RAMESH CHAND BANSAL,BEAWAR vs. DCIT, AJMER

In the result, the appeals of the assessee are allowed

4 of the assessee goes to the root of the legality of levy of penalty, therefore, we are deciding the same first. While pleading on behalf of the assessee, the ld AR has submitted written submissions wherein he has made the pleadings, which are reproduced as under: ‘’In all the above years, the facts and the controversy is identical therefore

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

132(4) of theIncome-tax Act, 1961) without there being any judicially acceptable evidence ofthe statement not being made voluntarily. Further, retraction after elapse oftime is an indication of the retraction being an afterthought. 5 (a) On the facts and in the circumstances of the case and in law the Ld. CIT(A) is not justified in applying GP rate

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

132(4) of theIncome-tax Act, 1961) without there being any judicially acceptable evidence ofthe statement not being made voluntarily. Further, retraction after elapse oftime is an indication of the retraction being an afterthought. 5 (a) On the facts and in the circumstances of the case and in law the Ld. CIT(A) is not justified in applying GP rate

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. NISHA JAIN, KOTA

In the result, the appeal of the Revenue is dismissed with no orders as to cost

Bench: SHRI SANDEEP GOSAIN (Judicial Member), DR MITHA LAL MEENA (Accountant Member)

132(4) and that recorded under Section 133A(3)(iii) of the Act. 41. This distinction was noticed by this Court in Dhingra Metal Works (supra). The Court there referred to the decision of the Kerala High Court in Paul Mathews & Sons v. CIT [2003] 263 ITR 101/129 Taxman 416 and of the Madras High Court in S. Khader Khan

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

132, the said proceeding shall abate. If such proceedings are already concluded by the AO by initiation of proceedings under s. 153A, the legal effect is the assessment gets reopened. The block assessment roped in only the undisclosed income and the regular assessment proceedings were preserved, resulting in multiple assessments. Under s. 153A, however, the AO has been given

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

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

132, the said proceeding shall abate. If such proceedings are already concluded by the AO by initiation of proceedings under s. 153A, the legal effect is the assessment gets reopened. The block assessment roped in only the undisclosed income and the regular assessment proceedings were preserved, resulting in multiple assessments. Under s. 153A, however, the AO has been given

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

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

132, the said proceeding shall abate. If such proceedings are already concluded by the AO by initiation of proceedings under s. 153A, the legal effect is the assessment gets reopened. The block assessment roped in only the undisclosed income and the regular assessment proceedings were preserved, resulting in multiple assessments. Under s. 153A, however, the AO has been given

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं. / ITA Nos.931 to 936/JP/2024 निर्धारण वर्ष / Assessment Years : 2012-13 & 2014-15 to 2018-19 Dheeraj Singh Sisodiya 005, (Nayagaun) Ram Ganmandi, Kota बनाम DCIT, Vill. Beedmandi Vs. Central Circle, Kota स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: APAPS 6392 E अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by : Sh. P. C. Parwal, CA राजस्व की ओर से / Revenue by : Mrs. Alka Gautam,

132, the said proceeding shall abate. If such proceedings are already concluded by the AO by initiation of proceedings under s. 153A, the legal effect is the assessment gets reopened. The block assessment roped in only the undisclosed income and the regular assessment proceedings were preserved, resulting in multiple assessments. Under s. 153A, however, the AO has been given

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

132, the said proceeding shall abate. If such proceedings are already concluded by the AO by initiation of proceedings under s. 153A, the legal effect is the assessment gets reopened. The block assessment roped in only the undisclosed income and the regular assessment proceedings were preserved, resulting in multiple assessments. Under s. 153A, however, the AO has been given

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं. / ITA Nos.931 to 936/JP/2024 निर्धारण वर्ष / Assessment Years : 2012-13 & 2014-15 to 2018-19 Dheeraj Singh Sisodiya 005, (Nayagaun) Ram Ganmandi, Kota बनाम DCIT, Vill. Beedmandi Vs. Central Circle, Kota स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: APAPS 6392 E अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by : Sh. P. C. Parwal, CA राजस्व की ओर से / Revenue by : Mrs. Alka Gautam,

132, the said proceeding shall abate. If such proceedings are already concluded by the AO by initiation of proceedings under s. 153A, the legal effect is the assessment gets reopened. The block assessment roped in only the undisclosed income and the regular assessment proceedings were preserved, resulting in multiple assessments. Under s. 153A, however, the AO has been given

ACIT, CENTRAL CIRCLE-3, JAIPUR vs. LAXMI NARAIN AGARWAL, JAIPUR

In the result, for the assessment years 2009-10 and 2010-11

132(4) and not under Section 133A. It was a statement by the Assessee himself. In response to question no. 7 whether all the purchases made by the family firms, were entered in the regular books of account, the answer was: "We and our family firms namely M/s. Assam Supari Traders and M/s. Balaji Perfumes generally try to record

LAXMI NARAIN AGARWAL,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR

In the result, for the assessment years 2009-10 and 2010-11

132(4) and not under Section 133A. It was a statement by the Assessee himself. In response to question no. 7 whether all the purchases made by the family firms, were entered in the regular books of account, the answer was: "We and our family firms namely M/s. Assam Supari Traders and M/s. Balaji Perfumes generally try to record

LAXMI NARAIN AGARWAL,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR

In the result, for the assessment years 2009-10 and 2010-11

132(4) and not under Section 133A. It was a statement by the Assessee himself. In response to question no. 7 whether all the purchases made by the family firms, were entered in the regular books of account, the answer was: "We and our family firms namely M/s. Assam Supari Traders and M/s. Balaji Perfumes generally try to record

LAXMI NARAIN AGARWAL,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR

In the result, for the assessment years 2009-10 and 2010-11

132(4) and not under Section 133A. It was a statement by the Assessee himself. In response to question no. 7 whether all the purchases made by the family firms, were entered in the regular books of account, the answer was: "We and our family firms namely M/s. Assam Supari Traders and M/s. Balaji Perfumes generally try to record

ACIT, CENTRAL CIRCLE-3, JAIPUR vs. LAXMI NARAIN AGARWAL, JAIPUR

In the result, for the assessment years 2009-10 and 2010-11

132(4) and not under Section 133A. It was a statement by the Assessee himself. In response to question no. 7 whether all the purchases made by the family firms, were entered in the regular books of account, the answer was: "We and our family firms namely M/s. Assam Supari Traders and M/s. Balaji Perfumes generally try to record

LAXMI NARAIN AGARWAL,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR

In the result, for the assessment years 2009-10 and 2010-11

132(4) and not under Section 133A. It was a statement by the Assessee himself. In response to question no. 7 whether all the purchases made by the family firms, were entered in the regular books of account, the answer was: "We and our family firms namely M/s. Assam Supari Traders and M/s. Balaji Perfumes generally try to record

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

4) of the\n1922 Act, analogous to Section 250/254 of the 1961 Act) do not confer on the\nappellate authority a power to make any direction on matters not arising in the\nappeal, especially as the Act provides separate mechanisms (like Section 34 of\n1922 Act, now Section 147) to deal with escaped income. Accordingly, the Apex\nCourt held that

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

Section 148 and the\nimpugned orders are quashed. However, the respondents shall be at liberty to\nproceed against the petitioners in accordance with law.”\nIn view of the above finding, the observation of Ld.CIT(A), that proceedings are to\nbe initiated u/s 153C is misconceived and under incorrect assumption of finding\nof Hon'ble Court.\n2.18 Covered issue: The issue