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

seizure”. Both these provisions, therefore,\nhave to be read together. Section 153A is indeed an extremely potent power\nwhich enables the Revenue to reopen at least six years of preceding assessment\nyear of search. It is not to be exercised lightly. It is only if during the course of\nsearch under section 132, incriminating material justifying the reopening

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

seizure”. Both these provisions, therefore,\nhave to be read together. Section 153A is indeed an extremely potent power\nwhich enables the Revenue to reopen at least six years of preceding assessment\nyear of search. It is not to be exercised lightly. It is only if during the course of\nsearch under section 132, incriminating material justifying the reopening

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

seizure”. Both these provisions, therefore,\nhave to be read together. Section 153A is indeed an extremely potent power\nwhich enables the Revenue to reopen at least six years of preceding assessment\nyear of search. It is not to be exercised lightly. It is only if during the course of\nsearch under section 132, incriminating material justifying the reopening

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

In the result, the appeals of the revenue stands dismissed, and the

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

seizure operation. 15.1 In view of the discussion hereinabove, once during search undisclosed income is found on unearthing the incriminating material during the search, the AO would assume jurisdiction to assess or reassess the total income even in case of completed/unabated assessments. Therefore, the impugned judgment(s) and order(s) passed by the High Court taking the view that

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

In the result, the appeals of the revenue stands dismissed, and the

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

seizure operation. 15.1 In view of the discussion hereinabove, once during search undisclosed income is found on unearthing the incriminating material during the search, the AO would assume jurisdiction to assess or reassess the total income even in case of completed/unabated assessments. Therefore, the impugned judgment(s) and order(s) passed by the High Court taking the view that

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

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

seizure operation.\n\n15.1 In view of the discussion hereinabove, once during search undisclosed\nincome is found on unearthing the incriminating material during the search, the AO\nwould assume jurisdiction to assess or reassess the total income even in case of\ncompleted/unabated assessments. Therefore, the impugned judgment(s) and\norder(s) passed by the High Court taking the view that

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

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

seizure operation.\n15.1 In view of the discussion hereinabove, once during search undisclosed\nincome is found on unearthing the incriminating material during the search, the AO\nwould assume jurisdiction to assess or reassess the total income even in case of\ncompleted/unabated assessments. Therefore, the impugned judgment(s) and\norder(s) passed by the High Court taking the view that

SHRI MADHO LAL SAINI,JAIPUR vs. ITO, WARD-2(3), JAIPUR

In the result, the appeals of the assessees are allowed

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

seizure operation conducted at the premises of Rock Land Group of Cases and the documents related to the assessee found during the course of search were made available to the Assessing Officer of the present assessee. We thus respectfully following the decision of Co-ordinate Bench of the ITAT in the case of ACIT vs. Arun Kapur

KANHAIYALAL RAMESHWAR DAS,KOTA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, JAIPUR

search and seizure action u/s 132(1) of the Act was carried out on 5-02-\n2015 in the case of Bundi Silica Group, Kota to which the assessee\nbelongs. It is noted that the AO issued a notice u/s 153 of the Act to the\nassessee on 13-05-2015. In response to the notice, the assessee filed

KANHAIYALAL RAMESHWAR DAS,KOTA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, JAIPUR

search and seizure action u/s 132(1) of the Act was carried out on 5-02-\n2015 in the case of Bundi Silica Group, Kota to which the assessee\nbelongs. It is noted that the AO issued a notice u/s 153 of the Act to the\nassessee on 13-05-2015. In response to the notice, the assessee filed

DCIT, CC-2, JAIPUR vs. SHRI VIMAL CHAND SURANA(HUF), JAIPUR

In the result, the appeal of the revenue stands dismissed

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

seizure operation conducted at the premises of Rock Land Group of Cases and the documents related to the assessee found during the course of search were made available to the Assessing Officer of the present assessee. We thus respectfully following the decision of Co-ordinate Bench of the ITAT in the case of ACIT vs. Arun Kapur

DCIT, CC-3, JAIPUR vs. M/S BHIVARAM PANNALAL KUMAWAT, JAIPUR

Appeal are disposed off and all the appeals of the

Bench: Us By The Department. The Facts As Well As Issues, Are More Or Less Involving The Disallowance Of Labour Expenses & Therefore, These Twelve Appeals Were Head

seizure action to indicate any undisclosed income on account of on money payment by the assessee for purchase of land, subsequent recording of statement of sellers by ACB after a gap of around two years from the date of search and consequential inquiry conducted by the AO during the assessment proceedings u/s 153A r.w.s. 35 M/s. Bhivaram PannalalKumawat vs ACIT

