ASSISSTANT COMMISSIONER OF INCOME TAX - 4(1), INDORE, INDORE vs. PRATAAP SNACKS LIMITED, INDORE

In the result revenue’s appeal is dismissed and assessee’s cross-objection is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

reassessment order passed u/s 147 of the Act. The Cross Objections of the assessee stand disposed off being allowed. Revenue’s Appeal for A.Y. 2012-13, 2013-14, 2017-18, 2020- 21 and 2018-19: 11. Ld. Departmental Representative vehemently argued and submitted that section 80IB(11A) provides for deduction in the case of an undertaking deriving profit from

ASSISTANT COMMISSIONER OF INCOME TAX - 4(1), INDORE, INDORE vs. PRATAAP SNACKS LIMITED, INDORE

In the result revenue’s appeal is dismissed and assessee’s cross-objection is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

reassessment order passed u/s 147 of the Act. The Cross Objections of the assessee stand disposed off being allowed. Revenue’s Appeal for A.Y. 2012-13, 2013-14, 2017-18, 2020- 21 and 2018-19: 11. Ld. Departmental Representative vehemently argued and submitted that section 80IB(11A) provides for deduction in the case of an undertaking deriving profit from

ASSISSTANT COMMISSIONER OF INCOME TAX - 4(1), INDORE, INDORE vs. PRATAAP SNACKS LIMITED, INDORE

In the result revenue’s appeal is dismissed and assessee’s cross-objection is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

reassessment order passed u/s 147 of the Act. The Cross Objections of the assessee stand disposed off being allowed. Revenue’s Appeal for A.Y. 2012-13, 2013-14, 2017-18, 2020- 21 and 2018-19: 11. Ld. Departmental Representative vehemently argued and submitted that section 80IB(11A) provides for deduction in the case of an undertaking deriving profit from

ASSISSTANT COMMISSIONER OF INCOME TAX - 4(1), INDORE, INDORE vs. PRATAAP SNACKS LIMITED, INDORE

In the result revenue’s appeal is dismissed and assessee’s cross-objection is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

reassessment order passed u/s 147 of the Act. The Cross Objections of the assessee stand disposed off being allowed. Revenue’s Appeal for A.Y. 2012-13, 2013-14, 2017-18, 2020- 21 and 2018-19: 11. Ld. Departmental Representative vehemently argued and submitted that section 80IB(11A) provides for deduction in the case of an undertaking deriving profit from

ASSISTANT COMMISSIONER OF INCOME TAX - 4(1), INDORE, INDORE vs. PRATAAP SNACKS LIMITED, INDORE

In the result revenue’s appeal is dismissed and assessee’s cross-objection is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

reassessment order passed u/s 147 of the Act. The Cross Objections of the assessee stand disposed off being allowed. Revenue’s Appeal for A.Y. 2012-13, 2013-14, 2017-18, 2020- 21 and 2018-19: 11. Ld. Departmental Representative vehemently argued and submitted that section 80IB(11A) provides for deduction in the case of an undertaking deriving profit from

NILIMA KOTHARI,INDORE vs. THE INCOME TAX OFFICER, NATIONAL FACELESS ASSTT. CENTRE, INDORE

In the result appeal of the assessee is allowed as per terms indicated above

Bench: Shri Manish Boradsmt. Neelima Kothari, Income Tax Officer, 601, N.R.K. Villas, Delhi Vs. 22/2 Manoramaganj, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Adnpk7832J Assessee By Shri S.S. Deshpande, Ar Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 08.08.2024 Date Of Pronouncement 20.09.2024

51. This brings us to the tenability of the travel back in time theory encapsulated in paragraphs 6.1 and 6.2(ii) of the Instruction dated 11.05.2022. For convenience, the relevant part of the instruction is set forth hereafter: "...6.0 Operation of the new section 149 of the Act to identify cases where fresh notice under section

ANNAMMA JOSEPH,PATHANAMTHITTA vs. THE INCOME TAX OFFICER, WARD-2(5), BHOPAL,MADHYA PRADESH, KERALA

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

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniannamma Joseph Ito-2(5) 1088, Zion Villa Bhopal Thottapuzhassery, Pullad S.O. Vs. Pathanamthitta Kerala (Appellant / Assessee) (Respondent/ Revenue) Pan: Adlpj3534G Assessee By None Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 31.07.2024 Date Of Pronouncement 31.07.2024

51,80,800/- has been paid. Here is the case of reassessment which is done for the benefit of Revenue. Hence, in our view, clause (b) of Section

THE DCIT, 2(1), INDORE vs. SHRI KESHAV KUMAR NACHANI, INDORE

In the result, all the appeals of the Revenue are dismissed

Bench: Smt. Madhumita Roy & Shri Bhagirath Mal Biyani

reassessment of the firm under section 143(3) read with section 148 wherein the impugned share of profit was offered to tax was completed and accepted by the Revenue. There is no material with the AO to demonstrate that firm was not genuine, and its activities were doubtful nature, and that the impugned amount of Rs.25,76,208/- represented unexplained

THE DCIT, 2(1), INDORE vs. SHRI KESHAV KUMAR NACHANI, INDORE

In the result, all the appeals of the Revenue are dismissed

Bench: Smt. Madhumita Roy & Shri Bhagirath Mal Biyani

reassessment of the firm under section 143(3) read with section 148 wherein the impugned share of profit was offered to tax was completed and accepted by the Revenue. There is no material with the AO to demonstrate that firm was not genuine, and its activities were doubtful nature, and that the impugned amount of Rs.25,76,208/- represented unexplained

