VINAI SHUKLA,LUCKNOW vs. ACIT-1, LUCKNOW NEW, LUCKNOW

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

Bench: Shri Kul Bharat & Shri Nikhil Choudharyआयकर अपील सं/ Ita No.624/Lkw/2024 ननिाारण वर्ा/ Assessment Year: 2017-18 Vinai Shukla V. Acit-1, Lucknow New 2/280, Vikas Khand Gomti Lucknow Nagar, Lucknow-226010. Pratyaksh Kar Bhawan, Lucknow-226001. Pan:Asnps3558C अपीलार्थी/(Appellant) प्रत्यर्थी/(Respondent) अपीलार्थी कक और से/Appellant By: Ms Shweta Mittal, Ca प्रत्यर्थी कक और से /Respondent By: Shri Prajesh Srivastava, Sr. Dr सुनवाई कक तारीख / Date Of Hearing: 21 08 2025 घोर्णा कक तारीख/ Date Of 12 09 2025 Pronouncement: आदेश / O R D E R

reassessment or re-computation, in conformity with such order of the Transfer Pricing Officer, within two months from the end of the month in which such order of the Transfer Pricing Officer is received by him.] (6)Nothing contained in sub-sections (1) and (2

KAMAL KANT VERMA,HAPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-II, KANPUR

In the result, all the appeals are allowed

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

2. In this regard reliance has been placed on the statement of Sh. Madho Gopal Agarwal recorded on oath under section 132(4) of the Act on 3rd August, 2015 and letter dated 31st July, 2015 issued by Sh. Madho Gopal Agarwal. The case was centralised as per the orders passed under section 127 of the Act and a notice

SACHIN VERMA,HAPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - II, KANPUR

In the result, all the appeals are allowed

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

2. In this regard reliance has been placed on the statement of Sh. Madho Gopal Agarwal recorded on oath under section 132(4) of the Act on 3rd August, 2015 and letter dated 31st July, 2015 issued by Sh. Madho Gopal Agarwal. The case was centralised as per the orders passed under section 127 of the Act and a notice

M/S STANDARD FROZEN FOODS EXPORTS PVT LTD,HAPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CC-II, KANPUR

In the result, all the appeals are allowed

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

2. In this regard reliance has been placed on the statement of Sh. Madho Gopal Agarwal recorded on oath under section 132(4) of the Act on 3rd August, 2015 and letter dated 31st July, 2015 issued by Sh. Madho Gopal Agarwal. The case was centralised as per the orders passed under section 127 of the Act and a notice

U.P.COOPERATIVE FEDERATIONLTD,LUCKNOW vs. ITO-2(3), , LUCKNOW

In the result, the appeal of the assessee is dismissed

Bench: Shri Kul Bharat & Shri Anadee Nath Misshraआयकर अपील सं/ Ita No.260/Lkw/2023 ननिाारण वर्ा/ Assessment Year: 2003-04 U.P. Cooperative Federation V. Income Tax Officer-2(3) Ltd Pratyaksh Kar Bhawan, Pcf Building, 32, Station Road, 57, Ram Tirath Marg, Lucknow-226004. Hazratganj, Lucknow- 226001. Pan:Aaaau0373P अपीलार्थी/(Appellant) प्रत्यर्थी/(Respondent) अपीलार्थी कक और से/Appellant By: Shri D. D. Chopra, Advocate प्रत्यर्थी कक और से /Respondent By: Shri Neeraj Kumar, Cit(Dr) सुनवाई कक तारीख / Date Of Hearing: 22 09 2025 घोर्णा कक तारीख/ Date Of 19 12 2025 Pronouncement: आदेश / O R D E R

2) shall not apply to the following classes of assessments, reassessments and re-computations which may, [subject to the provisions of sub-section (2A)] be completed at any time – (ii) where the assessment, re-assessment or recomputation is made on the assessee or any person in consequence of or to give effect to any finding or direction contained

ACIT, CIRCLE 3, LUCKNOW, LUCKNOW vs. ANSHUMAN SINGH, LUCKNOW

In the result, the appeal of Revenue is allowed

section 144B of the Income Tax Act, 1961 was passed by the National Faceless Assessment Centre against which the appellant is under appeal.\n\nISSUES:\nRegarding addition of Rs.1,31,63,190/-\n\nGround No. 1,2,5,6 & 7 of appeal:\n\nGround No. 1:\nThat having regard to the facts and circumstances of the case

