ASTT. COMMISSIONER OF INCOME TAX, LUCKNOW vs. M/S PRAG INDUSTRIES (INDIA) PVT. LTD., LUCKNOW

In the result, appeal of Revenue and Cross Objection of assessee, both are dismissed

Bench: Shri Kul Bharat, Videshri Anadee Nath Misshra

section 40A(2) of the Act, amounting to Rs.8,78,412/- out of payments made to Prag Precision Tools. In the impugned appellate order, the learned CIT(A) deleted the aforesaid addition. The learned CIT(A) has dealt with this issue in paragraphs 9(1) to 9(vii) of his order. His conclusion is reproduced below for ease of reference

NIRMAL SINGH,AYODHYA vs. ITO WARD-1,, FAIZABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria & Sa. No. 07/Lkw/2024 (Arising Out Of Ita. No.83/Lkw/2024 (Assessment Year: 2014-15) Nirmal Singh The Income Tax Officer, V. 15/2/16, Janki Ghat, Ayodhya- Ward-1, 224123, Faizabad (Up). Cinema Road, Faizabad- New-224001. Pan:Bdsps4165C (Appellant) (Respondent) Appellant By: Shri. Rakesh Garg, Adv Respondent By: Shri. Sanjeev Krishna Sharma, Addl. Cit(Dr) Date Of Hearing: 24 09 2024 Date Of Pronouncement: 10 10 2024 O R D E R

14,22,053/- under section 56(2)(vii) and Rs. 49,11,947/- under section 50C, treated as escaped income. The reassessment, being a result of what the AO considers concealed particulars of income, led to the initiation of penalty proceedings under section 271(1)(c) of the Act. The assessee submitted a response to the show cause, citing various

DCIT, RANGE-3, LUCKNOW vs. M/S. PRAYAGRAJ POWER GENERATION COMPANY LTD.,, NOIDA

In the result, ground no. 1 of appeal is dismissed and ground no

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

14 I.T.A. No.393/Lkw/2020 Assessment Year:2016-17 15 (D) At the time of hearing, learned Departmental Representative placed reliance on the assessment order. The learned Counsel for the assessee placed reliance on the impugned order of learned CIT(A). He also placed reliance on the contents of the particulars filed during appellate proceedings in Income Tax Appellate Tribunal, referred

MORADABAD DEVELOPMENT AUTHORITY,MORADABAD vs. DCIT(EXEMPTION), LUCKNOW

In the result, ITA No. 1071/Del/2020, ITA No

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos.273,199/Lkw/2019 A.Ys. 2014-15 & 2015-16 Dy. Commissioner Of Income Tax Vs. M/S Moradabad Development (Exemption), Lucknow Authority, Kanth Road, Moradabad Pan:Aajfm7731M (Appellant) (Respondent)

prices and selling the same land on much higher rates and earning a profit therefrom. It highlighted the new trend of auctioning plots by way of bidding and charging of interest on belated payments, to state that no charity was involved in such activities but rather the assessee had converted itself into a big businessman. Therefore, it held that

MORADABAD DEVELOPMENT AUTHORITY,MORADABAD vs. DCIT(EXEMPTION), LUCKNOW

In the result, ITA No. 1071/Del/2020, ITA No

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos.273,199/Lkw/2019 A.Ys. 2014-15 & 2015-16 Dy. Commissioner Of Income Tax Vs. M/S Moradabad Development (Exemption), Lucknow Authority, Kanth Road, Moradabad Pan:Aajfm7731M (Appellant) (Respondent)

prices and selling the same land on much higher rates and earning a profit therefrom. It highlighted the new trend of auctioning plots by way of bidding and charging of interest on belated payments, to state that no charity was involved in such activities but rather the assessee had converted itself into a big businessman. Therefore, it held that

DY. CIT(EXEMPTION), LUCKNOW vs. MORADABAD DEVELOPMENT AUTHORITY, MORADABAD

In the result, ITA No. 1071/Del/2020, ITA No

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos.273,199/Lkw/2019 A.Ys. 2014-15 & 2015-16 Dy. Commissioner Of Income Tax Vs. M/S Moradabad Development (Exemption), Lucknow Authority, Kanth Road, Moradabad Pan:Aajfm7731M (Appellant) (Respondent)

prices and selling the same land on much higher rates and earning a profit therefrom. It highlighted the new trend of auctioning plots by way of bidding and charging of interest on belated payments, to state that no charity was involved in such activities but rather the assessee had converted itself into a big businessman. Therefore, it held that

MORADABAD DEVELOPMENT AUTHORITY,MORADABAD vs. DY. CIT(EXEMPTION), LUCKNOW

In the result, ITA No. 1071/Del/2020, ITA No

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos.273,199/Lkw/2019 A.Ys. 2014-15 & 2015-16 Dy. Commissioner Of Income Tax Vs. M/S Moradabad Development (Exemption), Lucknow Authority, Kanth Road, Moradabad Pan:Aajfm7731M (Appellant) (Respondent)

prices and selling the same land on much higher rates and earning a profit therefrom. It highlighted the new trend of auctioning plots by way of bidding and charging of interest on belated payments, to state that no charity was involved in such activities but rather the assessee had converted itself into a big businessman. Therefore, it held that