JCIT(OSD),-2(1),INDORE, INDORE vs. SHRI KESHAV KUMAR NACHANI, INDORE

In the result, all the appeals of the Revenue are dismissed

Bench: Smt. Madhumita Roy & Shri Bhagirath Mal Biyani

reassessment of the firm under section 143(3) read with section 148 wherein the impugned share of profit was offered to tax was completed and accepted by the Revenue. There is no material with the AO to demonstrate that firm was not genuine, and its activities were doubtful nature, and that the impugned amount of Rs.25,76,208/- represented unexplained

ROHIT KUMAR YADAV,INDORE vs. INCOME TAX OFFICER 5(5), INDORE

In the result, appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanirohit Kumar Yadav Ito 5(5) Hig-Dx-2Manishmati Arvind Indore Vihar, Mahishmati Vs. Bhopal (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaupy5015 F Assessee By Shri Pankaj Shah & Soumya Bumb Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 09.04.2024 Date Of Pronouncement 15.04.2024

section 143 for those years. In the instant case we are concerned with the reassessment, in which there are more restraints on the power of the Assessing Officer. We, therefore, hold that the initiation of reassessment proceedings on this count cannot be upheld.” 6.1 Thus, the protective assessment cannot be independent of substantive assessment as protective assessment is always successive

JCIT OSD CENTRAL-1, BHOPAL vs. M/S SHAKSHI TOWN SHIP P LTD, GWALIOR

Appeal is dismissed and assessee's cross-\nobjection is allowed

reassessment proceedings and obliged\n\nKindly find the same in order and do the need full.\n\nIf any other information/documents required please inform us we shall comply the same\n\nThanking You\n\nYours faithfully\n\nFor Shakshi Township Pvt. Ltd\n\nNou s Afarand\n(Director)\n\nPage 31 of 52\n\nM/s. Shakshi Township P. Ltd.\nITA

AJIT BONDRIYA,LIMASSOL, CYPRUS vs. ITO 2(5), BHOPAL, BHOPAL, MADHYA PRADESH

Appeal is allowed for statistical purpose

section 142(1) of the Act enclosing:\na) Copy of Equity transaction statement\nb) Copy of bank statement FY 2015-16\n40\n35\n21-24\n11.\nShow Cause Notice dated 24.11.2023 issued u/s 144 of the Act.\n41-42\n12.\nAcknowledgement of Reply dated 29.11.2023 in response to show\ncause notice dated 24.11.2023 enclosing:\n43-44\nPage

M/S RADHISHWARI DEVLOPERS P LTD,INDORE vs. PR CIT -2 INDORE, INDORE

In the result, Assessee’s appeal in ITANo

Bench: Hon’Ble Rajpal Yadav & Hon’Ble Manish Boradvirtual Hearing Assessment Year 2013-14 M/S. Radhishwari Developers P. Ltd. (Now Known As R.C. Warehousing Pvt. Ltd. ) Indore : Appellant Pan :Aafcr1916A V/S Pr. Cito-2 : Respondent Indore Appellant By S/Shri Sumit Nema Sr. Adv. With Gagan Tiwari & Piyush Parashar Advs. Revenue By Shri S.S. Mantri, Cit-Dr Date Of Hearing 24.05.2021 Date Of Pronouncement 20.07.2021

51 SOT 1 (URO) (Asr.)(Trib.), Fine Jewellery (India) Ltd. v. ACIT 19 ITR 746 (Mum.) (Trib.); e. In case, where the High Court found that the Assessing Officer examined all the details with respect to assessee’s claim of deduction, the order could not be said to be erroneous or was passed without application of mind merely because

BABITA CHELAWAT,INDORE vs. DCIT/ACIT 1(1), INDORE, INDORE

The appeal of the assessee is allowed & the impugned order is set aside

Bench: Shri B.M. Biyani & Shri Paresh M Joshi

Section 143(3) r.w.s. 147 is bad in law, without jurisdiction, and liable to be quashed. 2. On the facts and circumstances of the case and in law, the 2 reassessment was completed without complying with the statutory requirements of law. 3. On the facts and circumstances of the case and in law, the 3 Hon. CIT(A) erred

RVR TECHNOLOGIES LTD.,MANDIDEEP vs. ADDL. CIT-RANGE-3, BHOPAL

In the result, appeal for A

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

reassessment. 2. On the facts and in the circumstances of the case, the honourable CIT(A) was not justified in upholding that the receipt from job work of mixing of rubber at Rs. 34,19,894 was not the business receipts/income and in confirming the same was income from other sources. 3.On the facts and in the circumstances

RVR TECHNOLOGIES LTD.,MANDIDEEP vs. ACIT-3(1), BHOPAL

In the result, appeal for A

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

reassessment. 2. On the facts and in the circumstances of the case, the honourable CIT(A) was not justified in upholding that the receipt from job work of mixing of rubber at Rs. 34,19,894 was not the business receipts/income and in confirming the same was income from other sources. 3.On the facts and in the circumstances

RVR TECHNOLOGIES LTD.,MANDIDEEP vs. ITO-2(1), BHOPAL

In the result, appeal for A

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

reassessment. 2. On the facts and in the circumstances of the case, the honourable CIT(A) was not justified in upholding that the receipt from job work of mixing of rubber at Rs. 34,19,894 was not the business receipts/income and in confirming the same was income from other sources. 3.On the facts and in the circumstances