LOVELY PROMOTERS PRIVATE LIMITED,KOLKATA vs. ACIT, CENTRAL CIRCLE, AJMER, AJMER

In the result, the appeal filed by the assessee is allowed

Bench: him regarding non mentioning of Document Identification Number (DIN) in the body of the order u/s. 127 of the Act dated 08-09-2021 and various other technical pleas raised in grounds of appeal regarding validity of notice u/s. 148 of the Act, thereby appellate order passed by the CIT(A) is non-speaking order and deserves to be quashed. 4. On the facts and in circumstances of the case and in law, the AO erred in issuing notice u/s. 148 of the Act as it was a search related case u/s. 132 r/w

149 or under the Finance Act, 2021 and in law and whatever rights were available to the Assessing Officer under the Finance Act, 2021 shall continue to be available; (v) This order shall substitute or modify judgments and orders passed by High Courts across the country quashing similar notices issued under the unamended section 148 of the Act irrespective

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

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

149 of the\nAct of 1961 as also the corresponding provisions of the Act of 1922 makes it plain\nthat two conditions have to be satisfied before the Income-tax Officer acquires\njurisdiction to issue notice under section 148 in respect of an assessment beyond\nthe period of four years but within a period of eight years from

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

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

149 of the\nAct of 1961 as also the corresponding provisions of the Act of 1922 makes it plain\nthat two conditions have to be satisfied before the Income-tax Officer acquires\njurisdiction to issue notice under section 148 in respect of an assessment beyond\nthe period of four years but within a period of eight years from

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

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

149 of the\nAct of 1961 as also the corresponding provisions of the Act of 1922 makes it plain\nthat two conditions have to be satisfied before the Income-tax Officer acquires\njurisdiction to issue notice under section 148 in respect of an assessment beyond\nthe period of four years but within a period of eight years from

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

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

149 of the\nAct of 1961 as also the corresponding provisions of the Act of 1922 makes it plain\nthat two conditions have to be satisfied before the Income-tax Officer acquires\njurisdiction to issue notice under section 148 in respect of an assessment beyond\nthe period of four years but within a period of eight years from

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

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

149 of the\nAct of 1961 as also the corresponding provisions of the Act of 1922 makes it plain\nthat two conditions have to be satisfied before the Income-tax Officer acquires\njurisdiction to issue notice under section 148 in respect of an assessment beyond\nthe period of four years but within a period of eight years from

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

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

149 of the\nAct of 1961 as also the corresponding provisions of the Act of 1922 makes it plain\nthat two conditions have to be satisfied before the Income-tax Officer acquires\njurisdiction to issue notice under section 148 in respect of an assessment beyond\nthe period of four years but within a period of eight years from

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

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

149 of the\nAct of 1961 as also the corresponding provisions of the Act of 1922 makes it plain\nthat two conditions have to be satisfied before the Income-tax Officer acquires\njurisdiction to issue notice under section 148 in respect of an assessment beyond\nthe period of four years but within a period of eight years from

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

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

149 of the\nAct of 1961 as also the corresponding provisions of the Act of 1922 makes it plain\nthat two conditions have to be satisfied before the Income-tax Officer acquires\njurisdiction to issue notice under section 148 in respect of an assessment beyond\nthe period of four years but within a period of eight years from

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

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

149 of the\nAct of 1961 as also the corresponding provisions of the Act of 1922 makes it plain\nthat two conditions have to be satisfied before the Income-tax Officer acquires\njurisdiction to issue notice under section 148 in respect of an assessment beyond\nthe period of four years but within a period of eight years from

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

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

149 of the\nAct of 1961 as also the corresponding provisions of the Act of 1922 makes it plain\nthat two conditions have to be satisfied before the Income-tax Officer acquires\njurisdiction to issue notice under section 148 in respect of an assessment beyond\nthe period of four years but within a period of eight years from

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

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

149 of the\nAct of 1961 as also the corresponding provisions of the Act of 1922 makes it plain\nthat two conditions have to be satisfied before the Income-tax Officer acquires\njurisdiction to issue notice under section 148 in respect of an assessment beyond\nthe period of four years but within a period of eight years from

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

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

149 of the\nAct of 1961 as also the corresponding provisions of the Act of 1922 makes it plain\nthat two conditions have to be satisfied before the Income-tax Officer acquires\njurisdiction to issue notice under section 148 in respect of an assessment beyond\nthe period of four years but within a period of eight years from

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)

149 has also been made inapplicable by the non obstante clause. Section 151 which requires sanction to be obtained by the Assessing Officer by issue of notice to reopen the assessment under Section 148 has also been excluded in a case covered by Section 153A. The time-limit prescribed for completion of an assessment or reassessment by Section

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)

149 has also been made inapplicable by the non obstante clause. Section 151 which requires sanction to be obtained by the Assessing Officer by issue of notice to reopen the assessment under Section 148 has also been excluded in a case covered by Section 153A. The time-limit prescribed for completion of an assessment or reassessment by Section

SYLVAN GREENS PRIVATE LIMITED,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 6, JAIPUR

In the result, the appeal of the assessee is allowed

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

149 is not mere signing of the notice under 17 ITA NO.414.JPR/2025 SYLVAN GREEN PRIVATE LTD VS DCIT,CIRCLE-6 , JAIPUR section 148, but is sent to the proper person within the end of the relevant assessment year. The assessee would also like to relied on the decision given by Hon,ble Madras High Court in Smt. Parveen Amin

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)

Section 147/148 of the Act, relying on the same judgment of Abhisar Buildwell (supra), CBDT Instruction No. 1/2023 (CLC 35-40), and the provisions of Section 150 of the Act. The assessee, while supporting the ultimate relief granted, is aggrieved by the directions given by the ld. CIT(A) in his order suggesting the AO initiate proceedings under Section 147/148

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)

Section 147/148 of the Act, relying on the same judgment of Abhisar Buildwell (supra), CBDT Instruction No. 1/2023 (CLC 35-40), and the provisions of Section 150 of the Act. The assessee, while supporting the ultimate relief granted, is aggrieved by the directions given by the ld. CIT(A) in his order suggesting the AO initiate proceedings under Section 147/148

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

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

Section 147/148 of the Act. The assessee\ntherefore before us by preferring the present Cross-Objection to challenge\nthe directions and to raise other legal and factual grounds in support of the\ndeletion of the addition. Record reveals that Id. CIT(A) vide page 36 while\ndealing with the appeal of the assessee has issued direction