CIT v. Ram Singh (220 CTR 629)

INCOME TAX OFFICER, WARD-1(2), JAIPUR, JAIPUR vs. MUKESH KUMAR SONI, JAIPUR

In the result appeal of the revenue is dismissed and the cross

ITA 656/JPR/2023[2018-19]Status: DisposedITAT Jaipur04 Mar 2024AY 2018-19

Bench: Moving Towards The Facts Of The Case We Would Like To Mention

For Appellant: Sh. S. B. Natani (FCA)For Respondent: Sh. Arvind Kumar (CIT)

Section 143(1)Section 143(3)Section 144BSection 147Section 148A

…ed In that view of the matter, following the aforesaid judgment in Ram Singh's case, the questions are answered against the Revenue, and in favour of the assessee Also followed by the Hon’ble Rajasthan High court in the case of k) CIT Vs Devendra Gupta (2008) 220 CTR 629 (Raj High court) l) Manoj Surgical Ind Vs. ACIT (2010) 42 DTR(Ind) (trib) 81 m) ITO Vs B Investment and Trading (2011) 59 DTR (mum Trib) 345. n) CIT v Jet Airways (I) Ltd. (2011) 331 ITR 236 (Bom) (HC).(AY.1999-2000) The effect of s. 147 as it now stands after the amendment of 2009 can be summarised as follows. (i) The AO must have reasons to bel…

S.A.BHIMARAJA,CHENNAI vs. ITO, CHENNAI

In the result, the appeal filed by the assessee is allowed

ITA 3414/CHNY/2016[2008-09]Status: DisposedITAT Chennai23 Jul 2021AY 2008-09

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita No.: 3414/Chny/2016 िनधा"रण वष" / Assessment Year: 2008-09

For Appellant: Shri T. Banusekar, CAFor Respondent: Shri G. Johnson, Addl.CIT

Section 2(14)(a)

…plethora of judicial precedents including decision of the Hon’ble High Court of Madras in the case of M/s. Martech Peripherals Pvt. Ltd. vs. DCIT, [2017] 394 ITR 733. The case laws relied upon by the assessee are as under:- 1) CIT v Dr. Devendra Gupta [2008] 220 CTR 629 (Raj) 2) CIT v Shri Ram Singh [2008] 306 ITR 343 (Raj) 3) CIT v Jet Airways (I) Ltd [2011] 331 ITR 236 (Bom) 4) Ranbaxy Laboratories Ltd v CIT [2011] 336 ITR 136 (Del) 5) CIT v Mohmed Juned Dadani [2013] 355 ITR 172 6) Oriental Bank of Commerce v AdCIT [2014] 90 CCH 27 Del High Court 7) PVP Ventures Limited v ACIT [2015] 94 CCH 0147 (Chennai HC)…

ACIT, JAIPUR vs. RAJENDRA KUMAR JAIN, JAIPUR

ITA 521/JPR/2017[2010-11]Status: DisposedITAT Jaipur28 Mar 2018AY 2010-11

For Appellant: Shri S.L. Poddar (Advocate)For Respondent: Shri Varinder Mehta (CIT)

Section 132Section 132(4)Section 147Section 148Section 153A

…Ltd. vs. DCIT (2017) 151 DTR 313 (Madras) and submitted that the reassessment is not valid when no addition is made on the reasons recorded by the AO. He has also relied upon the judgment of Hon’ble Jurisdictional High Court in the case of CIT vs. Ram Singh 220 CTR 629 (Raj.). The ld. A/R has referred to the objections raised against the notice issued under section 148 and submitted that the assessee has 5 ITA Nos. 293(7)/JP/2017 Shri Rajendra Kumar Jain, Jaipur. raised specific objection that the land in question was purchased in the name of M/s. Kalyan Buildmart Pvt. Ltd. through its director Shri Madan Mo…

ACIT, JAIPUR vs. RAJENDRA KUMAR JAIN, JAIPUR

ITA 520/JPR/2017[2009-10]Status: DisposedITAT Jaipur28 Mar 2018AY 2009-10

For Appellant: Shri S.L. Poddar (Advocate)For Respondent: Shri Varinder Mehta (CIT)

Section 132Section 132(4)Section 147Section 148Section 153A

…Ltd. vs. DCIT (2017) 151 DTR 313 (Madras) and submitted that the reassessment is not valid when no addition is made on the reasons recorded by the AO. He has also relied upon the judgment of Hon’ble Jurisdictional High Court in the case of CIT vs. Ram Singh 220 CTR 629 (Raj.). The ld. A/R has referred to the objections raised against the notice issued under section 148 and submitted that the assessee has 5 ITA Nos. 293(7)/JP/2017 Shri Rajendra Kumar Jain, Jaipur. raised specific objection that the land in question was purchased in the name of M/s. Kalyan Buildmart Pvt. Ltd. through its director Shri Madan Mo…

ACIT, JAIPUR vs. RAJENDRA KUMAR JAIN, JAIPUR

ITA 519/JPR/2017[2007-08]Status: DisposedITAT Jaipur28 Mar 2018AY 2007-08

For Appellant: Shri S.L. Poddar (Advocate)For Respondent: Shri Varinder Mehta (CIT)

