PALSANA GRAM SEWA SAHKARI SAMITI LTD.,PALSANA vs. PCIT-2, JAIPUR

In the result, all these three appeals of the assessee are allowed

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 35 To 37/Jp/2021 Assessment Years: 2010-11 To 2012-13 Palsana Gram Sewa Sahkari Samiti Cuke Pr.Cit-2, Vs. Limited, Jaipur. Village- Palsana Main Market, Palsana, Dist.- Sikar- 332402 (Raj) Pan No.: Aabap 8390 A Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri Shrawan Kr. Gupta (Adv) Jktlo Dh Vksj Ls@ Revenue By : Shri B.K. Gupta (Pr.Cit-Dr) Lquokbz Dh Rkjh[K@ Date Of Hearing : 04/08/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 02/11/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. These Are The Appeals Filed By The Assessee Against The Separate Order Of The Ld. Pr.Cit-2, Jaipur All Dated 31/03/2021 Passed U/S 263 Of The Income Tax Act, 1961 (In Short, The Act) For The A.Y. 2010-11 To 2012-13. 2. The Hearing Of The Appeal Was Concluded Through Video Conference In View Of The Prevailing Situation Of Covid-19 Pandemic.

80P was not there. And till date the position is same there is no change. It was not a regular assessment it was a reassessment for the limited purpose or issue and on perusal of the entire record or detailed it cannot be said that the ld. AO has not made inquiries. As admittedly the case of the assessee

PALSANA GRAM SEWA SAHKARI SAMITI LTD.,JAIPUR vs. PCIT-2, JAIPUR

In the result, all these three appeals of the assessee are allowed

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 35 To 37/Jp/2021 Assessment Years: 2010-11 To 2012-13 Palsana Gram Sewa Sahkari Samiti Cuke Pr.Cit-2, Vs. Limited, Jaipur. Village- Palsana Main Market, Palsana, Dist.- Sikar- 332402 (Raj) Pan No.: Aabap 8390 A Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri Shrawan Kr. Gupta (Adv) Jktlo Dh Vksj Ls@ Revenue By : Shri B.K. Gupta (Pr.Cit-Dr) Lquokbz Dh Rkjh[K@ Date Of Hearing : 04/08/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 02/11/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. These Are The Appeals Filed By The Assessee Against The Separate Order Of The Ld. Pr.Cit-2, Jaipur All Dated 31/03/2021 Passed U/S 263 Of The Income Tax Act, 1961 (In Short, The Act) For The A.Y. 2010-11 To 2012-13. 2. The Hearing Of The Appeal Was Concluded Through Video Conference In View Of The Prevailing Situation Of Covid-19 Pandemic.

80P was not there. And till date the position is same there is no change. It was not a regular assessment it was a reassessment for the limited purpose or issue and on perusal of the entire record or detailed it cannot be said that the ld. AO has not made inquiries. As admittedly the case of the assessee

RMS KARAMCHARI BACHAT AND SAKH SAHAKARI SAMITI LIMITED JAIPUR,JAIPUR vs. ITO, WARD-1(2), JAIPUR, JAIPUR

In the result, the appeals of the assessee are allowed

80P.\n2.4 This clear disconnect between the reasons recorded and the additions made is fatal to\nthe validity of the reassessment. The law requires that there must be a live link or nexus\nbetween the reasons which formed the foundation of the belief of escapement of income\nand the additions ultimately made in assessment. In the present case, that nexus

RMS KARAMCHARI BACHAT AND SAKH SAHAKARI SAMITI LIMITED JAIPUR,JAIPUR vs. ITO WARD-1(2), JAIPUR, JAIPUR

In the result, the appeals of the assessee are allowed

80P.\n2.4 This clear disconnect between the reasons recorded and the additions made is fatal to\nthe validity of the reassessment. The law requires that there must be a live link or nexus\nbetween the reasons which formed the foundation of the belief of escapement of income\nand the additions ultimately made in assessment. In the present case, that nexus

RMS KARAMCHARI BACHAT AND SAKH SAHAKARI SAMITI LIMITED JAIPUR,JAIPUR vs. ITO WARD-1(2), JAIPUR, JAIPUR

In the result, the appeals of the assessee are allowed

80P.\n2.4 This clear disconnect between the reasons recorded and the additions made is fatal to\nthe validity of the reassessment. The law requires that there must be a live link or nexus\nbetween the reasons which formed the foundation of the belief of escapement of income\nand the additions ultimately made in assessment. In the present case, that nexus

RMS KARAMCHARI BACHAT AND SAKH SAHAKARI SAMITI LIMITED JAIPUR,JAIPUR vs. ITO WARD-1(2), JAIPUR, JAIPUR

In the result, the appeals of the assessee are allowed

80P.\n\n2.4 This clear disconnect between the reasons recorded and the additions made is fatal to\nthe validity of the reassessment. The law requires that there must be a live link or nexus\nbetween the reasons which formed the foundation of the belief of escapement of income\nand the additions ultimately made in assessment. In the present case, that

SAJJAD ALI,CHITTORGARH vs. DCIT(INTL)- JAIPUR, JAIPUR

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

bogus, not verifiable and not correct. 2. Case reopened u/s 148 for limited issue: Further when the very basis of reopening of the case under section 148 was on account of investment in purchase of immovable property, then how it can be said that the AO has failed to make the inquiry, where the scope of inquiry is limited only

NIRMAL KUMAR AGRAWAL,JAIPUR vs. DCIT, CIRCLE - 4 , JAIPUR

In the result, the appeal of the assessee is allowed

Bogus Long Term Capital Gain/Loss to the beneficiaries; by receiving cash and the purchase and sale of share was done to route the unaccounted income into legal money. The financials of the company for the relevant period do not show any substantial change to support by financial fundamentals of the company. Both purchase and sale of the shares are concentrated

ANIL KUMAR BATAR,SIKAR vs. PCIT-JAIPUR-2, JAIPUR

In the result, the appeal of the assessee is allowed

80P(2)(d)\"\nCopy of order is enclosed.\n(3.3) Latest decision of this Honble Bench in the In the case of\nMahendra Singh Dhankhar HUF vs. ACIT ITA No. 265/JP/2020 Jun\n30, 2021 (2021) 62 CCH 0271 JaipurTribwhere It has been held that\n“Revision-Ordering revision where case is selected for limited\nscrutiny-Assessee firm is a real