DCIT, JAIPUR vs. VIMAL CHAND SURANA HUF, JAIPUR

In the result, the appeal of the revenue stands dismissed

153A and the same was considered and accepted by the AO then the AO is not permitted to reopen the assessment to review its order as it would amount to change of opinion. The Hon’ble Madras High court in case of CIT vs. Remedies Ltd. (Supra) has held in paras 10 to 12 as under:- “10. We find from

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)

153A and the same was considered and accepted by the AO then the AO is not permitted to reopen the assessment to review its order as it would amount to change of opinion. The Hon’ble Madras High court in case of CIT vs. Remedies Ltd. (Supra) has held in paras 10 to 12 as under:- “10. We find from

RAMESH CHAND BANSAL,BEAWAR vs. DCIT, AJMER

In the result, the appeals of the assessee are allowed

153A. Hence, the pleading on the ground of equity also fails. 5.7 Thus though surrender was during the search in course of statements u/s 132(4), the disclosure u/s 132(4), by itself cannot redeem the appellant from deeming provisions of the explanation 5A to section 271(1)( c) of the Act. Factually speaking the statement

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

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

153A and 153C, in the absence of\nincriminating material found during the search, in respect of such income\nwhich was found to have escaped assessment other than through\nincriminating material, the assessing officers would be entitled to\nreassess such income in terms of Section 147/148 read with section 150.\n(iii) That the Assessing Officer, may if found necessary initiate

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

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

153A and 153C, in the absence of\nincriminating material found during the search, in respect of such income\nwhich was found to have escaped assessment other than through\nincriminating material, the assessing officers would be entitled to\nreassess such income in terms of Section 147/148 read with section 150.\n(iii) That the Assessing Officer, may if found necessary initiate

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

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

153A and 153C, in the absence of\nincriminating material found during the search, in respect of such income\nwhich was found to have escaped assessment other than through\nincriminating material, the assessing officers would be entitled to\nreassess such income in terms of Section 147/148 read with section 150.\n(iii) That the Assessing Officer, may if found necessary initiate

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

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

153A and 153C, in the absence of\nincriminating material found during the search, in respect of such income\nwhich was found to have escaped assessment other than through\nincriminating material, the assessing officers would be entitled to\nreassess such income in terms of Section 147/148 read with section 150.\n(iii) That the Assessing Officer, may if found necessary initiate

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

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

153A and 153C, in the absence of\nincriminating material found during the search, in respect of such income\nwhich was found to have escaped assessment other than through\nincriminating material, the assessing officers would be entitled to\nreassess such income in terms of Section 147/148 read with section 150.\n(iii) That the Assessing Officer, may if found necessary initiate

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

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

153A and 153C, in the absence of\nincriminating material found during the search, in respect of such income\nwhich was found to have escaped assessment other than through\nincriminating material, the assessing officers would be entitled to\nreassess such income in terms of Section 147/148 read with section 150.\n(iii) That the Assessing Officer, may if found necessary initiate

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

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

153A and 153C, in the absence of\nincriminating material found during the search, in respect of such income\nwhich was found to have escaped assessment other than through\nincriminating material, the assessing officers would be entitled to\nreassess such income in terms of Section 147/148 read with section 150.\n(iii) That the Assessing Officer, may if found necessary initiate

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

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

153A and 153C, in the absence of\nincriminating material found during the search, in respect of such income\nwhich was found to have escaped assessment other than through\nincriminating material, the assessing officers would be entitled to\nreassess such income in terms of Section 147/148 read with section 150.\n(iii) That the Assessing Officer, may if found necessary initiate

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

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

153A and 153C, in the absence of\nincriminating material found during the search, in respect of such income\nwhich was found to have escaped assessment other than through\nincriminating material, the assessing officers would be entitled to\nreassess such income in terms of Section 147/148 read with section 150.\n(iii) That the Assessing Officer, may if found necessary initiate

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

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

153A and 153C, in the absence of\nincriminating material found during the search, in respect of such income\nwhich was found to have escaped assessment other than through\nincriminating material, the assessing officers would be entitled to\nreassess such income in terms of Section 147/148 read with section 150.\n(iii) That the Assessing Officer, may if found necessary initiate

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

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

153A and 153C, in the absence of\nincriminating material found during the search, in respect of such income\nwhich was found to have escaped assessment other than through\nincriminating material, the assessing officers would be entitled to\nreassess such income in terms of Section 147/148 read with section 150.\n(iii) That the Assessing Officer, may if found necessary initiate

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

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

153A and 153C, in the absence of\nincriminating material found during the search, in respect of such income\nwhich was found to have escaped assessment other than through\nincriminating material, the assessing officers would be entitled to\nreassess such income in terms of Section 147/148 read with section 150.\n\n(iii) That the Assessing Officer, may if found necessary

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

1). A search u/s 132\nwas carried out at various business and residential premises of firm and its\npartners on 05-02-2015.\nAction of Ld. A.O.\nThe Ld. A.O. thereafter issued notice u/s 153A of I.T. Act, 1961 on 13-05-2015\nand in response thereto the assessee filed return of income on 08-06-2015\ndeclaring an income

KATRATHAL GRAM SEWA SAHKARI SAMITI LIMITED ,KATRATHAL vs. ITO WARD 1 SIKAR, SIKAR

153A. In the case of Lanjani Co-Operative Agri\r\nService Society Ltd. (CPC) v. DCIT [2023] 146 taxmann.com 468 (Chandigarh-\r\nTrib.), the ITAT held that the enabling provisions of sub- clause (v) of section\r\n143(1) providing for disallowance of deduction under section 80P due to late\r\nfiling of return having been introduced by Finance

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. KARNANI SOLVEX PRIVATE LIMITED, JAIPUR

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

1) of Sushil Securities P Ltd\nfor AY 2018-19 dated 11.04.2019\n322-\n334\n70. Copy of Director Report and Auditors report of\nAngita Plaza P Ltd along with Financial\nStatements\n335-\n346\n71. Copy of Director Report and Auditors report of\nVidya Laxmi Fabrics P Ltd along with Financial\nStatements\n347-\n358\n\n52\nITA Nos.480/JP/2025\nDCIT vs. Karnani

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 153A/153C\nwere struck down due to absence of incriminating material. This administrative\ninstructions are not binding on quasi-judicial authorities like the CIT(A). It is a\nsettled principle of law, as held by the Hon'ble Supreme Court in UCO Bank v.\nCIT [(1999) 237 ITR 889 (SC)] (CLC 41-49), that CBDT circulars or instructions\ncannot override