THE ACIT,CENTRAL-1, INDORE vs. M/S PRAKASH OILS LTD., DHAR

In the result, the above captioned appeals filed by the Revenue as well as the

Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani

section 147 of the Act and, thereafter, concluded that the losses obtained by the assessee on NMCE platform were contrived CO Nos.2 to 4/Ind/2022 losses and those losses were incurred by executing the synchronized trades dealing in illiquid commodities only. He also alleged that the losses were incurred with a specific intention to reduce taxable income by setting

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

133(6) of the Act however, Ld AO neither made any independent enquiry subsequent to their filing of Affidavits retracting the statements nor Ld.AO provided any opportunity of cross-examination to the assessee. 13.4 Learned Counsel for the assessee further submitted that during the course of the assessment proceedings, it was submitted before the AO that in respect

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

133(6) of the Act however, Ld AO neither made any independent enquiry subsequent to their filing of Affidavits retracting the statements nor Ld.AO provided any opportunity of cross-examination to the assessee. 13.4 Learned Counsel for the assessee further submitted that during the course of the assessment proceedings, it was submitted before the AO that in respect

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 5 1, BHOPAL , BHOPAL MADHYA PRADESH vs. MAPAEX REMEDIES PVT LTD, BHOPAL MADHYA PRADESH

Appeals are dismissed

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

6 of 48 MAPAEX Remedies Pvt Ltd., Bhopal ITA Nos. 486, 444, 489/Ind/2024 & 508 to 510 for AYs 2012-13, 2016-17 & 2017-18 completed assessment. The four years’ period from end of AY 2012-13 expired on 31.03.2017 and as such the notice u/s 148 dated 30.03.2019 was issued after expiry of four years from end of the relevant

MS MAPAEX REMEDIES PVT LTD,BHOPAL vs. ACIT 2 (1) BHOPAL, BHOPAL MADHYA PRADESH

Appeals are dismissed

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

6 of 48 MAPAEX Remedies Pvt Ltd., Bhopal ITA Nos. 486, 444, 489/Ind/2024 & 508 to 510 for AYs 2012-13, 2016-17 & 2017-18 completed assessment. The four years’ period from end of AY 2012-13 expired on 31.03.2017 and as such the notice u/s 148 dated 30.03.2019 was issued after expiry of four years from end of the relevant

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -5(1), BHOPAL , BHOPAL, MADHYA PRADESH vs. MAPAEX REMEDIES PVT. LTD., BHOPAL MADHYA PRADESH

Appeals are dismissed

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

6 of 48 MAPAEX Remedies Pvt Ltd., Bhopal ITA Nos. 486, 444, 489/Ind/2024 & 508 to 510 for AYs 2012-13, 2016-17 & 2017-18 completed assessment. The four years’ period from end of AY 2012-13 expired on 31.03.2017 and as such the notice u/s 148 dated 30.03.2019 was issued after expiry of four years from end of the relevant

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE - 5(1), BHOPAL , BHOPAL MADHYA PRADESH vs. MAPAEX REMEDIES PVT LTD, BHOPAL MADHYA PRADESH

Appeals are dismissed

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

6 of 48 MAPAEX Remedies Pvt Ltd., Bhopal ITA Nos. 486, 444, 489/Ind/2024 & 508 to 510 for AYs 2012-13, 2016-17 & 2017-18 completed assessment. The four years’ period from end of AY 2012-13 expired on 31.03.2017 and as such the notice u/s 148 dated 30.03.2019 was issued after expiry of four years from end of the relevant

MAPAEX REMEDIES PVT LTD ,BHOPAL vs. THE DCIT -2- (1), BHOPAL , BHOPAL

Appeals are dismissed

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

6 of 48 MAPAEX Remedies Pvt Ltd., Bhopal ITA Nos. 486, 444, 489/Ind/2024 & 508 to 510 for AYs 2012-13, 2016-17 & 2017-18 completed assessment. The four years’ period from end of AY 2012-13 expired on 31.03.2017 and as such the notice u/s 148 dated 30.03.2019 was issued after expiry of four years from end of the relevant

MS MAPAEX REMEDIES PVT LTD,BHOPAL vs. ACIT 2 (1) BHOPAL, BHOPAL

Appeals are dismissed

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

6 of 48 MAPAEX Remedies Pvt Ltd., Bhopal ITA Nos. 486, 444, 489/Ind/2024 & 508 to 510 for AYs 2012-13, 2016-17 & 2017-18 completed assessment. The four years’ period from end of AY 2012-13 expired on 31.03.2017 and as such the notice u/s 148 dated 30.03.2019 was issued after expiry of four years from end of the relevant

