ADITI EXPRESS CARGO INDIA PRIVATE LIMITED THROUGH ITS ERSTWHILE DIRECTOR PRASHANT NATWARLAL LAKHANI,NAGPUR vs. DCITACIT CIRCLE-3 , NAGPUR

In the result, all the captioned seven appeal are allowed for statistical purposes

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Reassessment notices would have been served to him then this situation would not have arised.. 6. No Live Link: The Assessing officer has failed to establish live link with the information and tangible material and have also failed to establish the role of the Appellant herein with the alleged parties mentioned in the SCN and subsequently they have passed

ADITI EXPRESS CARGO INDIA PRIVATE LIMITED,NAGPUR vs. DCIT ACIT CIRCLE -3, NAGPUR

In the result, all the captioned seven appeal are allowed for statistical purposes

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Reassessment notices would have been served to him then this situation would not have arised.. 6. No Live Link: The Assessing officer has failed to establish live link with the information and tangible material and have also failed to establish the role of the Appellant herein with the alleged parties mentioned in the SCN and subsequently they have passed

ADITI EXPRESS CARGO INDIA PRIVATE LIMITED,NAGPUR vs. DCIT ACIT CIRCLE -3, , NAGPUR

In the result, all the captioned seven appeal are allowed for statistical purposes

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Reassessment notices would have been served to him then this situation would not have arised.. 6. No Live Link: The Assessing officer has failed to establish live link with the information and tangible material and have also failed to establish the role of the Appellant herein with the alleged parties mentioned in the SCN and subsequently they have passed

ADITI EXPRESS CARGO INDIA PRIVATE LIMITED,NAGPUR vs. DCIT ACIT CIRCLE -3, NAGPUR

In the result, all the captioned seven appeal are allowed for statistical purposes

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Reassessment notices would have been served to him then this situation would not have arised.. 6. No Live Link: The Assessing officer has failed to establish live link with the information and tangible material and have also failed to establish the role of the Appellant herein with the alleged parties mentioned in the SCN and subsequently they have passed

ADITI EXPRESS CARGO INDIA PRIVATE LIMITED,NAGPUR vs. DCIT ACIT CIRCLE -3, NAGPUR

In the result, all the captioned seven appeal are allowed for statistical purposes

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Reassessment notices would have been served to him then this situation would not have arised.. 6. No Live Link: The Assessing officer has failed to establish live link with the information and tangible material and have also failed to establish the role of the Appellant herein with the alleged parties mentioned in the SCN and subsequently they have passed

ADITI EXPRESS CARGO INDIA PRIVATE LIMITED THROUGH ITS ERSTWHILE DIRECTOR PRASHANT NATWARLAL LAKHANI,NAGPUR vs. DCIT ACIT CIRCLE-3, NAGPUR

In the result, all the captioned seven appeal are allowed for statistical purposes

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Reassessment notices would have been served to him then this situation would not have arised.. 6. No Live Link: The Assessing officer has failed to establish live link with the information and tangible material and have also failed to establish the role of the Appellant herein with the alleged parties mentioned in the SCN and subsequently they have passed

ADITI EXPRESS CARGO INDIA PRIVATE LIMITED THROUGH ITS ERSTWHILE DIRECTOR PRASHANT NATWARLAL LAKHANI,NAGPUR vs. DCIT ACIT CIRCLE-3, NAGPUR

In the result, all the captioned seven appeal are allowed for statistical purposes

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Reassessment notices would have been served to him then this situation would not have arised.. 6. No Live Link: The Assessing officer has failed to establish live link with the information and tangible material and have also failed to establish the role of the Appellant herein with the alleged parties mentioned in the SCN and subsequently they have passed

SUNRISE STRUCTURALS & ENGINEERING PVT LTD,NAGPUR vs. ASSISTANT/ DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-4 NAGPUR, NAGPUR

In the result, appeal filed by the assessee stands allowed

Bench: Shri Pawan Singh & Shri Khettra Mohan Roysunrise Structural & Acit/Dcit, Circle-4, Engineering P. Ltd., A10, Vs Nagpur Hingna Midc, Nagpur (Urban), Nagpur-440016 Pan : Aaccs 3220 M Assessee Respondent Assessee By : Shri K.P. Dewani, Advocate Revenue By : Shri Surjit Kumar Saha, Sr. Dr Date Of Hearing : 25.02.2026 Date Of Pronouncement : 10.04.2026 O R D E R

section 234B and 234C of I.T. Act 1961 is unjustified, unwarranted and excessive. 9) Any other ground shall be prayed at the time of hearing.” 5. The assessee submitted the following submissions along with the paper book for consideration. 3.1 Ground No.1: Notice u/s 148 of I.T. Act 1961 is not in accordance with law:- A) Notice u/s 148A

