Ajay Bakliwal, Kota vs. ACIT, Central Circle, Kota
In the result, the appeal of the assessee is allowed
ITA 1279/JPR/2024[2017-18]Status: DisposedITAT Jaipur11 Apr 2025AY 2017-18
Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)
For Appellant: Sh. Rajendra Sisodia, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 132(1)Section 139Section 143(3)Section 153ASection 154Section 270A
…stante clause which has an override effect over Section 147 of the Act among others. Reference was drawn to decision Shrikant Mohta v. CIT [2018] 95 taxmann.com 224/257 Taxman 43/[2019] 414 ITR 270 (Cal.), Asstt. CIT v. V.N. Devadoss [2013] 32 taxmann.com 133/57 SOT 67 (URO) (Chennai - Trib.) and held that a conspectus of the aforesaid decision cited would thus give a rise to a compelling impression that assessee is not prevented from making a claim to its advantage in the proceedings under section 153A of the Act unlike Section 147 of the Act. In above decision, court has not discussed second proviso to section…