4, Daboli, Circle-1(2)(1) Kanpur. 16/69, Aayakar Bhawan, Civil Lines, Kanpur- 208001. Pan:Afepm4342J (Appellant) (Respondent) Appellant By: Shri Ashish Jaiswal, Advocate Respondent By: Shri Amit Kumar, Cit-Dr O R D E R

cash deposit made by the assessee in the bank. Further, an addition of Rs.23,06,000/- by way of disallowance

ANANT KUMAR,BARABANKI vs. INCOME TAX OFFICER, BARABANKI

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

Bench: SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY (Accountant Member)

cash deposited in bank account out of the sale proceeds alleging the same to be income chargeable to tax under section 68 of the Income Tax Act, 1961. 2. That the Learned CIT(A) erred in confirming the addition of ₹ 1,51,473/- made by the Learned Assessing Officer by disallowing

PRIYA KANT SINGH,LUCKNOW vs. ACIT, RANGE-1, LUCKNOW

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

Bench: Sh. Sudhanshu Srivastava & Sh. Anadee Nath Misshraa.Y. 2017-18 Priya Kant Singh, Vs. Income Tax Officer 1/428, Vishal Khand, Gomti (Exemption), Lucknow, The Nagar, Lucknow, U.P. Jurisdictional Assessing Officer Pan:Aaatb4391F (Appellant) (Respondent) Assessee By: Sh. B.P. Yadav, Advocate Revenue By: Sh. Sanjeev Krishna Sharma, Addl. Cit (Dr) Date Of Hearing: 16.04.2025 Date Of Pronouncement: 24.04.2025 O R D E R Per Sudhanshu Srivastava, J.M.: This Is An Appeal Filed By The Assessee Against The Order Passed By The Ld. Cit(A) On 24.04.2024 Under Section 250 Of The Income Tax Act, 1961. The Grounds Of Appeal Preferred By The Assesse Are As Under:- “1. The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (Hereinafter Referred To As The "Ld. Cit (A)") Has Erred On Facts & In Law In Dismissing The Appeal Of The Appellant Ex-Parte Without Appreciating The Legal Aspects Pertaining To The Case Of The Assessee & Also Without Looking Into The Merit Of The Additions Made By The Ld. A.O. 2. On The Undemoted Facts The Ld. Cit (A) Was Not Justified At All In Dismissing The Appeal Of The Appellant. Because No Notice Of Hearing Was Served On The Appellant Either On Her Postal Address Or On The Ernail-Id Provided In The Appeal Memo.

deposits made into the bank accounts were on account of sale proceeds received in cash which stood duly recorded in the books of the appellant and offered to tax. 5. The Ld. CIT (A) has erred on facts and in law in confirming the addition of Rs.27,97,338/- made by Ld. A.O. In the hands of the appellant

UP GOVERNMENT EMPLOYEES WELFARE,LUCKNOW vs. ACIT, NFAC, DELHI, DELHI

In the result appeals in ITA No

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharyita Nos.743 & 746/Lkw/2024 & Ita No. 30/Lkw/2024 A.Y. 2017-18 U.P. Government Employees Vs. Assessing Officer, Nfac Welfare, Lucknow Pan:Aaatu0957A (Appellant) (Respondent) Assessee By: None Revenue By: Sh. Manu Chaurasia, Cit (Dr) Date Of Hearing: 15.04.2025 Date Of Pronouncement: 30.04.2025 O R D E R Per Bench.: These Three Appeals Have Been Filed By The Assessee Against The Orders Passed By The Ld. Cit(A), Nfac On 23.10.2024, 28.10.2024 & 2.01.2024 In The Appeals Preferred Against The Assessment Order Under Section 143(3), The Penalty Order Under Section 271Aac(1) & The Penalty Order Under Section 270A. The Grounds Of Appeal In These Three Appeals Are As Under:-

cash deposits that were made during the demonetization period. It explained its difficulties by pointing out that it had sent follow up letter to all the depots and family bazars but not received replies and therefore, was unable to furnish the details. It furnished copies of purchase ledgers, discount, salary, allowance benefits and wages paid during the year, VAT paid

ROHILKHAND EDUCATIONAL CHARITABLE TRUST,BAREILLY vs. DCIT, CENTRAL CIRCLE, BAREILLY

In the result, both appeals of the assessee in ITA No

deposit\nhad been made out of known and genuine sources, accordingly she held that cash\ndeposited during the demonetization period had rightly been added back to the\nincome of the assessee. On the disallowance

VIKAS SINGH ,PILIBHIT vs. ITO, PILIBHIT

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

Bench: Sh. Kul Bharat & Sh. Nikhil Choudhary

deposit made in bank during the year cannot be treated as unexplained money u/s 69A and cannot be added in appellant income. 4. Any other ground as deem fit at the time of hearing of appeal.” 2. The facts of the case are that the assessee is a Arhatia (dealer in wholesale and commission sales of food grains), who sells