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

1,65,07,560, the ACIT\nfailed to notice the error.\n12. This aspect was brought to the fore by the Tribunal in the impugned\norder. The Trib, thus, concluded there was a complete lack of application of\nmind, inasmuch as the ACIT, who granted approval, failed to notice the said\nerror.\n12.1. More particularly, the Tribunal notes that

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

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

1 SCC 248 and SL Kapoor v. Jagmohan (1980)\n4 SCC 379).\n30. As already noted above, the expression "civil consequences”\nencompasses infraction of not merely property or personal rights but of civil\nliberties, material deprivations and non-pecuniary damages. Anything which\naffects a citizen in his civil life comes under its wide umbrella. Accordingly,\nwe reject the argument

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

1 SCC 248 and SL Kapoor v. Jagmohan (1980)\n4 SCC 379).\n30. As already noted above, the expression "civil consequences”\nencompasses infraction of not merely property or personal rights but of civil\nliberties, material deprivations and non-pecuniary damages. Anything which\naffects a citizen in his civil life comes under its wide umbrella. Accordingly,\nwe reject the argument

UMESH SADASHIV THAKRE ,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

1,65,07,560, the ACIT\nfailed to notice the error.\n12. This aspect was brought to the fore by the Tribunal in the impugned\norder. The Trib, thus, concluded there was a complete lack of application of\nmind, inasmuch as the ACIT, who granted approval, failed to notice the said\nerror.\n12.1. More particularly, the Tribunal notes that

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

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

1,65,07,560, the ACIT\nfailed to notice the error.\n12. This aspect was brought to the fore by the Tribunal in the impugned\norder. The Trib, thus, concluded there was a complete lack of application of\nmind, inasmuch as the ACIT, who granted approval, failed to notice the said\nerror.\n12.1. More particularly, the Tribunal notes that

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

1 SCC 248 and SL Kapoor v. Jagmohan (1980)\n4 SCC 379).\n30. As already noted above, the expression "civil consequences”\nencompasses infraction of not merely property or personal rights but of civil\nliberties, material deprivations and non-pecuniary damages. Anything which\naffects a citizen in his civil life comes under its wide umbrella. Accordingly,\nwe reject the argument

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

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

1 SCC 248 and SL Kapoor v. Jagmohan (1980)\n4 SCC 379).\n30. As already noted above, the expression \"civil consequences”\nencompasses infraction of not merely property or personal rights but of civil\nliberties, material deprivations and non-pecuniary damages. Anything which\naffects a citizen in his civil life comes under its wide umbrella. Accordingly,\nwe reject the argument

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

1 in appeal of the assessee is allowed in all these 34\nappeals filed by the assessee holding that approval granted u/s153D is\nwithout application of mind and hence, the assessment orders are annulled.”\n(x) Subhash Bhawnani v. DCIT (2023) 37 NYPTTJ 807 (Indore-Trib)\ndt.25-5-23, ITA Nos. 38 to 40/Ind/2020; AY12-13, 16-17 & 17-18,\nheld that

YRCE EDUCATE PVT. LTD,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

1 in appeal of the assessee is allowed in all these 34\nappeals filed by the assessee holding that approval granted u/s153D is\nwithout application of mind and hence, the assessment orders are annulled.”\n(x) Subhash Bhawnani v. DCIT (2023) 37 NYPTTJ 807 (Indore-Trib)\ndt.25-5-23, ITA Nos. 38 to 40/Ind/2020; AY12-13, 16-17 & 17-18,\nheld that

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

1 SCC 248 and SL Kapoor v. Jagmohan (1980)\n4 SCC 379).\n30. As already noted above, the expression "civil consequences”\nencompasses infraction of not merely property or personal rights but of civil\nliberties, material deprivations and non-pecuniary damages. Anything which\naffects a citizen in his civil life comes under its wide umbrella. Accordingly,\nwe reject the argument

CHANDRAKUMAR MADHUSUDANJI JAJODIA,THANE vs. ASSISTANT COMMISSIONER OF INCOME TAX, AMRAVATI CIRCLE

In the result, appeal filed by the assessee is allowed

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

reassessment is general in nature and is not on specific transaction of assessee. Evidence placed on record is not found to be incorrect or false. Conclusion of escapement of income tantamount to mere change of opinion. Belief of escapement of income could not be derived on the basis of report of Investigation Wing being not specific to transaction of loan

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

1 & 2) [Vol.-IV]. Detailed documentary evidence was placed on record on 09/03/2023 to explain the various observations made in the notice u/s 148A(a) of I.T. Act demonstrating genuineness and bonafides of purchase transaction (P- 3 to 7) [Vol.- IV). B) A.O. without verification and application of mind has issued notice u/s 148A