LATE SHRI JITENDRA NAGAR THROUGH HIS L/R SMT. DEEPIKA NAGAR,BARAN vs. INCOME TAX OFFICER WARD BARAN, BARAN

In the result, appeal of the assessee is allowed

Bench: The Date Of Hearing.”

Section 148 for AY 2015-16 is invalid, rendering the subsequent assessment proceedings null and void. 4.7 Hon’ble ITAT, Raipur Bench in the case of DCIT v. Vinay Agrawal[2025] 2 TMI 891 order dated 17.02.2025after considering theaforesaid judgment of Hon’ble Supreme Court in Rajeev Bansal (supra) has held: Reopening of assessment - Period of limitation - Bogus purchases

AJAY BAKLIWAL,KOTA vs. ACIT, CENTRAL CIRCLE, KOTA, KOTA

bogus claim in the return filed. However, the question\nto be considered was whether the assessee could be the beneficiary of its own\nfraud or mistake and whether the Assessing Officer was prevented from correcting\nthe same under section 147. It was to be noted that the Explanation to section\n147(2) specifically provides that the excessive relief granted under

NARAIN LAL AGRAWAL,JAIPUR vs. DCIT CIRCLE 1 JAIPUR, JAIPUR

In the result the appeal of the assessee is allowed

151 taxmann.com 18 (Kolkata- Trib.) has held as under:\nSection 56 of the Income-tax Act, 1961 Income from other sources\nChargeable as (Immovable property - Tolerance band) - Assessment year 2018-\n19 - During year, assessee purchased a property and paid consideration which\nwas 5.93 per cent less than stamp duty valuation - Difference between two was\nadded to income of assessee

INCOME TAX OFFICER, WARD-1, BEAWAR vs. SHRI MANOJ AMAR CHAND TAILOR, MASUDA BIJAINAGAR

In the result, the appeal filed by the Revenue is dismissed

151 and 153. 2.3. Section 147 and 153C are not interchangeable but are mutually exclusive sections. It is not the choice of the revenue to invoke either of the two sections at its whims. The scope of the two sections has been legislated differently with a definitive purpose. 2.4. Reliance is placed in the following decisions: a) Hon’ble ITAT

SHRI MANOJ AMAR CHAND TAILOR,MASUDA BIJAINAGAR vs. INCOME TAX OFFICER, WARD-1, BEAWAR

In the result, the appeal filed by the Revenue is dismissed

151 and 153. 2.3. Section 147 and 153C are not interchangeable but are mutually exclusive sections. It is not the choice of the revenue to invoke either of the two sections at its whims. The scope of the two sections has been legislated differently with a definitive purpose. 2.4. Reliance is placed in the following decisions: a) Hon’ble ITAT

ACIT, NCR BUILDING, JAIPUR vs. HANS RAJ AGARWAL, VIDHYADHAR NAGAR JAIPUR

39. In view of the above discussion and findings, memorandum of cross objections No 1/JP/2025 filed by the assessee is allowed

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

2) has time till 31 March 2021 to grant approval. The time limit for Section 151 of the old regime expires on 31 March 2021 because the new regime comes into effect on 1 April 2021. 78. For example, the three year time limit for assessment year 2017-2018 falls for completion on 31 March 2021. It falls during

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SNEHLATA AGARWAL, SIKAR

In the result, the appeals of the revenue in ITA No

purchase receipts\n3. Sale bill cum contract note (Annexure A/5)\n4. Copy of Demat Account\n5. Copy of Bank Account showing the sale receipts\n6. Copy of Return of Income for AY 2016-17 where assessee has\ndeclared income of Rs.45,14,780/- under the head LTCG exempt\nunder section 10(38) of the Act. (Annexure A/1)\nHe also based

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. PRIYA DEWAN, SIKAR

In the result, the appeals of the revenue in ITA No

purchase receipts\n3. Sale bill cum contract note (Annexure A/5)\n4. Copy of Demat Account\n5. Copy of Bank Account showing the sale receipts\n6. Copy of Return of Income for AY 2016-17 where assessee has\ndeclared income of Rs.45,14,780/- under the head LTCG exempt\nunder section 10(38) of the Act. (Annexure A/1)\nHe also based

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SUBHASH CHANDRA BANKA, SIKAR

In the result, the appeals of the revenue in ITA No

purchase receipts\n3. Sale bill cum contract note (Annexure A/5)\n4. Copy of Demat Account\n5. Copy of Bank Account showing the sale receipts\n6. Copy of Return of Income for AY 2016-17 where assessee has\ndeclared income of Rs.45,14,780/- under the head LTCG exempt\nunder section 10(38) of the Act. (Annexure A/1)\nHe also based

