ACIT, JAIPUR vs. UDAI BUILDHOME PVT LTD, JAIPUR

In the result, all the appeals of the revenue are dismissed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, JM आयकर अपील सं. / ITA Nos.1399, 1400, 1401 & 1486/JP/2024 निर्धारण वर्ष / Assessment Years : 2014-15, 2015-16, 2017-18 & 2018-19 Asstt. Commissioner of Income Tax, Central Circle-02, Jaipur बनाम Vs. M/s Udai Buildhome Pvt. Ltd. 302, Golden Sunrise Apartment, Lajpat Marg, C- Scheme, Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AABCU 5068 J अपीलार्थी / Appellant निर्धारिती की ओर से / Assessee by: प्रत्यर्थी / Respond

bogus companies ACIT vs. M/s Udai Buildhome Pvt. Ltd. which includes the lender company M/s Inner Mercantile Pvt. Ltd. The Inspector report reveals that it is clear that the companies are not in existence in their registered addresses and holding offices but on those addresses a combined office of various companies were found, which is used only for receiving

SH. KAPIL TANEJA,JAIPUR vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, JAIPUR

In the result, the appeal of the assessee is allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

Bogus purchase) - Certain portion of purchases made by assessee was disallowed - Commissioner (Appeals) found that entire disallowance was based on third party information gathered by Investigation Wing of Department, which had not been independently subjected to further verification by Assessing Officer and he had not provided copy of such statements to appellant, thus, denying opportunity of cross examination to appellant

DCIT, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. KAMLAPRABHA L/H OF LATE SHRI GOPAL LAL JI GOSWAMI, KOTA

In the result, the appeal of the revenue is dismissed and the Cross objection of the assessee is disposed off in terms of the observation made herein above

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

153C must have been issued prior thereto but, in any case, not later than 30.09.2020, or the impugned assessment order must have been passed not later than 30.09.2020, as against which the said notices have been issued only 47 ITA No. 94 & CO. No. 22/JPR/2025 Smt. Kamla Prabha L/h Late Sh. Gopal Lal Ji Goswami on 22.03.2022 and the impugned

GEMCO INTERNATIONAL,JAIPUR vs. INCOME TAX OFFICER WARD 2(1), JAIPUR

In the result, the appeal filed by the assessee stands partly allowed with no order as to cost

Bench: SHRI SANDEEP GOSAIN (Judicial Member)

bogus purchases from these two concerns. Therefore, the AO was well within his jurisprudence to reopen the case of the appellant u/s 148, having “reasons to believe” that some income has escaped assessment well within the meaning of section 148. Besides, the appellant never raised these issues before the AO and raising an academic issue like at the appellate stage

ACIT, JAIPUR vs. M/S UDAI BUILDHOME PVT LTD., JAIPUR

In the result, all the appeals of the revenue are dismissed

bogus companies\nwhich includes the lender company M/s Inner Mercantile Pvt. Ltd. The\nInspector report reveals that it is clear that the companies are not in\nexistence in their registered addresses and holding offices but on those\naddresses a combined office of various companies were found, which is\nused only for receiving Dak (mail). Hence in the field enquiry

INCOME TAX OFFICER , SIKAR vs. BHASKAR CHAUHAN, JAIPUR

In the result the appeal of the revenue in ITA no

Bench: Him.

153C in the absence of any incriminating material pertaining to the appellant found during course of search under section 132 or requisition under section 132A. However third party information from sources other than seized material belonging to the appellant, shall be relied upon by the assessing officer to complete assessment u/s 143 rws 144. As a result, ground

PRAMILA AGARWAL,JAIPUR vs. THE INCOME TAX OFFICER WARD-2(5), JAIPUR

In the result, the appeal of the assessee is allowed

153C\nr.w.s.153A and the provisions of section 147/148 of the Act are not applicable in\nsuch cases. No contrary decision has been brought to our notice. Accordingly, we\nhold that initiation of proceedings u/s 147/148 by the AO to reassess the income is\nillegal being without jurisdiction and consequently the reassessment order passed\nu/s 147 r.w.s.143(3) is also illegal

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. SAPNA KARNANI, TONK PHATAK

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

sections 153A and 153C of the Act.”\niv.The Hon'ble Delhi High Court in the case of PCIT (Central) vs Agson Global Pvt\nLtd "dismissed a bunch of appeals against deletion of addition u/s 68 towards\nShare capital/ share premium, bogus purchases

MACRO PROPRIETIES PRIVATE LIMITED,M 28 INCOME TAX COLONY TONK ROAD JAIPUR vs. DCIT CENTRAL CIRCLE 2, LIC BUILDING JAIPUR

In the result, the appeals of the assessee are allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;djvihy la-@ITA No.174 TO 177/JP/2023 fu/kZkj.ko"kZ@AssessmentYear : 2013-14 TO 2016-17 M/s. Macro Properties Pvt. Ltd.M-28, Income Tax Colony, Tonk Road Jaipur cuke Vs. The DCIT Central Circle-2 LIC Building, Jaipur LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAFCM 3633 D vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksjls@Assesseeby : Shri C.M. Agarwal, CA jktLo dh vksjls@Revenue by: Shri JameshKurian, CI

