DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 1(1), JABALPUR vs. M/S.TDP & ASSOCIATES, JABALPUR

In the result, both the Revenue’s appeal and the assessee’s CO are dismissed

Bench: Shri Sanjay Arora, Hon’Ble & Shri Manomohan Das, Hon'Ble

147 read with section 143(3) of the 1 | P a g e C.O.No. 01/JAB/2022 TDP & Associates Income Tax Act, 1961 (‘the Act’ hereinafter) dated 28/12/2017 for Assessment Year (AY) 2012-13. 2. The appeal, initially dismissed by the Tribunal on 23/08/2019 on account of low tax-effect, was later recalled vide order u/s. 254(2) dated 27/04/2022 for being

SAURABH SINGHAI L/H LATE SHRI MAHENDRA KUMAR JAIN,SAGAR vs. INCOME TAX OFFICER-3 SAGAR, SAGAR

In the result, the assessee‟s appeal is dismissed

Bench: Sh. Sanjay Arora, Hon'Ble & Sh. Manomohan Das, Hon‟Ble

147 of the Act, the power of revision under section 263 is not contingent on the giving of a notice to show cause. In fact, section 263 has been understood not to require any specific show-cause notice to be served on the assessee. Rather, what is required under the provision is an opportunity of hearing to the assessee

DINESH JAT,SAGAR vs. CIT (A), SAGAR

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

Reassessment is Without Proper Foundation - Absence of Tangible Material The reopening of the assessment under section 147 is purely based on AIR-reported bank deposits without any independent verification or tangible evidence. This amounts to a borrowed satisfaction, which has been consistently held by judicial forums (including Harmeet Singh vs. ITO) as invalid and unsustainable in law. 5. Addition

DINESH JAT,SAGAR vs. CIT(A), NFAC

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

Reassessment is Without Proper Foundation - Absence of Tangible Material The reopening of the assessment under section 147 is purely based on AIR-reported bank deposits without any independent verification or tangible evidence. This amounts to a borrowed satisfaction, which has been consistently held by judicial forums (including Harmeet Singh vs. ITO) as invalid and unsustainable in law. 5. Addition