Pioneer Town Planners Pvt. Ltd. v. DCIT

170 DTR 237High Court2018#19477 most cited

judgments rely on this decision, according to BharatTax’s citation analysis of 350,364 Indian tax judgments — from 2019 to 2024.

Sections most often in play

Section 143(1)Section 147 Section 148 Section 10(38)Section 139(1)Section 143(3)Section 144B Section 68

Judgments citing Pioneer Town Planners Pvt. Ltd. v. DCIT

Smt. Sudha Agarwal, Jaipur vs. ITO, Ward-6(4), Jaipur

In the result, the appeal filed by the assessee stands partly allowed with no orders to cost

ITA 532/JPR/2024[2013-14]Status: HeardITAT Jaipur30 Oct 2024AY 2013-14

For Appellant: Shri P.C. Parwal, CAFor Respondent: Shri Gautam Singh Choudhary,JCIT-DR

Section 10(38)Section 147Section 148Section 69A

…s purchase bills from ‘GJ’, since AO had not recorded his own satisfaction and had not made any effort to examine and to discuss material received from Investigation wing, reassessment so made was to be quashed. Pioneer Town Planners Pvt. Ltd. Vs. DCIT (2018) 170 DTR 237 (Del.) (Trib.) AO having formed the belief that assessee’s income has escaped assessment only on the basis of some material received from the Investigation Wing without making any effort to examine and discuss the material received from the Investigation Wing and without application of the mind to the same, it follows that he initiated the reasse…

Smt. Lakshmi Agarwal, Jaipur vs. ITO, Ward-4(5), Jaipur

In the result, the appeal of the assessee is dismissed with no orders as to costs

ITA 286/JPR/2024[2011-12]Status: DisposedITAT Jaipur11 Sept 2024AY 2011-12

Bench: recording satisfaction for issuance of notice since the information is specific. Thus the reasons recorded for re-opening is on borrowed satisfaction and not on any satisfaction by the AO. The

For Appellant: Shri P.C. Parwal, CAFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR

Section 147Section 148Section 68Section 69C

Sh. Dileep Gangwal, B-138, Vijay Path, Tilak Nagar, Jaipur vs. ITO, Ward-6(1), Jaipur

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 348/JPR/2022[2011-12]Status: DisposedITAT Jaipur14 Dec 2022AY 2011-12

For Appellant: Shri P.C. Parwal, CAFor Respondent: Smt. Monisha Choudhary, JCIT

Section 133Section 143(3)Section 147Section 148Section 68

…r "reason to The AO has to carry out further examination to convert the "reason to suspect" into "reason to believe. If the AO acts on borrowed satisfaction and without application of mind, the reopening is void. Pioneer Town Planners (P) Ltd. Vs. DCIT (2018) 170 DTR 237 (Del.) (Trib.) AO having formed the belief that assessee's income has escaped assessment only on the basis of some material received from the Investigation Wing without making any effort to examine and discuss the material received from the Investigation Wing and without application of the mind to the same, it follows that be initiated the reasse…

Akarsh Steels Pvt. Ltd., Jaipur vs. Income Tax Officer, Jaipur

In the result, the appeal of the assessee is allowed

ITA 218/JPR/2018[2009-10]Status: DisposedITAT Jaipur03 Oct 2019AY 2009-10

For Appellant: Shri P.C. Parwal (CA)For Respondent: Shri Abhishek Sharma (Addl. CIT)

Section 143(1)Section 147Section 148Section 68

…f mind as well as the examination of so called material and information received from the Investigation Wing. In support of his contention, he has relied upon the decision of Delhi Benches of the Tribunal in case of Pioneer Town Planners Pvt. Ltd vs. DCIT, 170 DTR 237 (Del. Trib.). Thus the ld. A/R has submitted that the bare reading of the reasons shows that the AO mechanically and blindly acted upon the information received from the Investigation Wing without applying his own mind to form the belief that income of the assessee has escaped assessment. Hence the reopening of the assessment only at the instanc…