M/S FIVE ROSES,KANPUR vs. J/DCIT-CC,, KANPUR

In the result, all the three appeals are partly allowed for statistical purposes

Bench: Shri. Sudhanshu Srivastava & Shri Anadee Nath Misshra

reassessment order u/s 147 of the Act had been passed by the Assessing Officer without issuing the mandatory notice under section 143(2) of the Act, the ld. "CIT(A)" should have held the re-assessment order as illegal, bad in law and without jurisdiction. 6

M/S FIVE ROSES,KANPUR vs. DY, CIT-CC-1, KANPUR

In the result, all the three appeals are partly allowed for statistical purposes

Bench: Shri. Sudhanshu Srivastava & Shri Anadee Nath Misshra

reassessment order u/s 147 of the Act had been passed by the Assessing Officer without issuing the mandatory notice under section 143(2) of the Act, the ld. "CIT(A)" should have held the re-assessment order as illegal, bad in law and without jurisdiction. 6

M/S FIVE ROSES,KANPUR vs. DY, CIT-CC-1, KANPUR

In the result, all the three appeals are partly allowed for statistical purposes

Bench: Shri. Sudhanshu Srivastava & Shri Anadee Nath Misshra

reassessment order u/s 147 of the Act had been passed by the Assessing Officer without issuing the mandatory notice under section 143(2) of the Act, the ld. "CIT(A)" should have held the re-assessment order as illegal, bad in law and without jurisdiction. 6

ACIT, RANGE-I, LUCKNOW vs. M/S APCO INFRATECH PVT. LTD.,, LUCKNOW

Reassessment Proceeding.\nDt. 27.06.2022, 20.07.2022, 03.08.2022, 09.01.2023,\n16.02.2023 03.03.2023, 16.03.2023, 21.03.2023 & 22.03.2023\n6. Copy of Replies filed before CIT(Appeal)\n1. Written Submission dt. 14.06.2024\n2. Written Submission dt. 16.08.2024\nITA NO. 356/LKW./2020\nITA NO. 453/LKW./2020\nA.Y. 2016-17\nPAPER BOOK\nIN\nAPCO INFRATECH PVT. LTD., LUCKNOW\nINDEX\nS.L.\nNo.\nPARTICULARS\n1.\nCopy of Return of Income

ASSISTANT COMMISIONER OF INCOME TAX, CENTRAL CIRCLE, BAREILLY, BAREILLY vs. MOHIT ANAND, BAREILLY

Appeals of the Department stand dismissed

Bench: Shri Sudhanshu Srivastava & Shri Nikhil Choudharyit(Ss) A Nos.336 & 337/Lkw/2025 Assessment Years: 2014-15 & 2015-16 Acit, Central Circle, Bareilly Vs. Ankur Anand Kamla Nehru Marg, Civil Lines, 148 Civil Lines, Bareilly, Bareilly, Bareilly-243001. Bareilly-243001. Tan/Pan:Agppa4219C (Appellant) (Respondent) It(Ss)A No.334/Lkw/2025 Assessment Year:2015-16 Acit, Central Circle, Bareilly Vs. Mohit Anand Kamla Nehru Marg, Civil Lines, 148 Civil Lines, Bareilly, Bareilly, Bareilly-243001. Bareilly-243001. Tan/Pan:Abupa3002H (Appellant) (Respondent)

6. Whether on the facts and circumstances of the case and in law, the CIT(A) erred in ignoring the decision of the Hon hie High Court of Calcutta in the case of PCIT us Swati Bajaj [2022] 139 taxmann.com 352 (Calcutta) wherein the Hon hie Court has held that “a holistic approach is required to be made

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BAREILLY, BAREILLY vs. ANKUR ANAND, BAREILLY

