ACIT, RANGE-1, LUCKNOW vs. MOTOR FAB SALES PVT. LTD., LUCKNOW

In the result, Departmental appeal bearing

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2017-18 M/S Motor Fab Sales Pvt. Ltd. V. The Dcit/Acit-4 11, Mahatma Gandhi Marg Lucknow Hazratganj, Lucknow Tan/Pan:Aaccm5754E (Appellant) (Respondent) Assessment Year: 2017-18 Theacit-1 V. M/S Motor Fab Sales Pvt. Ltd. Lucknow 11, Mahatma Gandhi Marg Hazratganj, Lucknow Tan/Pan:Aaccm5754E (Appellant) (Respondent) Assessee By: Shri Rakesh Garg, Advocate Revenue By: Shri H.S. Usmani, Cit(Dr)

D minus C) F Less: PMGKY declaration 2,25,10,000.00 G Unexplained cash deposit out of 17,50,26,651.00 bogus cash receipts 2.1 The AO, accordingly, completed the assessment under section 143(3) of the Income Tax Act, 1961 (hereinafter called “the Act’) by making addition of Rs.17,50,26,650/- under section 68

M/S. MAA RAKLTDANTIKA CONTRACTORS AND SUPPLIERS PVT. LTD.,,LUCKNOW vs. THE DCIT/ACIT, RANGE-4, LUCKNOW

In the result, the appeal filed by the Revenue is dismissed and the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

D) The assessee is in the business of contractors and material suppliers. The aforesaid additions of Rs.8,30,40,000/- and Rs.2,48,16,616/- made u/s 68 of the IT Act by the Assessing Officer pertain to the assessee’s business of sale of Maurang. As regards the quantity of Maurang sold by the assessee, the following submissions were

ACIT, RANGE-1, LUCKNOW vs. MAA RAKTDANTIKA CONTRACTORS AND SUPPLIERS PVT. LTD., LUCKNOW

In the result, the appeal filed by the Revenue is dismissed and the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

D) The assessee is in the business of contractors and material suppliers. The aforesaid additions of Rs.8,30,40,000/- and Rs.2,48,16,616/- made u/s 68 of the IT Act by the Assessing Officer pertain to the assessee’s business of sale of Maurang. As regards the quantity of Maurang sold by the assessee, the following submissions were

M/S APCO INFRATECH PVT. LTD.,LUCKNOW vs. D/ACIT-1,CENTRAL-1, LUCKNOW

In the result, appeals vide

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

17-18 A.C.I.T.-1, Vs. M/s APCO Infratech Pvt. Ltd., (Central-1), B-9, Vibhuti Khand, Lucknow Gomti Nagar, Lucknow. PAN:AADCA5639H (Appellant) (Respondent) I.T.A. No.623/Lkw/2024 Assessment Years:2018-19 A.C.I.T.-1, Vs. M/s APCO Infratech Pvt. Ltd., (Central-1), B-9, Vibhuti Khand, Lucknow Gomti Nagar, Lucknow. PAN:AADCA5639H (Appellant) (Respondent) C.O.No.01/Lkw/2025 ( in I.T.A. No.623/Lkw/2024 Assessment Years

ASSTT. COMMISSIONER OF INCOME TAX, CC-1, LUCKNOW, AAYAKAR BHAWAN, ASHOK MARG, LUCKNOW vs. APCO INFRATECH PVT. LTD., VIBHUTI KHAND GOMTI NAGAR LKO

In the result, appeals vide

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

17-18 A.C.I.T.-1, Vs. M/s APCO Infratech Pvt. Ltd., (Central-1), B-9, Vibhuti Khand, Lucknow Gomti Nagar, Lucknow. PAN:AADCA5639H (Appellant) (Respondent) I.T.A. No.623/Lkw/2024 Assessment Years:2018-19 A.C.I.T.-1, Vs. M/s APCO Infratech Pvt. Ltd., (Central-1), B-9, Vibhuti Khand, Lucknow Gomti Nagar, Lucknow. PAN:AADCA5639H (Appellant) (Respondent) C.O.No.01/Lkw/2025 ( in I.T.A. No.623/Lkw/2024 Assessment Years

