M/S MODEL TANNERS (INDIA) PVT. LTD.,KANPUR vs. ASTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, KANPUR

In the result, both the appeals are partly allowed

Bench: Shri. A. D. Jain & Shri T. S. Kapoor

disallowance of Rs.26,24,573/- under section 80-IB of the Act; interest of Rs.1,699/- on TDS and addition of Rs.36,310/- under section 14A of the Act, were not the subject matter of either the notice issued, or the order passed under section 263 of the Act. 17. In “CIT vs. D.N. Dosani”, 280 ITR 275

M/S MODEL TANNERS (INDIA) PVT. LTD.,KANPUR vs. ASTT. COMMISSIONER OF INCOME TAX, KANPUR

In the result, both the appeals are partly allowed

Bench: Shri. A. D. Jain & Shri T. S. Kapoor

disallowance of Rs.26,24,573/- under section 80-IB of the Act; interest of Rs.1,699/- on TDS and addition of Rs.36,310/- under section 14A of the Act, were not the subject matter of either the notice issued, or the order passed under section 263 of the Act. 17. In “CIT vs. D.N. Dosani”, 280 ITR 275

BHARTIYA JAN SEWA ASHRAM,JAUNPUR vs. INCOME TAX OFFICER (EXEMPTION), LUCKNOW

Bench: Shri Kul Bharat & Shri, Nikhil Choudhary

section 68 of the Act); (3) grants in question had been received for 'specified purpose' which was in conformity with the objects of the “appellant society" and the same being fully verifiable from utilization, reports, surplus and other related information as had duly been placed on record during the course of assessment/appellate proceedings and on a due consideration

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.”

disallowed the balance of Rs. 2,64,19,000/- and added the same back under section 68 of the Income Tax Act. 4 Khanna Sales (India) Pvt. Ltd. A.Y. 2017-18 3. Aggrieved with the said order passed by the ld. AO, the assessee filed an appeal before the NFAC. The ld. CIT(A), NFAC observed that

ASTT. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

Bench: Shri A. D. Jain & Shri T. S. Kapoor

disallowing the exemption claimed and assessing to tax the income of the assessee and the appellate authorities were justified in confirming the same. In such circumstances, we Page 36 of 242 (UP AWAS EVAM VIKAS PARISHAD) don’t see any question of law arising in these appeals to be considered by this Court under Section 260(A) of the Income

ASTT. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

Bench: Shri A. D. Jain & Shri T. S. Kapoor

disallowing the exemption claimed and assessing to tax the income of the assessee and the appellate authorities were justified in confirming the same. In such circumstances, we Page 36 of 242 (UP AWAS EVAM VIKAS PARISHAD) don’t see any question of law arising in these appeals to be considered by this Court under Section 260(A) of the Income

ASTT. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

Bench: Shri A. D. Jain & Shri T. S. Kapoor

disallowing the exemption claimed and assessing to tax the income of the assessee and the appellate authorities were justified in confirming the same. In such circumstances, we Page 36 of 242 (UP AWAS EVAM VIKAS PARISHAD) don’t see any question of law arising in these appeals to be considered by this Court under Section 260(A) of the Income

ASTT. COMMISIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

Bench: Shri A. D. Jain & Shri T. S. Kapoor

disallowing the exemption claimed and assessing to tax the income of the assessee and the appellate authorities were justified in confirming the same. In such circumstances, we Page 36 of 242 (UP AWAS EVAM VIKAS PARISHAD) don’t see any question of law arising in these appeals to be considered by this Court under Section 260(A) of the Income

ASTT. COMMISIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

Bench: Shri A. D. Jain & Shri T. S. Kapoor

disallowing the exemption claimed and assessing to tax the income of the assessee and the appellate authorities were justified in confirming the same. In such circumstances, we Page 36 of 242 (UP AWAS EVAM VIKAS PARISHAD) don’t see any question of law arising in these appeals to be considered by this Court under Section 260(A) of the Income

ASTT. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

Bench: Shri A. D. Jain & Shri T. S. Kapoor

disallowing the exemption claimed and assessing to tax the income of the assessee and the appellate authorities were justified in confirming the same. In such circumstances, we Page 36 of 242 (UP AWAS EVAM VIKAS PARISHAD) don’t see any question of law arising in these appeals to be considered by this Court under Section 260(A) of the Income

ASTT. COMMISIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

Bench: Shri A. D. Jain & Shri T. S. Kapoor

disallowing the exemption claimed and assessing to tax the income of the assessee and the appellate authorities were justified in confirming the same. In such circumstances, we Page 36 of 242 (UP AWAS EVAM VIKAS PARISHAD) don’t see any question of law arising in these appeals to be considered by this Court under Section 260(A) of the Income

ASTT. COMMISIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

Bench: Shri A. D. Jain & Shri T. S. Kapoor

disallowing the exemption claimed and assessing to tax the income of the assessee and the appellate authorities were justified in confirming the same. In such circumstances, we Page 36 of 242 (UP AWAS EVAM VIKAS PARISHAD) don’t see any question of law arising in these appeals to be considered by this Court under Section 260(A) of the Income