DCIT, CENTRAL CIRCLE-1, JAIPUR , JAIPUR vs. USHA BANKA, SIKAR

In the result, the appeals of the revenue in ITA No

purchase receipts\n3. Sale bill cum contract note (Annexure A/5)\n4. Copy of Demat Account\n5. Copy of Bank Account showing the sale receipts\n6. Copy of Return of Income for AY 2016-17 where assessee has\ndeclared income of Rs.45,14,780/- under the head LTCG exempt\nunder section 10(38) of the Act. (Annexure A/1)\nHe also based

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SARITA DEWAN, SIKAR

In the result, the appeals of the revenue in ITA No

purchase receipts\n3. Sale bill cum contract note (Annexure A/5)\n4. Copy of Demat Account\n5. Copy of Bank Account showing the sale receipts\n6. Copy of Return of Income for AY 2016-17 where assessee has\ndeclared income of Rs.45,14,780/- under the head LTCG exempt\nunder section 10(38) of the Act. (Annexure A/1)\nHe also based

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SARITA DEWAN, SIKAR

In the result, the appeals of the revenue in ITA No

purchase receipts\n3. Sale bill cum contract note (Annexure A/5)\n4. Copy of Demat Account\n5. Copy of Bank Account showing the sale receipts\n6. Copy of Return of Income for AY 2016-17 where assessee has\ndeclared income of Rs.45,14,780/- under the head LTCG exempt\nunder section 10(38) of the Act. (Annexure A/1)\nHe also based

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. USHA BANKA, SIKAR

In the result, the appeals of the revenue in ITA No

purchase receipts\n3. Sale bill cum contract note (Annexure A/5)\n4. Copy of Demat Account\n5. Copy of Bank Account showing the sale receipts\n6. Copy of Return of Income for AY 2016-17 where assessee has\ndeclared income of Rs.45,14,780/- under the head LTCG exempt\nunder section 10(38) of the Act. (Annexure A/1)\nHe also based

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. TRILOK DEWAN, SIKAR

In the result, the appeals of the revenue in ITA No

purchase receipts\n3. Sale bill cum contract note (Annexure A/5)\n4. Copy of Demat Account\n5. Copy of Bank Account showing the sale receipts\n6. Copy of Return of Income for AY 2016-17 where assessee has\ndeclared income of Rs.45,14,780/- under the head LTCG exempt\nunder section 10(38) of the Act. (Annexure A/1)\nHe also based

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. PRIYA DEWAN, SIKAR

In the result, the appeals of the revenue in ITA No

purchase receipts\n3. Sale bill cum contract note (Annexure A/5)\n4. Copy of Demat Account\n5. Copy of Bank Account showing the sale receipts\n6. Copy of Return of Income for AY 2016-17 where assessee has\ndeclared income of Rs.45,14,780/- under the head LTCG exempt\nunder section 10(38) of the Act. (Annexure A/1)\nHe also based

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. VIPUL BANKA, SIKAR

In the result, the appeals of the revenue in ITA No

purchase receipts\n3. Sale bill cum contract note (Annexure A/5)\n4. Copy of Demat Account\n5. Copy of Bank Account showing the sale receipts\n6. Copy of Return of Income for AY 2016-17 where assessee has\ndeclared income of Rs.45,14,780/- under the head LTCG exempt\nunder section 10(38) of the Act. (Annexure A/1)\nHe also based

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. ANIMESH AGARWAL, SIKAR

In the result, the appeals of the revenue in ITA No

purchase receipts\n3. Sale bill cum contract note (Annexure A/5)\n4. Copy of Demat Account\n5. Copy of Bank Account showing the sale receipts\n6. Copy of Return of Income for AY 2016-17 where assessee has\ndeclared income of Rs.45,14,780/- under the head LTCG exempt\nunder section 10(38) of the Act. (Annexure A/1)\nHe also based

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SNEHLATA AGARWAL, SIKAR

In the result, the appeals of the revenue in ITA No

purchase receipts\n3. Sale bill cum contract note (Annexure A/5)\n4. Copy of Demat Account\n5. Copy of Bank Account showing the sale receipts\n6. Copy of Return of Income for AY 2016-17 where assessee has\ndeclared income of Rs.45,14,780/- under the head LTCG exempt\nunder section 10(38) of the Act. (Annexure A/1)\n\nHe also

BHASKAR CHOUHAN,JAIPUR vs. INCOME TAX OFFICER, SIKAR

purchases made\nagainst these sales nor rejected appellant's books of accounts.\n4.2.1 Section 69A stipulates that, Where in any financial year the\nassessee is found to be the owner of any money, bullion jewellery or\nother valuable article and such money, bullion, jewellery or valuable\narticle is not recorded in the books of account, if any, maintained