M/S. APCO INFRATECH PVT. LTD.,LUCKNOW vs. ACIT-1, LUCKNOW

In the result, appeals vide

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

17-18 A.C.I.T.-1, Vs. M/s APCO Infratech Pvt. Ltd., (Central-1), B-9, Vibhuti Khand, Lucknow Gomti Nagar, Lucknow. PAN:AADCA5639H (Appellant) (Respondent) I.T.A. No.623/Lkw/2024 Assessment Years:2018-19 A.C.I.T.-1, Vs. M/s APCO Infratech Pvt. Ltd., (Central-1), B-9, Vibhuti Khand, Lucknow Gomti Nagar, Lucknow. PAN:AADCA5639H (Appellant) (Respondent) C.O.No.01/Lkw/2025 ( in I.T.A. No.623/Lkw/2024 Assessment Years

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

d). On the issue of accumulation under section 11(2), the ld. CIT DR invited our attention to paragraph 10.6.3 of the order of the ld. CIT(A) in which he pointed out that the ld. CIT(A)had elaborately discussed why specification of purpose was a requirement of section 11(2) of the Act and generality

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

In the result, appeals vide I

17-18\n\nA.C.I.T.-1,\n(Central-1),\nLucknow\n(Appellant)\nVs.\nM/s APCO Infratech Pvt. Ltd.,\nB-9, Vibhuti Khand,\nGomti Nagar,\nLucknow.\nPAN:AADCA5639H\n(Respondent)\n\nI.T.A. No.623/Lkw/2024\n Assessment Years:2018-19\n\nA.C.I.T.-1,\n(Central-1),\nLucknow\n(Appellant)\nVs.\nM/s APCO Infratech Pvt. Ltd.,\nB-9, Vibhuti Khand,\nGomti Nagar,\nLucknow.\nPAN:AADCA5639H

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

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

d). On the issue of accumulation under section 11(2), the ld. CIT DR invited our attention to paragraph 10.6.3 of the order of the ld. CIT(A) in which he pointed out that the ld. CIT(A)had elaborately discussed why specification of purpose was a requirement of section 11(2) of the Act and generality

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, RANGE-1, LUCKNOW., LUCKNOW. vs. M/S. MG AUTOSALES PRIVATE LIMITED, LUCKNOW.

The appeal is partly allowed for statistical purposes

Bench: Shri Kul Bharat & Shri Anadee Nath Misshradcit, Circle-1 M/S. Mg Autosales Pvt Ltd V. Pratyaksh Kar Bhawan, 57, 3/44 Ambalika, Gokhale Ramtirath Marg, Lucknow- Vihar Marg, Lucknow- 226001. 226001. Pan:Aamcs0717R (Appellant) (Respondent) Appellant By: Shri Ashok Seth, C.A. Respondent By: Shri Sunil Kumar Rajwanshi, Addl. Cit(Dr) Date Of Hearing: 11 12 2024 O R D E R

D E R PER ANADEE NATH MISSHRA, A.M.: 1. The present appeal has been filed by Revenue challenging the impugned order dated 15/06/2022 passed by the learned Commissioner of Income Tax (Appeals) [hereinafter referred as “CIT(A)”]/National Faceless Appeal Centre (NFAC), Delhi for the assessment year 2017-18. In this appeal, Revenue has raised the following grounds

TACK EXIM PVT. LTD.,KANPUR vs. ACIT CIRCLE2(3)(1), KANPUR

The appeal of the assessee stands allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2017-18 Tack Exim Pvt. Limited V. Asstt. Commissioner Of 11/18-A, Pokharpur Income Tax, Jajmau, Kanpur Circle 2(3)(1), Kanpur Tan/Pan:Aadct7929D (Appellant) (Respondent) Appellant By: Shri Rakesh Garg, Advocate Respondent By: Shri Sanjeev Krishna Sharma, D.R. Date Of Hearing: 02 09 2024 Date Of Pronouncement: 29 11 2024 O R D E R

5. On and from the appointed day, no person shall, knowingly or voluntarily, hold, transfer or receive any specified bank note: Provided that nothing contained in this section shall prohibit the holding of specified bank notes- (a) by any person- (i) up to the expiry of the grace period; or (ii) after the expiry of the grace period

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BAREILLY, BAREILLY vs. VARUNARJUN TRUST, LUCKNOW