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

133 (6) should be the trigger point to make further inquires; it is not the resting point. In the present case, the fact shows that the assessing officer has merely relied upon the enquiries conducted by the investigation wing of the department and has not confronted the assessee with material that he has received from the investigation wing

M/S JAYGANGA EXIM INDIA (P) LTD.,KOLKATA vs. DCIT, CIRCLE-II, BHOPAL

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2012-13 M/S. Jayganga Exim India Pvt. Dy. Cit, Limited Central-Ii, [Formerly Known As ‘Jay Jyoti Bhopal (India) Pvt. Ltd.’] बनाम/ 26, Col. Biswas Road, Ground Floor, Vs. West Side Flat, Kolkata (Assessee / Appellant) (Revenue / Respondent) Pan: Aaacj 8822 E Assessee By Shri Harsh Vijaywargiya, Ca Revenue By Ms. Simran Bhullar, Cit Dr Date Of Hearing 21.11.2023 Date Of Pronouncement 02.01.2024

133,30,03,030/- Aggrieved by order of re-assessment, the assessee went in appeal to Ld. CIT(A) but did not get any relief. Now, the assessee has come in next appeal before us. Submission by parties: 6. Ld. AR for assessee straightaway carried us to the reasons recorded by AO before issuing notice u/s 148. The said reasons

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

MS. SANGEETA CHOPRA,UJJAIN vs. THE PR. CIT. UJJAIN, UJJAIN

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

Bench: Shri Manish Borad& Ms. Madhumita Roy

133(6) dated 24.04.2012 on the basis of AIR Information was served upon the assessee whereupon on 23.09.2016 the return of income was filed. The assessee filed the following details and/or working in regard to the capital gain in response to the notice under Section 147 of the Act upon filing her return of income showing total income

RAJESH KUMAR RATHORE,SEHORE vs. INCOME TAX OFFICER- WARD 5, SEHORE, SEHORE

In the result, the impugned order is set aside as & by way of\nremand back to the file of the Ld

133(6) issued to the assessee's bankers to\nfurnish the bank statement for the relevant year. The bank\nsubmitted the bank statements for the year under\nconsideration. The same has been verified and tallied with\nthe information.\n5. In view of the facts and circumstances of the case and\nafter due verification of the information available on record

ADIM JATI SEVA SAHAKARI S ANSTHA BELKUND,BELKUND, BETUL vs. ITO, BETUL, BETUL

Appeal is allowed for statistical purpose

u/s 69A r.w.s. 115BBE. Aggrieved, the assessee matter\nin first-appeal whereupon the CIT(A) dismissed assessee's appeal in limine\nwithout adjudicating merits of case due to non-prosecution. Still aggrieved,\nthe assessee has come in next appeal before us.\n5. Ld. AR for assessee at first submitted that the section 250(6) of the\nIncome

JASTEJ GOROWARA,BHOPAL vs. COMMISSIONER OF INCOME-TAX (APPEALS), DELHI

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

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

reassessment proceedings for A.Y. 2011–12. The Assessing Officer reopened the assessment by issuing notice under section 148 of the Income-tax Act, 1961 (“the Act”). The reopening was based on information received from the Investigation Wing that the assessee had purchased an immovable property worth ₹2,40,40,000/- through open auction from UCO Bank and that part

JASTEJ GOROWARA,BHOPAL vs. CIT(A), DELHI

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

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

reassessment proceedings for A.Y. 2011–12. The Assessing Officer reopened the assessment by issuing notice under section 148 of the Income-tax Act, 1961 (“the Act”). The reopening was based on information received from the Investigation Wing that the assessee had purchased an immovable property worth ₹2,40,40,000/- through open auction from UCO Bank and that part

CHANDAN CHOUHAN,KHARGONE vs. DCIT, DELHI

The appeal of the assessee is partly allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanishri Chandan Chouhan, Dcit, Ward No.24, Nfac Vs. Nath Gali, Delhi Khargone (Appellant / Assessee) (Respondent/ Revenue) Pan: Auxpc9073A Assessee By Shri Ashok Surjan, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 07.10.2024 Date Of Pronouncement 18.10.2024 O R D E R

133(6). 9. The Ld. CIT(A) erred in dismissing the appeal which confirms the action of AO wherein the AO erred in not making first addition of bank deposits 2 ChandanChouhan for which assessment was reopened u/s 147. This assessment is without having jurisdiction u/s 147 which had ceased with non-assessment of bank deposits