SHRIMATI AMARJIT KAUR W/O BUGAR SINGH,MANSA vs. INCOME TAX OFFICER WARD 1(4), MANSA

In the result, the appeal of the assessee is dismissed

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

v. ITO particulars of the return without any new material. Even if proceedings under s. 143(2) are not taken, reassessment proceedings can be taken. h) Aditya and Co. Vs CIT 279 ITR 47 P&H In the case of an intimation under section

POONAM MARWAHA,AMRITSAR vs. ACIT DCIT CEN CIR, AMRITSAR

In the result, the appeal filed by assessee is allowed

v. Union of India\nSection 263 of the Income-tax Act, 1961 - Revision - Of orders prejudicial to interest of\nrevenue (General Principles) - An order under section 263 was assailed on ground that\ncondition precedent of initiating a proceeding under section 263 was absent and, therefore,\nimpugned order was an order without jurisdiction Whether two conditions of order\nbeing erroneous

M/S BLUE CITY TOWNSHIP & COLONIZERS,AMRITSAR. vs. THE INCOME TAX OFFICER,, AMRITSAR.

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

2) on 12.11.2014 served upon the assessee on 5 I.T.A. No. 90/Asr/2017 Blue City Township & Colonizers v. ITO 13.11.2014 fixing the case for hearing on 20.11.2014. The case of the appellant company was adjourned on different dates at the request of the ld. counsel for the assessee company during the course of assessment proceedings by granting adjournment

SHRI GURBINDER SINGH MAHAL,AMRITSAR vs. INCOME TAX OFFICER WARD-IV ( 2), AMRITSAR

In the result, the appeal of the assessee bearing ITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

reassessment or recomputation under section 147) of the income of the deceased and for the purpose of levying any sum in the hands of the legal representative in accordance with the provisions of sub-section (1),— (a) any proceeding taken against the deceased before his death shall be deemed to have been taken against the legal representative

INCOME TAX OFFICER, FEROZEPUR vs. MS.JATIN AGRO, FORT ROAD

In the result, the appeal of the revenue is dismissed

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 103 & 104/Asr/2024 Assessment Years: 2014-15 & 2017-18 Ito, Ward-3(1), Vs. M/S Jatin Agro Fort Road, Ferozepur. 152-P, Ferozepur. [Pan:-Aarpm5393F] (Appellant) (Respondent) Sh. Ashray Sarna, Ca Appellant By Respondent By Sh. Sunil Gautam, Cit. Dr

47,11,318/- as against claimed by the assessee in respect of expenditure of Rs 77,65,67,171/-. Hence, deduction u/s 35AD of the Act has been claimed by the assessee wrongly. 6. As per the provisions of section 147 of the Income Tax Act, 1961, if the Assessing Officer has reasons to believe that any income may, subject

INCOME TAX OFFICER, WARD-3(1),FEROZEPUR, FEROZEPUR vs. MS.JATIN AGRO, FORT ROAD

In the result, the appeal of the revenue is dismissed

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 103 & 104/Asr/2024 Assessment Years: 2014-15 & 2017-18 Ito, Ward-3(1), Vs. M/S Jatin Agro Fort Road, Ferozepur. 152-P, Ferozepur. [Pan:-Aarpm5393F] (Appellant) (Respondent) Sh. Ashray Sarna, Ca Appellant By Respondent By Sh. Sunil Gautam, Cit. Dr

47,11,318/- as against claimed by the assessee in respect of expenditure of Rs 77,65,67,171/-. Hence, deduction u/s 35AD of the Act has been claimed by the assessee wrongly. 6. As per the provisions of section 147 of the Income Tax Act, 1961, if the Assessing Officer has reasons to believe that any income may, subject

SH. SURINDER SINGH LEGAL HEIR. OF SMT SITA DEVI,BATHINDA vs. INCOME TAX OFFICER WARD-1(1), BATHINDA

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

v. ITO account of his death. If he dies, his legal representative shall be liable to pay any tax which would have been liable to be paid by such person if he had not died. Sub-section (2) makes the position clear that for the purpose of assessment, reassessment or recomputation under section 147 of the Act, any proceeding taken

SHRI PURAN SINGH,SHAHKOT vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), LUDHIANA

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

2) makes the position clear that for the purpose of assessment, reassessment or recomputation under section 147 of the Act, any proceeding taken against the deceased before his death shall be deemed to have been taken against the legal representative and may be continued against the legal representative from the stage at which it stood on the date of death

SHRI PURAN SINGH ,SHAHKOT vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), LUDHIANA