In the result, both the appeals are dismissed

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

5. The assessee filed detailed submission along with necessary evidences and proofs explain the fact that the donations were received though banking channel and all the records were duly maintained. The amount of donations so received was utilised for charitable purpose. The enquiries about the donations were made under section 133(6) also during original assessment proceedings and proceedings

ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE), BAREILLY vs. VARUNARJUN TRUST, LUCKNOW

In the result, both the appeals are dismissed

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

5. The assessee filed detailed submission along with necessary evidences and proofs explain the fact that the donations were received though banking channel and all the records were duly maintained. The amount of donations so received was utilised for charitable purpose. The enquiries about the donations were made under section 133(6) also during original assessment proceedings and proceedings

M/S U.P STATE INDUSTRIAL DEVELOPMENT CORPORATION LTD.,KANPUR vs. ASTT. COMMISSIONER OF INCOME TAX-VI, KANPUR

Bench: Sh. Subhash Malguria & Sh. Nikhil Choudharyinterest Tax Appeal Nos.3 & 4/Lkw/2004 A.Ys.1995-96 & 1996-97

d) Rs.9,66,47,048: in relation to premium payable by the allottees of Industrial Sheds/sites aggregating Rs.11,75,75,706 and in upholding the liability of the appellant to that extent. 7.2 BECAUSE none of the two sums as mentioned above can be treated as 'chargeable interest' under section 2(5) of the Act read with the definition

M/S U.P STATE INDUSTRIAL DEVELOPMENT CORPORATION LTD.,KANPUR vs. ASTT. COMMISSIONER OF INCOME TAX-VI, KANPUR

d) Rs.9,66,47,048: in relation to premium payable by the allottees of Industrial Sheds/sites aggregating Rs. 11,75,75,706 and in upholding the liability of the appellant to that extent. 7.2 BECAUSE none of the two sums as mentioned above can be treated as 'chargeable interest' under section 2(5) of the Act read with

DY. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S SHRI RAMSWAROOP CHARITABLE TRUST, LUCKNOW

In the result, appeal of the Revenue stands dismissed

Bench: Shri A. D. Jain & Shri T. S. Kapoorassessment Year:2014-2015

5, Learned D. R. submitted that the Assessing Officer had made the addition on account of anonymous donations as the assessee could not establish the identity and capability/financial status of the donors and learned CIT(A) was not justified in deleting the addition made by the Assessing Officer. 16. Learned A. R., on the other hand, supported the order

ASTT. COMMISIONER OF INCOME TAX, LUCKNOW vs. M/S APCO INFRATECH PVT. LTD., LUCKNOW

In the result, appeal of the Revenue and Cross Objection of the assessee are dismissed, as indicated above

Bench: Shri G. D. Padamahshali & Shri Subhash Malguriaassessment Year: 2014-15 The Asstt. Commissioner V. M/S Apco Infratech Pvt. Ltd Of Income Tax B-9, Vibhuti Khand Central Circle Ii Gomti Nagar Lucnow Lucknow Pan:Aadca5639H (Appellant) (Respondent) C.O. No.19/Lkw/2017 [In Ita No.66/Lkw/2017] Assessment Year: 2014-15 M/S Apco Infratech Pvt. Ltd V. The Asstt. Commissioner Of B-9, Vibhuti Khand Income Tax Gomti Nagar Central Circle Ii Lucknow Lucnow Pan:Aadca5639H (Cross Objector) (Respondent)

68,60,927/- under Chapter VI-A of the Act. The assessee thereafter again revised its return of income on 21.3.2016 wherein the assessee claimed deduction of Rs.4,66,10,927/- under section 80IA of the Act. The Assessing Officer was of the view that deduction under section 80IA of the Act is allowable only if return

DY. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S SHRI RAMSWAROOP CHARITABLE TRUST, LUCKNOW

In the result, appeal of the Revenue is dismissed

Bench: Shri A.D Jain & Shri T.S. Kapoora.Y. 2013-14

68 of the Act as the assessee was not able to explain the unexplained credit. It was further argued that against the addition of Rs.8,57,31,152/- the assessee could produce ledger account and vouchers for Rs.7,69,08,761/- only. 6. As regards Ground No.4, the ld. DR stated that the Assessing Officer had made the disallowance