RAKESH KUMAR PANDEY,GONDA vs. DCIT/ACIT (CENTRAL)-2, LUCKNOW

In the result, the outcome of the appeals and Cross Objections are as under:

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

disallowed, the net profit rate of 11% applied by the Assessing Officer is too high when appellant has shown comparatively higher profit margin of 10.13% and 9.68% in subsequent years i.e. A.Y. 2021-22 and A.Y. 2022- 23 to cover up the deficiencies of unproved sundry creditors/remission of liabilities found during search proceeding. Therefore, I am of the considered view

ACIT, CENTRAL CIRCLE-II, LUCKNOW, LUCKNOW vs. RAKESH KUMAR PANDEY, GONDA U.P.

In the result, the outcome of the appeals and Cross Objections are as under:

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

disallowed, the net profit rate of 11% applied by the Assessing Officer is too high when appellant has shown comparatively higher profit margin of 10.13% and 9.68% in subsequent years i.e. A.Y. 2021-22 and A.Y. 2022- 23 to cover up the deficiencies of unproved sundry creditors/remission of liabilities found during search proceeding. Therefore, I am of the considered view

RAKESH KUMAR PANDEY,GONDA vs. DCIT/ACIT (CENTRAL)-2, LUCKNOW

In the result, the outcome of the appeals and Cross Objections are as under:

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

disallowed, the net profit rate of 11% applied by the Assessing Officer is too high when appellant has shown comparatively higher profit margin of 10.13% and 9.68% in subsequent years i.e. A.Y. 2021-22 and A.Y. 2022- 23 to cover up the deficiencies of unproved sundry creditors/remission of liabilities found during search proceeding. Therefore, I am of the considered view

PURNAGIRI RICE MILLS,SHAHJAHANPUR vs. INCOME TAX OFFICER, SHAHJAHANPUR

In the result, the appeal of the assessee is allowed

Bench: Shri Kul Bharat & Shri Nikhil Choudharyआयकर अपील सं/ Ita No.251/Lkw/2017 ननिाारण वर्ा/ Assessment Year: 2007-08 Purnagiri Rice Mills, V. Income Tax Officer Meeran Pur Katra, Range-1(5), Shahajhanpur-242301. Shahajhanpur-242301. Pan:Aahfp6663R अपीलार्थी/(Appellant) प्रत्यर्थी/(Respondent) अपीलार्थी कक और से/Appellant By: Shri Saurabh Gupta, Ca प्रत्यर्थी कक और से /Respondent By: Shri R. R. N. Shukla, Addl. Cit(Dr) सुनवाई कक तारीख / Date Of Hearing: 28 10 2025 घोर्णा कक तारीख/ Date Of 26 11 2025 Pronouncement: आदेश / O R D E R

disallowances of Rs.2,75,939/- and Rs.6,95,618/- being the unverifiable paddy purchase expenses and amount of bonus paid on paddy Page 4 of 12 purchases respectively. Aggrieved against this, the assessee preferred an appeal before the Ld. CIT(A), who sustained the additions. Now, the assessee is in appeal before this Tribunal. 6. Ground

SMT. ANJU BANGER,KANPUR vs. INCOME TAX OFFICER, KANPUR

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

Bench: Shri. A. D. Jain & Shri T. S. Kapoorassessment Year: 2005-06 Smt. Anju Banger V. The Ito Prop. M/S Shree Balaji Syntex Ward 2 (1) C-50, Udyog Kunj Kanpur Panki Industrial Estate, Site V Kanpur Tan/Pan:Aaqpb0526J (Appellant) (Respondent) Appellant By: Shri Pradeep Seth, Fca Respondent By: Shri C. K. Singh, D.R. Date Of Hearing: 03 09 2019 Date Of Pronouncement: 06 09 2019 O R D E R Per A. D. Jain, V.P.: This Is Assessee’S Appeal Against The Order Of The Ld. Cit(A)-I, Kanpur, Dated 18/1/2016, For Assessment Year 2005-06, Taking The Following Grounds: 1) That The Learned Cit (Appeals) Has Erred In Law & On Fact In Confirming Disallowance Of Rs.27,760/- Being Adhoc/Estimated Disallowance Of 10% Out Of Various Expenses Under The Heads Sales Promotion, Travelling Expenses, Conveyance Expenses, General Expenses, Generator Rent & Maintenance Expenses, Repairs & Office Expenses 2) That The Learned Cit (Appeals) Has Further Erred In Law & On Fact In Ignoring The Fact That The Assessee Had Not Disputed The Disallowance Out Of Telephone Expenses & That The Bills & Vouchers In Respect Of The Expenses Under The Aforesaid Heads Were Available But Were Never Required To Be Produced.

disallowance out of telephone expenses and that the bills and vouchers in respect of the expenses under the aforesaid heads were available but were never required to be produced. ITA No.169/LKW/2016 Page 2 of 9 3) That the learned CIT (Appeals) has further erred in law and on facts in changing entirely the basis of addition and in confirming