SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

Bench: This Tribunal Are As Under :

Charitable Trust). • The transfer is a lawful administrative act within the Commissioner’s discretion (Pannalal Binjraj; Kashiram Aggarwalla). • Procedural safeguards were satisfied: notice, opportunity, and communication of reasons (Ajantha Industries; Genus Electrotech). • Under the faceless regime, territorial inconvenience is illusory (Ashapura Enterprises). • The challenge to the Section 127 order, therefore, deserves rejection. Reliefs prayed (without prejudice to the preliminary objection

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

Bench: This Tribunal Are As Under :

Charitable Trust). • The transfer is a lawful administrative act within the Commissioner’s discretion (Pannalal Binjraj; Kashiram Aggarwalla). • Procedural safeguards were satisfied: notice, opportunity, and communication of reasons (Ajantha Industries; Genus Electrotech). • Under the faceless regime, territorial inconvenience is illusory (Ashapura Enterprises). • The challenge to the Section 127 order, therefore, deserves rejection. Reliefs prayed (without prejudice to the preliminary objection

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

Bench: This Tribunal Are As Under :

Charitable Trust). • The transfer is a lawful administrative act within the Commissioner’s discretion (Pannalal Binjraj; Kashiram Aggarwalla). • Procedural safeguards were satisfied: notice, opportunity, and communication of reasons (Ajantha Industries; Genus Electrotech). • Under the faceless regime, territorial inconvenience is illusory (Ashapura Enterprises). • The challenge to the Section 127 order, therefore, deserves rejection. Reliefs prayed (without prejudice to the preliminary objection

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

Bench: This Tribunal Are As Under :

Charitable Trust). • The transfer is a lawful administrative act within the Commissioner’s discretion (Pannalal Binjraj; Kashiram Aggarwalla). • Procedural safeguards were satisfied: notice, opportunity, and communication of reasons (Ajantha Industries; Genus Electrotech). • Under the faceless regime, territorial inconvenience is illusory (Ashapura Enterprises). • The challenge to the Section 127 order, therefore, deserves rejection. Reliefs prayed (without prejudice to the preliminary objection

ARUN KUMAR PALAWAT,JAIPUR vs. PR CIT, JAIPUR-1, JAIPUR, JAIPUR

In the result, this appeal of the assessee is allowed

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

Charitable Trust (1987) 167 ITR (129) (Rajasthan), CIT Vs. Godawari Sugar Mills Ltd. (1993) 203 ITR 108 (Bom.) and CIT Vs. Shakti Charities (2000) 160 CTR 107 (Mad.). The facts and submissions are verifiable from the assessment record. The Supreme Court in case of CIT Vs. Green World Corporation (2009) 314 ITR 81 (Supreme Court) held that ‘The jurisdiction under

ALLEN CAREER INSTITUTE,JAIPUR vs. JCIT, KOTA

In the result, the appeal of the assessee is partly allowed

charitable trust and not incurred for business purpose. The disallowance so made and confirmed by the ld. CIT(A) is contrary to the provision of law and hence, kindly be deleted in full 3.2. Rs.2,45,919/-: The ld. CIT(A) erred in law as well as on the facts of the case in confirming the disallowance of interest

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

Charitable Trust v. DCIT (Raj HC) — where notice warned that\nnon-response would be treated as “no objection,” silence led the Court to\npresume no objection and uphold transfer (Paper Book 1 Page No. 129 to 143).\nΟ Vishal Darshanlal Talreja v. PCIT (Guj HC, 2025) similar facts; vague\ninconvenience pleas rejected; transfer upheld (Paper Book 143 to 156).\nDuty

ALLEN CAREER INSTITUTE,KOTA vs. JCIT, JAIPUR

In the result, the Grounds No

charitable trust and not incurred for business purpose. The disallowance so made and confirmed by the ld. CIT(A) is contrary to the provision of law and hence, kindly be deleted in full 4. Rs.23,64,158/-: The ld. CIT(A) erred in law as well as on the facts of the case in confirming the disallowance of Rs.23

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

Charitable or\nreligious trust Exemption of income from property held under (Audit objection)\n Assessment year 2016-17 Assessment of assessee-trust was completed under section\n143(3) at 'Nil' income - Revenue audit party, however, objected to finalization of retum of\nassessee-trust at 'Nil' for reason that during year, assessee received corpus donations\nwhich were not included in income

SHRI JITENDRA KUMAR GUPTA,BHARATPUR vs. INCOME TAX OFFICER, WARD-2, BHARATPUR

In the result, the appeals for the assessment year 2011-12 is dismissed and for the assessment year 2012-13 is allowed