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

2) makes the position clear that for the purpose of assessment, reassessment or recomputation under section 147 of the Act, any proceeding taken against the deceased before his death shall be deemed to have been taken against the legal representative and may be continued against the legal representative from the stage at which it stood on the date of death

SHRI PURAN SINGH,SHAHKOT vs. PRINCIPAL COMMISSIONER OF INCOME TAX(CENTRJAL), LUDHIANA

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

2) makes the position clear that for the purpose of assessment, reassessment or recomputation under section 147 of the Act, any proceeding taken against the deceased before his death shall be deemed to have been taken against the legal representative and may be continued against the legal representative from the stage at which it stood on the date of death

SHRI PURAN SINGH,SHAHKOT vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), LUDHIANA

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

2) makes the position clear that for the purpose of assessment, reassessment or recomputation under section 147 of the Act, any proceeding taken against the deceased before his death shall be deemed to have been taken against the legal representative and may be continued against the legal representative from the stage at which it stood on the date of death

SHRI PURAN SINGH ,SHAHKOT vs. PRINICIPAL COMMISSIONER AOF INCOME TAX(CENTRAL), LUDHIANA

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

2) makes the position clear that for the purpose of assessment, reassessment or recomputation under section 147 of the Act, any proceeding taken against the deceased before his death shall be deemed to have been taken against the legal representative and may be continued against the legal representative from the stage at which it stood on the date of death

SHRI PURAN SINGH,SHAHKOT vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), LUDHIANA

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

2) makes the position clear that for the purpose of assessment, reassessment or recomputation under section 147 of the Act, any proceeding taken against the deceased before his death shall be deemed to have been taken against the legal representative and may be continued against the legal representative from the stage at which it stood on the date of death

SHRI PURAN SINGH,SHAHKOT vs. PRINICIPAL COMMISSIONER OF INCOME TAX (CENTRAL) , LUDHIANA

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

2) makes the position clear that for the purpose of assessment, reassessment or recomputation under section 147 of the Act, any proceeding taken against the deceased before his death shall be deemed to have been taken against the legal representative and may be continued against the legal representative from the stage at which it stood on the date of death

NEERAJ KUMAR SETHI,DELHI vs. ITO, NATIONAL FACELESS APPEAL CENTRE (NFAC)

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

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

47,645/-, Notice u/s.133(6) of the Act, was issued by the AO on 26.02.2022 to Mr. Ashok Gupta, Proprietor of Gayatri Maa (AAAPG2240G) &Ridhi Sindhi Impex (AAAPG2240G) and to Anuj Kumar Gupta Proprietor of Parth International (AGJPG39758). Both the notices have been delivered to one e-mail caashokgupta@yahoo.co.in, but no compliance have been made by both the parties

SMT. SATYAWATI MARWAHA THROUGH LEGAL HEIR SH, CHANDER SHEIKHAR MARWAHA,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeal for Asstt

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

reassessment proceedings provided he has reasons to believe but the same cannot be taken recourse to on the basis of reasons to suspect-ITO & Ors, vs. Lakhmani Mewal Das 1976 CTR (SC) 220 (1976) 103 ITR 437 (SC) relied on". Therefore, the very assumption of jurisdiction u/s 147 on the basis of the "reason" recorded is vitiated. Thus, the reasons

SMT. SATYAWATI MARWAHA THROUGH LEGAL HEIR SH. CHANDER SHEIKHAR MARWAHA,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeal for Asstt

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

reassessment proceedings provided he has reasons to believe but the same cannot be taken recourse to on the basis of reasons to suspect-ITO & Ors, vs. Lakhmani Mewal Das 1976 CTR (SC) 220 (1976) 103 ITR 437 (SC) relied on". Therefore, the very assumption of jurisdiction u/s 147 on the basis of the "reason" recorded is vitiated. Thus, the reasons

M/S GCA MARKETING PVT. LTD,BATHINDA vs. A.C.I.T , CIRCLE-1,, BATHINDA

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

reassessment in response to illegal, invalid notice issued under section 148 of the I. T. Act. As such, assessment framed in response to such a notice is void abinitio. The same be cancelled". 2. The learned CIT(A) has erred in law as well as on the facts of the case in confirming the gross receipts

M/S GCA MARKETING PVT. LTD,BATHINDA vs. A.C.I.T , CIRCLE-1,, BATHINDA

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

reassessment in response to illegal, invalid notice issued under section 148 of the I. T. Act. As such, assessment framed in response to such a notice is void abinitio. The same be cancelled". 2. The learned CIT(A) has erred in law as well as on the facts of the case in confirming the gross receipts