Appeals of the Department stand dismissed

Bench: Shri Sudhanshu Srivastava & Shri Nikhil Choudharyit(Ss) A Nos.336 & 337/Lkw/2025 Assessment Years: 2014-15 & 2015-16 Acit, Central Circle, Bareilly Vs. Ankur Anand Kamla Nehru Marg, Civil Lines, 148 Civil Lines, Bareilly, Bareilly, Bareilly-243001. Bareilly-243001. Tan/Pan:Agppa4219C (Appellant) (Respondent) It(Ss)A No.334/Lkw/2025 Assessment Year:2015-16 Acit, Central Circle, Bareilly Vs. Mohit Anand Kamla Nehru Marg, Civil Lines, 148 Civil Lines, Bareilly, Bareilly, Bareilly-243001. Bareilly-243001. Tan/Pan:Abupa3002H (Appellant) (Respondent)

6. Whether on the facts and circumstances of the case and in law, the CIT(A) erred in ignoring the decision of the Hon hie High Court of Calcutta in the case of PCIT us Swati Bajaj [2022] 139 taxmann.com 352 (Calcutta) wherein the Hon hie Court has held that “a holistic approach is required to be made

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BAREILLY, BAREILLY vs. ANKUR ANAND, BAREILLY

Appeals of the Department stand dismissed

Bench: Shri Sudhanshu Srivastava & Shri Nikhil Choudharyit(Ss) A Nos.336 & 337/Lkw/2025 Assessment Years: 2014-15 & 2015-16 Acit, Central Circle, Bareilly Vs. Ankur Anand Kamla Nehru Marg, Civil Lines, 148 Civil Lines, Bareilly, Bareilly, Bareilly-243001. Bareilly-243001. Tan/Pan:Agppa4219C (Appellant) (Respondent) It(Ss)A No.334/Lkw/2025 Assessment Year:2015-16 Acit, Central Circle, Bareilly Vs. Mohit Anand Kamla Nehru Marg, Civil Lines, 148 Civil Lines, Bareilly, Bareilly, Bareilly-243001. Bareilly-243001. Tan/Pan:Abupa3002H (Appellant) (Respondent)

6. Whether on the facts and circumstances of the case and in law, the CIT(A) erred in ignoring the decision of the Hon hie High Court of Calcutta in the case of PCIT us Swati Bajaj [2022] 139 taxmann.com 352 (Calcutta) wherein the Hon hie Court has held that “a holistic approach is required to be made

VIKAS JAIN,KANPUR vs. ACIT-CC 2(1)(1), KANPUR

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

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2015-16 Vikas Jain, Vs. The Acit, H-2/1, Kidwai Nagar, Kanpur- Circle 2(1)(1), Kanpur 208001 208006 Pan: Abqpj8049R (Appellant) (Respondent) Assessee By: Sh. Rakesh Garg, Adv Revenue By: Sh. Amit Kumar, Dr Date Of Hearing: 07.10.2025 Date Of Pronouncement: 31.12.2025 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 On 17.05.2024 Wherein The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee Against The Order Passed By The Ld. Assessing Officer Under Section 147 R.W.S. 143(3) For The A.Y. 2015-16 On 27.12.2018. The Grounds Of Appeal Are As Under:- “01. Because There Being No Reason To Believe, Far From There Being Any Material To Form Reasons To Believe, The Proceedings Initiated Right From Issue Of Notice U/S. 148 & The Re-Assessment Framed Thereof Are All Without Jurisdiction Bad In Law, The Order Passed Be Quashed. 02. Because The So-Called Reasons Having Been Recorded Applying Explanation 2(A) To Section 147, Of The Act Which Not Being Applicable, The Very Reason To Believe Being Contrary To The Mandate Of The Section, The Proceedings- Initiated U/S 148, The Reassessment Framed Are All Contrary To The Provisions Of Law, Be Quashed. 03. Because The Approval Given By The Competent Authority U/S 151, Being Mechanical In Nature Without Verification Of Facts, The Notice Issued U/S 148 & The Reassessment Framed Thereafter Be Quashed.

reassessment framed thereafter be quashed. 1 Vikas Jain A.Y. 2015-16 04. Because the NFAC has erred on facts and in law in upholding the addition of Rs.21,12,500/- u/s 50C of the Act which addition is contrary to facts, bad in law, be deleted. 05. Because the NFAC has failed to appreciate the facts and circumstances

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, KANPUR., KANPUR vs. M/S. SUSHRUT INSTITUTE OF PLASTIC SURGERY PRIVATE LIMITED, LUCKNOW