Section 153C of the Income Tax Act. 6. The Assessing Officer has not recorded satisfaction in respect of each of the assessment years before issuing notice u/s 153C of the Income Tax Act relating seized Books of accounts or documents to each assessment year separately. 7. The Assessing Officer has not recorded satisfaction about incriminating nature of the Books

SHRI KHANDELWAL DIAMONDS PRIVATE LIMITED,JAIPUR vs. ACIT, CIRCLE 1, JAIPUR, JAIPUR

In the result, appeal of the assessee is partly allowed

Bench: Him On The Reason Of Issuing Notice U/S 148 On Borrowed Satisfaction Of Another Wing Of The Department.

bogus purchase bills pertains to diamonds [ bills at page 4,13 & 24 ]. The profit in this diamond business computed at page 41 comes to 5.96 % as computed here in below : Sales of Diamond Rs. 3,19,10,125/- Closing stock of Diamond Rs. 29,93,033/- Total Rs. 3,49,03,158/- Purchase of Diamond

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. SAPNA KARNANI, TONK PHATAK

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

sections 153A and 153C of the Act.”\niv.The Hon'ble Delhi High Court in the case of PCIT (Central) vs Agson Global Pvt\nLtd \"dismissed a bunch of appeals against deletion of addition u/s 68 towards\nShare capital/ share premium, bogus purchases

BHASKAR CHOUHAN,JAIPUR vs. INCOME TAX OFFICER, SIKAR

153C in the absence of any incriminating\nmaterial pertaining to the appellant found during course of search under\nsection 132 or requisition under section 132A. However third party\ninformation from sources other than seized material belonging to the\nappellant, shall be relied upon by the assessing officer to complete\nassessment u/s 143 rws 144. As a result, ground

MACRO TOWNSHIP PVT LTD,288-289 MAHAVEER NAGAR DURGAPURA JAIPUR vs. DCIT CC -2 JAIPUR, LIC BUILDING JAIPUR

In the result, the appeals of the assessee are allowed

Bench: HON’BLE SHRI SANDEEP GOSAIN, JM & HON’BLE SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

Section 153C of the Income Tax Act. 6. The Assessing Officer has not recorded satisfaction in respect of each of the assessment years before issuing notice u/s 153C of the Income Tax Act relating seized Books of accounts or documents to each assessment year separately. M/s. Macro Township Pvt. Ltd., Jaipur. 7. The Assessing Officer has not recorded satisfaction about

MACRO TOWNSHIP PVT LTD,288-289 MAHAVEER NAGAR DURGAPURA JAIPUR vs. DCIT CC -2 JAIPUR , LIC BUILDING JAIPUR

In the result, the appeals of the assessee are allowed

Bench: HON’BLE SHRI SANDEEP GOSAIN, JM & HON’BLE SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

Section 153C of the Income Tax Act. 6. The Assessing Officer has not recorded satisfaction in respect of each of the assessment years before issuing notice u/s 153C of the Income Tax Act relating seized Books of accounts or documents to each assessment year separately. M/s. Macro Township Pvt. Ltd., Jaipur. 7. The Assessing Officer has not recorded satisfaction about

MACRO TOWNSHIP PVT LTD,288-289 MAHAVEER NAGAR DURGAPURA JAIPUR vs. DCIT CC-2 JAIPUR, LIC BUILDING JAIPUR

In the result, the appeals of the assessee are allowed

Bench: HON’BLE SHRI SANDEEP GOSAIN, JM & HON’BLE SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

Section 153C of the Income Tax Act. 6. The Assessing Officer has not recorded satisfaction in respect of each of the assessment years before issuing notice u/s 153C of the Income Tax Act relating seized Books of accounts or documents to each assessment year separately. M/s. Macro Township Pvt. Ltd., Jaipur. 7. The Assessing Officer has not recorded satisfaction about

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. SAPNA KARNANI, TONK PHATAK

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

sections 153A and 153C of the Act.”\n\niv.The Hon'ble Delhi High Court in the case of PCIT (Central) vs Agson Global Pvt\nLtd \"dismissed a bunch of appeals against deletion of addition u/s 68 towards\nShare capital/ share premium, bogus purchases

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. SAPNA KARNANI, TONK PHATAK

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

sections 153A and 153C of the Act.” iv. The Hon’ble Delhi High Court in the case of PCIT (Central) vs Agson Global Pvt Ltd “dismissed a bunch of appeals against deletion of addition u/s 68 towards Share capital/ share premium, bogus purchases

DEPUTY COMMISSIONER OF INCOME TAX , JAIPUR vs. BHARAT SPUN PIPE AND CONSTRUCTION COMPANY, JAIPUR

In the result the appeal of the revenue in ITA no

purchases and\nassessee is one of the beneficiaries who has carried out bogus transaction with\nM/s DRAIPL to the extent of Rs.6,46,31,000/- in the relevant assessment year\nand accordingly reached to the satisfaction that income to this extent has escaped\nassessment.\n\nFrom perusal of above, it is crystal clear that information, based on which notice\nu/s