Bench: Or During The Course Of Hearing.”

trust. The AO has given the details of the aggregate annual receipt of Rs. 36,05,243/- out of which an amount of Rs. 32,99,012/- was found to be incurred upon charitable activities during the year under consideration. Subsequently, the AO proposed to reopen the assessment by issuing a notice u/s 148 on 16.03.2015. The reassessment framed

SHRI JITENDRA KUMAR GUPTA,BHARATPUR vs. INCOME TAX OFFICER, WARD-2, BHARATPUR

In the result, the appeals for the assessment year 2011-12 is dismissed and for the assessment year 2012-13 is allowed

Bench: Or During The Course Of Hearing.”

trust. The AO has given the details of the aggregate annual receipt of Rs. 36,05,243/- out of which an amount of Rs. 32,99,012/- was found to be incurred upon charitable activities during the year under consideration. Subsequently, the AO proposed to reopen the assessment by issuing a notice u/s 148 on 16.03.2015. The reassessment framed

SHRI RADHA GOVIND LASHKARI,JAIPUR vs. PCIT-2, JAIPUR

In the result, this appeal of the assessee is allowed

Charitable Trust (1987) 167 ITR (129) (Rajasthan), CIT Vs. Godawari Sugar Mills Ltd. (1993) 203 ITR 108 (Bom.) and CIT Vs. Shakti Charities (2000) 160 CTR 107 (Mad.). The facts and submissions are verifiable from the assessment record. The Hon’ble Supreme Court in case of CIT Vs. Green World Corporation (2009) 314 ITR 81 (SC) held that ‘The jurisdiction

ALLEN CAREER INSTITUTE,JAIPUR vs. JCIT, KOTA

In the result, the appeal of the assessee is partly allowed

221 CTR (Bom) 435 : (2009) 18 DTR (Bom) 1 : (2009) 313 ITR 340 (Bom) and Hon’ble Delhi High Court in the case of CIT vs. Bharti Televenture Ltd. (2011) 51 DTR (Del) 98 : 2010- TIOL-51-HC-Del. There is no provision in the Act which may compel an assessee to earn income

PROFESSIONAL AUTOMOTIVES PRIVATE LIMITED,JAMMU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JAIPUR

In the result the appeal of the assessee in ITA no

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील /ITA Nos.809 to 815/JP/2025 निर्धारण वर्ष /Assessment Years :2013-14 to 2019-20 Professional Automotives Pvt. बनाम ACIT, Ltd. Bahu Plaza, Bahu Plaza, Jammu Vs. Central Circle- 1, and Kashmir Jaipur स्थायी लेखा सं./जी.आई.आर. सं./PAN/GIR No.:AAACP9608E अपीलार्थी/Appellant प्र]त्यर्थी/Respondent निर्धारिती की ओर से / Assessee by :Shri Tarun Mittal, CA राजस्व की ओर से /Revenue by: Shri Ajey Malik, CIT (Th. V.C)

221 also, the Hon'ble Supreme Court has observed that fraud vitiates all judicial acts whether in rem or in personam and that a judgment, decree or order obtained by fraud has to be treated as non-est and nullity, whether by the Court of first instance or by the final Court and that the same can be challenged

RAJESH PRODUCTS,TONK ,RAJASTHAN vs. ACIT, JAIPUR

221 aiso, the Hon'ble\nSupreme Court has observed that fraud vitiates all judicial acts whether in rem or\nin personam and that a judgment, decree or order obtained by fraud has to be\ntreated as non-est and nullity, whether by the Court of first instance or by the final\nCourt and that the same can be challenged

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.

Charitable Trust [1987] 65 CTR (Raj.) 30 : [1987] 167 ITR 129 (Raj.) Thus it is clear that Assessing Officer has made enquiry but sufficiency of enquiry can be depend upon from person to person. The AO cannot remain passive in the face of a return which is apparently in order but calls for further enquiry. It is the duty

PALSANA GRAM SEWA SAHKARI SAMITI LTD.,PALASANA 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.

Charitable Trust [1987] 65 CTR (Raj.) 30 : [1987] 167 ITR 129 (Raj.) Thus it is clear that Assessing Officer has made enquiry but sufficiency of enquiry can be depend upon from person to person. The AO cannot remain passive in the face of a return which is apparently in order but calls for further enquiry. It is the duty

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.

Charitable Trust [1987] 65 CTR (Raj.) 30 : [1987] 167 ITR 129 (Raj.) Thus it is clear that Assessing Officer has made enquiry but sufficiency of enquiry can be depend upon from person to person. The AO cannot remain passive in the face of a return which is apparently in order but calls for further enquiry. It is the duty