The appeal of the Department stands dismissed whereas the Cross Objection of the assessee stands allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2019-20 The Acit V. M/S Sushrut Institute Of Plastic Central Circle 2 Surgery Private Limited Kanpur 29, Shahmeena Road Lucknow Tan/Pan:Aaics2582G (Appellant) (Respondent) C.O. No.15/Lkw/2023 [Arising Out Of Ita No.30/Lkw/2023] Assessment Year: 2019-20 M/S Sushrut Institute Of Plastic V. The Acit Surgery Private Limited Central Circle 2 29, Shahmeena Road Kanpur Lucknow Tan/Pan:Aaics2582G (Cross - Objector) (Respondent)

reassessment is required to be made in accordance with the provisions of section 153A. Explanation.-- In this section, "Valuation Officer" has the same meaning as in clause (r) of section 2 of the Wealth-tax Act, 1957 (27 of 1957)." The Section was inserted by the Finance (No.2) Act, 2004 with effect from 15.11.1972 to confer power on the Assessing

ISHRAT BEG,SITAPUR vs. ITO, SITAPUR

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

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2017-18 Ishrat Beg V. The Income Tax Officer S/O Akhtar Beg Sitapur Katra Astal, Laharpur Sitapur (U.P) Tan/Pan:Aoypb5773P (Appellant) (Respondent) Appellant By: Shri K. R. Rastogi, C.A. Respondent By: Shri Saurabh Dubey, D.R. O R D E R

6 of 9 assessee had, in fact, not even made any compliance during the course of assessment proceedings and as the assessment order would show, the same was passed under section 144 of the Act due to reason of non-compliance by the assessee. The Ld. Sr. D.R. also submitted that in the immediately preceding year, the Tribunal

M/S. APCO INFRATECH PVT. LTD.,,LUCKNOW vs. ACIT-I, LUCKNOW

In the result, appeals vide I

Reassessment Proceeding.\n27.06.2022, 20.07.2022, 03.08.2022, 09.01.2023,\n16.02.2023 03.03.2023, 16.03.2023, 21.03.2023 & 22.03.2023\n6.\nCopy of Replies filed before CIT(Appeal)\n1. Written Submission dt. 14.06.2024\n2. Written Submission dt. 16.08.2024\n\nITA NO. 356/LKW./2020\nITA NO. 453/LKW./2020\nA.Y. 2016-17\nPAPER BOOK\nIN\nAPCO INFRATECH PVT. LTD., LUCKNOW\nINDEX\n\nS.L.\nNo.\nPARTICULARS\n1.\nCopy of Return of Income

DHIRENDRA PRATAP,LUCKNOW vs. INCOME TAX OFFICER-3(2), WARD-3(2), HARDOI

In the result, the appeal of the assessee stands allowed

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2011-12 Dhirendra Pratap V. The Income Tax Officer A-16/1052, Sector 15 Ward 3(2) Near Vasundhra Complex Hardoi Indira Nagar, Lucknow (U.P) Tan/Pan:Ayepp3148C (Applicant) (Respondent) Applicant By: Shri Rakesh Garg, Advocate Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 19.12.2024, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2011-12. 2.0 The Brief Facts Of The Case Are That The Assessee Filed His Return Of Income For The Year Under Consideration On 06.11.2018 Declaring A Total Income Of Rs.1,75,750/-. The Income Tax Department Was In Possession Of Information That The Assessee Had Deposited Cash To The Tune Of Rs.19,81,000/- In His Bank Account. The Assessing Officer (Ao) Issued A Query Letter Under Section 133(6) Of The Income Tax Act, 1961 (Hereinafter Called “The Act’) On 04.01.2018, Requiring The Assessee To Furnish The Source Of Cash Deposits Along With Other Evidentiary Proof, In Response To Which The Assessee Filed Reply On 07.02.2018. Since

6) of the Income Tax Act, 1961 (hereinafter called “the Act’) on 04.01.2018, requiring the assessee to furnish the source of cash deposits along with other evidentiary proof, in response to which the assessee filed reply on 07.02.2018. Since ITA No.467/LKW/2025 Page 2 of 7 the AO was not satisfied with the reply furnished by the assessee, he reopened