JABALPUR DEVELOPMENT AUTHORITY,JABALPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(1), JABALPUR

In the result, appeals filed by the assessee are partly allowed

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.

u/s 147 & 148.” 5.8 CIT vs. Pawan Gupta & Ors. [(2009) 318 ITR 322 (Del) Hon'ble Delhi High Court held in Para 38 of the order observed as under:- "Thus, we are of the clear view that where the assessing officer is not inclined to accept the return of undisclosed assessment filed by the assessee issuance of a notice under

JABALPUR DEVELOPMENT AUTHORITY,JABALPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(1), JABALPUR

In the result, appeals filed by the assessee are partly allowed

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.

u/s 147 & 148.” 5.8 CIT vs. Pawan Gupta & Ors. [(2009) 318 ITR 322 (Del) Hon'ble Delhi High Court held in Para 38 of the order observed as under:- "Thus, we are of the clear view that where the assessing officer is not inclined to accept the return of undisclosed assessment filed by the assessee issuance of a notice under

JABALPUR DEVELOPMENT AUTHORITY,JABALPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(1), JABALPUR

In the result, appeals filed by the assessee are partly allowed

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.

u/s 147 & 148.” 5.8 CIT vs. Pawan Gupta & Ors. [(2009) 318 ITR 322 (Del) Hon'ble Delhi High Court held in Para 38 of the order observed as under:- "Thus, we are of the clear view that where the assessing officer is not inclined to accept the return of undisclosed assessment filed by the assessee issuance of a notice under

JABALPUR DEVELOPMENT AUTHORITY,JABALPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(1), JABALPUR

In the result, appeals filed by the assessee are partly allowed

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.

u/s 147 & 148.” 5.8 CIT vs. Pawan Gupta & Ors. [(2009) 318 ITR 322 (Del) Hon'ble Delhi High Court held in Para 38 of the order observed as under:- "Thus, we are of the clear view that where the assessing officer is not inclined to accept the return of undisclosed assessment filed by the assessee issuance of a notice under

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), 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

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

KADEER KHAN,JABALPUR vs. PR. COMMISSIONER OF INCOME TAX-1, JABALPUR, JABALPUR

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

147 of the Act were initiated on 30/03/2019 upon receipt of information that the assessees had sold land for Rs. 50 lacs, as no capital gain (long term or short term), much less in terms of s. 50C, had been returned by them per their returns of income for the relevant year (copy of the reason/s recorded u/s

SHABANA KHAN,JABALPUR vs. PR-1, JABALPUR. COMMISSIONER OF INCOME TAX, JABALPUR

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

147 of the Act were initiated on 30/03/2019 upon receipt of information that the assessees had sold land for Rs. 50 lacs, as no capital gain (long term or short term), much less in terms of s. 50C, had been returned by them per their returns of income for the relevant year (copy of the reason/s recorded u/s

ALOK KUMAR JAIN ,SAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX (1) JABALPUR, JABALPUR

In the result, the appeal by the assessee is dismissed

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

147 read with section 144B of the Act, dated 17/09/2021 for Assessment Year (AY) 2014-15. 2. The background of facts of the case in brief are that the assessee, who had initially filed his return of income for the relevant year at Rs. 2,28,630, was subject to reassessment on account of failure to disclose fully and truly