Section 132Section 132(4)Section 147Section 148Section 153A

…Ltd. vs. DCIT (2017) 151 DTR 313 (Madras) and submitted that the reassessment is not valid when no addition is made on the reasons recorded by the AO. He has also relied upon the judgment of Hon’ble Jurisdictional High Court in the case of CIT vs. Ram Singh 220 CTR 629 (Raj.). The ld. A/R has referred to the objections raised against the notice issued under section 148 and submitted that the assessee has 5 ITA Nos. 293(7)/JP/2017 Shri Rajendra Kumar Jain, Jaipur. raised specific objection that the land in question was purchased in the name of M/s. Kalyan Buildmart Pvt. Ltd. through its director Shri Madan Mo…

RAJENDRA KUMAR JAIN,JAIPUR vs. ACIT, JAIPUR

ITA 408/JPR/2017[2009-10]Status: DisposedITAT Jaipur28 Mar 2018AY 2009-10

For Appellant: Shri S.L. Poddar (Advocate)For Respondent: Shri Varinder Mehta (CIT)

Section 132Section 132(4)Section 147Section 148Section 153A

…Ltd. vs. DCIT (2017) 151 DTR 313 (Madras) and submitted that the reassessment is not valid when no addition is made on the reasons recorded by the AO. He has also relied upon the judgment of Hon’ble Jurisdictional High Court in the case of CIT vs. Ram Singh 220 CTR 629 (Raj.). The ld. A/R has referred to the objections raised against the notice issued under section 148 and submitted that the assessee has 5 ITA Nos. 293(7)/JP/2017 Shri Rajendra Kumar Jain, Jaipur. raised specific objection that the land in question was purchased in the name of M/s. Kalyan Buildmart Pvt. Ltd. through its director Shri Madan Mo…

RAJENDRA KUMAR JAIN,JAIPUR vs. ACIT, JAIPUR

ITA 295/JPR/2017[2011-12]Status: DisposedITAT Jaipur28 Mar 2018AY 2011-12

For Appellant: Shri S.L. Poddar (Advocate)For Respondent: Shri Varinder Mehta (CIT)

Section 132Section 132(4)Section 147Section 148Section 153A

…Ltd. vs. DCIT (2017) 151 DTR 313 (Madras) and submitted that the reassessment is not valid when no addition is made on the reasons recorded by the AO. He has also relied upon the judgment of Hon’ble Jurisdictional High Court in the case of CIT vs. Ram Singh 220 CTR 629 (Raj.). The ld. A/R has referred to the objections raised against the notice issued under section 148 and submitted that the assessee has 5 ITA Nos. 293(7)/JP/2017 Shri Rajendra Kumar Jain, Jaipur. raised specific objection that the land in question was purchased in the name of M/s. Kalyan Buildmart Pvt. Ltd. through its director Shri Madan Mo…

RAJENDRA KUMAR JAIN,JAIPUR vs. ACIT, JAIPUR

ITA 294/JPR/2017[2010-11]Status: DisposedITAT Jaipur28 Mar 2018AY 2010-11

For Appellant: Shri S.L. Poddar (Advocate)For Respondent: Shri Varinder Mehta (CIT)

Section 132Section 132(4)Section 147Section 148Section 153A

…Ltd. vs. DCIT (2017) 151 DTR 313 (Madras) and submitted that the reassessment is not valid when no addition is made on the reasons recorded by the AO. He has also relied upon the judgment of Hon’ble Jurisdictional High Court in the case of CIT vs. Ram Singh 220 CTR 629 (Raj.). The ld. A/R has referred to the objections raised against the notice issued under section 148 and submitted that the assessee has 5 ITA Nos. 293(7)/JP/2017 Shri Rajendra Kumar Jain, Jaipur. raised specific objection that the land in question was purchased in the name of M/s. Kalyan Buildmart Pvt. Ltd. through its director Shri Madan Mo…

RAJENDRA KUMAR JAIN,JAIPUR vs. ACIT, JAIPUR

ITA 293/JPR/2017[2007-08]Status: DisposedITAT Jaipur28 Mar 2018AY 2007-08

For Appellant: Shri S.L. Poddar (Advocate)For Respondent: Shri Varinder Mehta (CIT)

Section 132Section 132(4)Section 147Section 148Section 153A

…Ltd. vs. DCIT (2017) 151 DTR 313 (Madras) and submitted that the reassessment is not valid when no addition is made on the reasons recorded by the AO. He has also relied upon the judgment of Hon’ble Jurisdictional High Court in the case of CIT vs. Ram Singh 220 CTR 629 (Raj.). The ld. A/R has referred to the objections raised against the notice issued under section 148 and submitted that the assessee has 5 ITA Nos. 293(7)/JP/2017 Shri Rajendra Kumar Jain, Jaipur. raised specific objection that the land in question was purchased in the name of M/s. Kalyan Buildmart Pvt. Ltd. through its director Shri Madan Mo…