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

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

justice and liable to be set aside. 4. 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

SHRI NITIN SHARMA,JABALPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX -2, JABALPUR

In the result, the appeal is partly allowed

Bench: Shri N.R.S. Ganesan & Shri Sanjay Arora

reassessment proceedings, for the benefit of the 5 | P a g e Nitin Sharma v. Pr. CIT Revenue. Suffice to state that we find the assessment proceedings to have been validly initiated, and the absence of jurisdictional fact for proceeding u/s. 153A(1) r/w s. 153C. The finality of concluded proceedings cannot be lightly, if at all, disturbed

M/S ANUSHREE ENGINEERING,JABALPUR vs. INCOME TAX OFFICER, JABALPUR

In the result, subject to the caveat stated at para 3

Bench: Sh. Sanjay Arora, Hon'Ble

u/s. 147 and, accordingly, penalty levied at Rs. 60, 275. The assessee filed appeal against both these orders as well. The quantum appeals were taken up together for hearing by the first appellate authority. The ld. CIT(A), as explained by Sh. Usrethe, the ld. Counsel for the assessee, observing two appeals for the same year, which were

M/S.ANUSHRI ENGINEERING,JABALPUR vs. INCOME TAX OFFICER WARD 2(1), JABALPUR

In the result, subject to the caveat stated at para 3

Bench: Sh. Sanjay Arora, Hon'Ble

u/s. 147 and, accordingly, penalty levied at Rs. 60, 275. The assessee filed appeal against both these orders as well. The quantum appeals were taken up together for hearing by the first appellate authority. The ld. CIT(A), as explained by Sh. Usrethe, the ld. Counsel for the assessee, observing two appeals for the same year, which were

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

SHRI ANAND PANDEY,REWA vs. PRINCIPAL COMMISSIONER OF INCOME TAX-2, JABALPUR

In the result, the assessee‟s appeal is dismissed

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

147 r/w s. 143(3) of the Act dated 11/09/2017 for the Assessment Year (AY) 2010-11. 2.1 The brief facts of the case are that the assessee, along with one Shri Rakesh Singh, purchased a property, valued at Rs. 31.50 lacs (as per AIR information), on 10/08/2009, i.e., during the relevant year, for a stated consideration

SUNIL KUMAR PATHAK,REWA vs. INCOME TAX OFFICER WARD -1, , REWA

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

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadalesunil Kumar Pathak Vs. Ito, Ward – 1, 3Rd Floor, A Block, Shilpi Rewa-486001, Plaza, Pili Kothi, Madhya Pradesh. Rewa-486001, Madhya Pradesh. Pan/Gir No. : Arwpp9628A Appellant .. Respondent Appellant By : Shri.Dhiraj Ghai.Fca.Ar Respondentby : Shri.Shiv Kumar. Sr.Dr Date Of Hearing 15.09.2023 Date Of Pronouncement 10.11.2023 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of The National Faceless Appeal Centre (Nfac) / Cit(A) Passed U/Sec 144 & 250 Of The Act. The Assessee Has Raised The Following Grounds Of Appeal:

natural justice. 2. On the facts and circumstances of the case Id CIT (A) erred in not considering notice under section 148 issued on 22/3/2018 as defective and resulting assessment order as bad in law on reason that AO has recorded reason for reopening in the name of Shri SUNIL KUMAR PATHAK legal hier of late Ram Karan Pathak while

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(1), JABALPUR vs. MADHYA PRADESH POWER GENERATING CO. LTD., JABALPUR

In the result, the Revenue's appeal is dismissed as not maintainable

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

147 r/w s. 143(3) dated 21.3.2016. The same was further modified u/s.154 (on 11.01.2017) to bring on record the income under Minimum Alternate Tax (MAT) regime at Rs. 817.29 lacs, which income had remained unchanged. The said reassessment and modification were not challenged in appeal', attaining finality. 2.2 In the penalty proceedings, initiated on 21.3.2016, the assessee's explanation