M/S BHIVARAM PANNALAL KUMAWAT,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR

Appeal are disposed off and all the appeals of the

Bench: Us By The Department. The Facts As Well As Issues, Are More Or Less Involving The Disallowance Of Labour Expenses & Therefore, These Twelve Appeals Were Head

seizure action to indicate any undisclosed income on account of on money payment by the assessee for purchase of land, subsequent recording of statement of sellers by ACB after a gap of around two years from the date of search and consequential inquiry conducted by the AO during the assessment proceedings u/s 153A r.w.s. 35 M/s. Bhivaram PannalalKumawat vs ACIT

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

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

seizure action on the appellant. Since the\n\n20\nITA No. 301 and others /JP/2025 & CO No. 2 and others-JP-2025\nDCIT vs. Vaibhav Banka and others\nadditions do not survive on technical ground, the other grounds of appeal on the\nmerits of such addition are rendered only academic and do not warrant detailed\nadjudication. In view of this

MANGI LAL KANDOI ,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE – 2, JAIPUR, JAIPUR

In the result, appeal of the assessee is partly allowed

search. The learned CIT(A) has also mentioned on page 13 of the appellate order that the surrender of income was not voluntary and the income was offered by affidavit agreed to consider in the hands of the assessee. The Learned CIT(A) further relied upon certain case laws. In this regard our submission is that – (i) The paper

RAJESH KUMAR POONIA,JHUNJHUNU vs. ASSISTANT COMMISSIONER OF INCOME TAX, JHUNJHUNU

In the result, both the appeals of the assessee are allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

depreciation and deduction u/s 80 C. The Books of accounts found on the fateful day of survey were in the form of the ledgers and cash books and true income could not assessed through such records then and there. So, he retracted the statements in around 60 days of the survey operations. Rajesh Kumar Poonia vs. ACIT The Apex Court

RAJESH KUMAR POONIA,JHUNJHUNU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- JHUNJHUNU, JHUNJHUNU, JHUNJHUNU

In the result, both the appeals of the assessee are allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

depreciation and deduction u/s 80 C. The Books of accounts found on the fateful day of survey were in the form of the ledgers and cash books and true income could not assessed through such records then and there. So, he retracted the statements in around 60 days of the survey operations. Rajesh Kumar Poonia vs. ACIT The Apex Court

M/S WHOLESALE CLOTH MERCHANT,KOTA vs. PR. COMMISSIONER OF INCOME TAX (CENTRAL), RAJASTHAN, JAIPUR

In the result, appeal of the assessee is allowed

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 688/Jp/2019 Assessment Year: ………………………… M/S Wholesale Cloth Merchant Cuke Pr.C.I.T. (Central), Vs. Association, Jaipur (Rajasthan) New Cloth Market, Kota. Pan No.: Aaatw 0127 C Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri Siddarth Ranka & Shri Shravan Kr. Gupta (Advs) Jktlo Dh Vksj Ls@ Revenue By : Shri Ambrish Bedi (Cit-Dr) Lquokbz Dh Rkjh[K@ Date Of Hearing : 14/10/2020 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 06/01/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. The Present Appeal Has Been Filed By The Assessee Against The Order Of The Ld. Pr.Cit(Central), Rajasthan, Jaipur Dated 22/03/2019 Passed U/S 12Aa(3) & 12Aa(4) Of The Income Tax Act, 1961 (In Short, The Act). Following Grounds Have Been Taken By The Assessee: “1. That In The Facts & In The Circumstances Of The Case & In Law, The Ld Pr. Cit(Central), Rajasthan, Jaipur Has Grossly Erred In Cancelling The Registration Of The Assessee Appellant Trust Under Section 12A Of The Act By Invoking Section 12Aa(4) Of The Act W.E.F. 01/04/2013. 2. The Appellant Craves Leave To Add, Alter, Modify Or Amend Any Ground On Or Before The Date Of Hearing.”

Seizure action nor any notice u/s 153A or 153C of the Act or assessment u/s 153A or 153C of the Act in the case of assessee were initiated and there was only a survey u/s 133A of the Act in the case of assessee. The assessment has been completed u/s 148/143(3) of the act vide order dated