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

Section 153A only on the basis of some\nincriminating material unearthed during the course of search or requisition of\ndocuments or undisclosed income or property discovered in the course of\nsearch which were not produced or not already disclosed or made known in\nthe course of original assessment which is not in the case of assessee.\n(4) On contrary

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

In the result, assessee' appeal for A

Section 153A only on the basis of some incriminating material unearthed during the course of search or requisition of documents or undisclosed income or property discovered in the course of search which were not produced or not already disclosed or made known in the course of original assessment which is not in the case of assessee. (4) On contrary

ATUL MANOHARRAO YAMSANWAR,NAGPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE 2(1), NAGPUR

reassessment shall be passed by an Assessing Officer below the rank of Joint Commissioner in respect of each assessment year referred..... except with the prior approval of the Joint Commissioner.” 20. The emphasis supplied in the above excerpt of section 153D above, is to highlight the intent of the legislature regarding the necessity of application of mind to the draft

UMESH SADASHIV THAKRE ,NAGPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(1), NAGPUR

reassessment shall be passed by an Assessing Officer below the rank of Joint Commissioner in respect of each assessment year referred..... except with the prior approval of the Joint Commissioner.” 20. The emphasis supplied in the above excerpt of section 153D above, is to highlight the intent of the legislature regarding the necessity of application of mind to the draft

UMESH SADASHIV THAKRE ,NAGPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(1), NAGPUR

reassessment shall be passed by an Assessing\nOfficer below the rank of Joint Commissioner in respect of each assessment\nyear referred..... except with the prior approval of the Joint Commissioner.”\n20. The emphasis supplied in the above excerpt of section 153D above, is to\nhighlight the intent of the legislature regarding the necessity of application of\nmind to the draft

UMESH SADASHIV THAKRE ,NAGPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(1), NAGPUR

reassessment shall be passed by an Assessing\nOfficer below the rank of Joint Commissioner in respect of each assessment\nyear referred..... except with the prior approval of the Joint Commissioner.”\n20. The emphasis supplied in the above excerpt of section 153D above, is to\nhighlight the intent of the legislature regarding the necessity of application of\nmind to the draft

YRCE EDUCATE PVT. LTD,NAGPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(1), NAGPUR

reassessment shall be passed by an Assessing\nOfficer below the rank of Joint Commissioner in respect of each assessment\nyear referred..... except with the prior approval of the Joint Commissioner.”\n20. The emphasis supplied in the above excerpt of section 153D above, is to\nhighlight the intent of the legislature regarding the necessity of application of\nmind to the draft

ATUL MANOHARRAO YAMSANWAR,NAGPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE 2(1), NAGPUR

In the result, all the appeals filed by the assessee are allowed and all\nthe appeals filed by the Revenue are dismissed

reassessment shall be passed by an Assessing\nOfficer below the rank of Joint Commissioner in respect of each assessment\nyear referred..... except with the prior approval of the Joint Commissioner.”\n20. The emphasis supplied in the above excerpt of section 153D above, is to\nhighlight the intent of the legislature regarding the necessity of application of\nmind to the draft

ATUL MANOHARRAO YAMSANWAR,NAGPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE 2(1), NAGPUR

In the result, all the appeals filed by the assessee are allowed and all\nthe appeals filed by the Revenue are dismissed

reassessment shall be passed by an Assessing\nOfficer below the rank of Joint Commissioner in respect of each assessment\nyear referred..... except with the prior approval of the Joint Commissioner.”\n20. The emphasis supplied in the above excerpt of section 153D above, is to\nhighlight the intent of the legislature regarding the necessity of application of\nmind to the draft

UMESH SADASHIV THAKRE ,NAGPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(1), NAGPUR

reassessment shall be passed by an Assessing Officer below the rank of Joint Commissioner in respect of each assessment year referred..... except with the prior approval of the Joint Commissioner.”\n20.\nThe emphasis supplied in the above excerpt of section 153D above, is to highlight the intent of the legislature regarding the necessity of application of\nmind to the draft