ACIT(CENTRAL)-1,, INDORE vs. SHRI RAJUL BHARGAVA, INDORE

The appeals of the Revenue are dismissed

Bench: Shri Mahavir Prasad & Shri Manish Borad

4- Through this ground of appeal the appellant has challenged that the original assessment for this year was completed u/s 153A and therefore, reassessment proceedings u/s 148 could not have been legally initiated in this case. The appellant also filed a detailed written submission in this respect wherein it is contended by the appellant that reopening u/s 147

SANJEEV AGRAWAL ,BHOPAL vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL-2, BHOPAL

Appeal is allowed

sections": [ "147", "133A", "139(1)", "143(3)", "143(2)", "148", "69C", "69A", "292C", "132(4A)", "65B(4)" ], "issues": "1. Whether the reassessment proceedings initiated u/s

KAMAL PANJWANI,INDORE vs. THE ACIT 3 (1), INDORE

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

132(4) wherein a surrender of undisclosed assets/income of Rs. 51,57,000/- was made by assessee. Post- search, the AO recorded reasons dated 30.04.1993, issued notices dated 27.05.1993 u/s 148 and thereby took action u/s 147 for AY 1988-89 to 1992-93 as per provisions of the Act existing at the relevant time to deal search-cases

KAMAL PANJWANI,INDORE vs. THE ACIT 3 (1), INDORE

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

132(4) wherein a surrender of undisclosed assets/income of Rs. 51,57,000/- was made by assessee. Post- search, the AO recorded reasons dated 30.04.1993, issued notices dated 27.05.1993 u/s 148 and thereby took action u/s 147 for AY 1988-89 to 1992-93 as per provisions of the Act existing at the relevant time to deal search-cases

KAMAL PANJWANI,INDORE vs. THE ACIT 3 (1), INDORE

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

132(4) wherein a surrender of undisclosed assets/income of Rs. 51,57,000/- was made by assessee. Post- search, the AO recorded reasons dated 30.04.1993, issued notices dated 27.05.1993 u/s 148 and thereby took action u/s 147 for AY 1988-89 to 1992-93 as per provisions of the Act existing at the relevant time to deal search-cases

KAMAL PANJWANI,INDORE vs. THE ACIT 3 (1), INDORE

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

132(4) wherein a surrender of undisclosed assets/income of Rs. 51,57,000/- was made by assessee. Post- search, the AO recorded reasons dated 30.04.1993, issued notices dated 27.05.1993 u/s 148 and thereby took action u/s 147 for AY 1988-89 to 1992-93 as per provisions of the Act existing at the relevant time to deal search-cases

KAMAL PANJWANI,INDORE vs. THE ACIT 3 (1), INDORE

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

132(4) wherein a surrender of undisclosed assets/income of Rs. 51,57,000/- was made by assessee. Post- search, the AO recorded reasons dated 30.04.1993, issued notices dated 27.05.1993 u/s 148 and thereby took action u/s 147 for AY 1988-89 to 1992-93 as per provisions of the Act existing at the relevant time to deal search-cases

DCIT (CENTRAL), BHOPAL vs. SHAILENDRA SHARMA, BHOPAL

In the result the appeals of the assessee for the Assessment

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

147, Section 148, Section 149, Section 151 and Section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132-A after the 31st day of May, 2003, the Assessing Officer shall- (a) issue notice to such person requiring him to furnish

ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL)-1, INDORE vs. SHRI RITESH JAIN, INDORE

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani & It(Ss)Ano.14/Ind/2022 (Assesssment Year 2011-12

reassessment framed by the AO u/s 147 r.w. section 143(3) without a valid notice u/s 143(2) is not valid and liable to be quashed as held by the Hon’ble Supreme Court in case of ACIT vs. Hotel Blue Moon 321 ITR 362. 7. The next objection of the assessee is against the validity of the order passed

BHARGAVI KESWANI,INDORE vs. ASST. COMMISSIONER OF INCOME TAX (CENTRAL)- II, BHOPAL , BHOPAL

Appeals are allowed

reassess taking into consideration the other material in\nrespect of completed assessments/unabated assessments. Meaning\nthereby, in respect of completed/unabated assessments, no addition can\nbe made by the AO in absence of any incriminating material found\nduring the course of search under Section 132 or requisition\nunder Section 132A of the Act, 1961. However, the completed/unabated\nassessments can be re-opened

SUNIL SAHU,RAIPUR vs. ACIT(CENTRAL)-2, BHOPAL

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

4. We have carefully gone through the approval letter dated 22.03.2017 issued by the Additional Commissioner of Income Tax appearing at page 75 of the paper book before us for assessment year 2010-11 wherefrom it appears that the sanction note of the PCIT, Central Bhopal has also been annexed. The same is also available at page 76 to page

SUNIL SAHU,RAIPUR vs. ACIT(CENTRAL)-2, BHOPAL

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

4. We have carefully gone through the approval letter dated 22.03.2017 issued by the Additional Commissioner of Income Tax appearing at page 75 of the paper book before us for assessment year 2010-11 wherefrom it appears that the sanction note of the PCIT, Central Bhopal has also been annexed. The same is also available at page 76 to page

SUNIL SAHU,RAIPUR vs. ACIT(CENTRAL)-2, BHOPAL

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

4. We have carefully gone through the approval letter dated 22.03.2017 issued by the Additional Commissioner of Income Tax appearing at page 75 of the paper book before us for assessment year 2010-11 wherefrom it appears that the sanction note of the PCIT, Central Bhopal has also been annexed. The same is also available at page 76 to page

THE ACIT CENTRAL -1, BHOPAL vs. SHRI SUNIL SAHU , RAIPUR

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

4. We have carefully gone through the approval letter dated 22.03.2017 issued by the Additional Commissioner of Income Tax appearing at page 75 of the paper book before us for assessment year 2010-11 wherefrom it appears that the sanction note of the PCIT, Central Bhopal has also been annexed. The same is also available at page 76 to page

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

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

DCIT , CENTRAL -2 , INDORE vs. M/S GREAT GALLEON VENTURES LTD , INDORE

In the result, the appeals of the Revenue bearing ITANo

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad

4,20,000 19. Sanskar Commosale Pvt. SCPL - - 79,782 Ltd. - 20,00,000 1,75,339 20. Blackberry Tradecom Pvt. BTPL - - - - - 40,96,026 M/sGreat Galleon Ventures ltd. IT(SS)A No.114, to 116 /Ind/2020 & ITANo.67 to 70/Ind/2021 Ltd. TOTAL