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

14 of 21 under section 68 of the Act was that the assessee had violated the Notification No.S.O.3408(E) dated 08.11.2016 issued by the Reserve Bank of India, wherein legal character of the SBNs in the denomination of Rs.500/- and Rs.1,000/- was withdrawn w.e.f. 08.11.2016 and, thus, the assessee was not authorized by the Government of India to collect

M/S AYODHYA DEVELOPMENT AUTHORITY(FORMERLY AYODHYA FAIZABAD DEVELOPMENT AUTHORITY),AYODHYA vs. THE DY. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

14 of the Constitution and because of this order, since the assessee did not remain a public trust but rather was one in violation of section 13(3) of the Act, the claim made by the assessee under section 11 was not maintainable. The ld. AO also made additions on account of depreciation claimed

M/S AYODHYA DEVELOPMENT AUTHORITY (FORMELY AYODHYA FAIZABAD DEVELOPMENT AUTHORITY),LUCKNOW vs. THE DY. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW, LUCKNOW

In the result all six appeals filed by the assessee are partly allowed

14 of the Constitution and because of this order, since the assessee did \nnot remain a public trust but rather was one in violation of section 13(3) of the Act, the claim \nmade by the assessee under section 11 was not maintainable. The ld. AO also made additions on \naccount of depreciation claimed of Rs.31

M/S AYODHYA FAIZABAD DEVELOPEMENT AUTHORITY,FAIZABAD vs. DY. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

14 of the Constitution and because of this order, since the assessee did \nnot remain a public trust but rather was one in violation of section 13(3) of the Act, the claim \nmade by the assessee under section 11 was not maintainable. The ld. AO also made additions on \naccount of depreciation claimed of Rs.31

M/S AYODHYA FAIZABAD DEVELOPEMENT AUTHORITY,FAIZABAD vs. DY. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

14 of the Constitution and because of this order, since the assessee did \nnot remain a public trust but rather was one in violation of section 13(3) of the Act, the claim \nmade by the assessee under section 11 was not maintainable. The ld. AO also made additions on \naccount of depreciation claimed of Rs.31

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

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal [Chief Commissioner or Chief Commissioner or Principal] Commissioner or Commissioner,— a) the order is passed without making inquiries or verification which should have been made; Page

SHYAM SUNDER GUPTA,KANPUR vs. DY. COMMISSIONER OF INCOME TAX-1, KANPUR

In the result, the appeal of the assessee is dismissed

14 September, 2001\nEquivalent citations: 2002 254 ITR 216 SC Bench: S Bharucha, y\nSabharwal ORDER 1. Leave granted.\nThe Tribunal had declined to make a reference, at the instance of the\nRevenue, of the following question:\n\"Whether, on the facts and in the circumstances of the case, the Income-tax\nAppellate Tribunal was legally correct in upholding

SHILPA KHANDELWAL,BAREILLY vs. DEPUTY COMMISSIONER OF INCOME TAX-2, BAREILLY

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

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2015-16 Smt. Shilpa Khandelwal V. The Dy. Cit-2 330, Kalibari Bareilly Bareilly (U.P) Tan/Pan:Arypk5700A (Appellant) (Respondent) Appellant By: Shri P. K. Kapoor, C.A. Respondent By: Shri Sanjeev Krishna Sharma, D.R. Date Of Hearing: 27 02 2025 Date Of Pronouncement: 24 04 2025 O R D E R

transferred to assessee given by M/s Shalibhadra Steel Pvt. Ltd. in response to notice issued under section 133(6) of the Act. (9) Dematerialisation request Form dated 27.05.2014 for dematerializing 3000 shares of M/s Kapрас Pharma Ltd. (10) Contract Note-cum-Bill dated 12.11.2014 for sale of 3000 shares of M/s Kapрас Pharma Ltd. ITA No.313/LKW/2023 Page

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

In the result, ITA No. 374/LKW/2017 is partly allowed while ITA No

price prevailing in the market and this cash was being carried by Mr. Mehtab Alam. The bank was requested to issue a certificate for the aforementioned purpose. Consequent to this search, the case of the assessee was centralized with the DCIT, Central Circle-I, Kanpur on 23.03.2012. Subsequently, it was transferred to the DCIT, Central Circle-II. Prior to this

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

In the result, ITA No. 374/LKW/2017 is partly allowed while ITA No

price prevailing in the market and this cash was being carried by Mr. Mehtab Alam. The bank was requested to issue a certificate for the aforementioned purpose. Consequent to this search, the case of the assessee was centralized with the DCIT, Central Circle-I, Kanpur on 23.03.2012. Subsequently, it was transferred to the DCIT, Central Circle-II. Prior to this

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.

transfer of an asset. Accordingly, applying the provisions of section 50C, he held reasons to believe that assessee’s income chargeable to tax of Rs. 1,10,72,650/- had escaped assessment during the assessment year 2015-16 by virtue of the proviso of Explanation 2(a) of section 147. 3. In response to the said notice, the assessee filed