ACIT, JAIPUR vs. UDAI BUILDHOME PVT LTD, JAIPUR

In the result, all the appeals of the revenue are dismissed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकर अपील सं. / ITA Nos.1399, 1400, 1401 & 1486/JP/2024 निर्धारण वर्ष / Assessment Years : 2014-15, 2015-16, 2017-18 & 2018-19 Asstt. Commissioner of Income बनाम M/s Udai Buildhome Pvt. Tax, Vs. Ltd. 302, Golden Sunrise Central Circle-02, Jaipur Apartment, Lajpat Marg, C- Scheme, Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AABCU 5068 J अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee

153C of the Act dated 08- 08-2019 was issued and served upon the Assessee, requiring them to file a true and correct return of income as prescribed under Rule 12 of the Income Tax Rules, 1962 within 15 days of the service of the said notice. 5.1 In response to the said notice(s), a return declaring a loss

SH. KAPIL TANEJA,JAIPUR vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, JAIPUR

In the result, the appeal of the assessee is allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

153C r.w.s. 153A and the provisions of section 147/148 of the Act are not applicable in such cases. No contrary decision has been brought to our notice. Accordingly, we hold that initiation of proceedings u/s 147/148 by the AO to reassess the income is illegal being without jurisdiction and consequently the reassessment order passed u/s 147 r.w.s

DCIT, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. KAMLAPRABHA L/H OF LATE SHRI GOPAL LAL JI GOSWAMI, KOTA

In the result, the appeal of the revenue is dismissed and the Cross objection of the assessee is disposed off in terms of the observation made herein above

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

section 153C thereafter is also barred by limitation and thus, being a nullity, deserves to be quashed. 2. The Id. CITA erred in not deciding that the impugned assessment order passed us 144 r.w.s. 153C of the Act dated 30.03.2023 for A.Y. 2014 15 is barred by limitation us 153B r.w.s 153C of the Act. Considering that the date

ACIT, JAIPUR vs. M/S UDAI BUILDHOME PVT LTD., JAIPUR

In the result, all the appeals of the revenue are dismissed

153C of the Act dated 08-\n08-2019 was issued and served upon the Assessee, requiring them to file a\ntrue and correct return of income as prescribed under Rule 12 of the\nIncome Tax Rules, 1962 within 15 days of the service of the said notice.\n5.1 In response to the said notice(s), a return declaring a loss

GEMCO INTERNATIONAL,JAIPUR vs. INCOME TAX OFFICER WARD 2(1), JAIPUR

In the result, the appeal filed by the assessee stands partly allowed with no order as to cost

Bench: SHRI SANDEEP GOSAIN (Judicial Member)

153C read with section 153A. 2. The Id. CIT (Appeals) erred in law and on facts in confirming the issuance of notice u/s 148 by the Id. AO which was issued on the basis of information received from a different AO and without independent verification of the information and independent application of mind over the information 2 GEMCO INTERNATIONAL

PRAMILA AGARWAL,JAIPUR vs. THE INCOME TAX OFFICER WARD-2(5), JAIPUR

In the result, the appeal of the assessee is allowed

153C\nr.w.s.153A and the provisions of section 147/148 of the Act are not applicable in\nsuch cases. No contrary decision has been brought to our notice. Accordingly, we\nhold that initiation of proceedings u/s 147/148 by the AO to reassess the income is\nillegal being without jurisdiction and consequently the reassessment order passed\nu/s 147 r.w.s.143(3) is also illegal

MACRO PROPRIETIES PRIVATE LIMITED,M 28 INCOME TAX COLONY TONK ROAD JAIPUR vs. DCIT CENTRAL CIRCLE 2, LIC BUILDING JAIPUR

In the result, the appeals of the assessee are allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;djvihy la-@ITA No.174 TO 177/JP/2023 fu/kZkj.ko"kZ@AssessmentYear : 2013-14 TO 2016-17 M/s. Macro Properties Pvt. Ltd.M-28, Income Tax Colony, Tonk Road Jaipur cuke Vs. The DCIT Central Circle-2 LIC Building, Jaipur LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAFCM 3633 D vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksjls@Assesseeby : Shri C.M. Agarwal, CA jktLo dh vksjls@Revenue by: Shri JameshKurian, CI

Section 153C of the Income Tax Act. 6. The Assessing Officer has not recorded satisfaction in respect of each of the assessment years before issuing notice u/s 153C of the Income Tax Act relating seized Books of accounts or documents to each assessment year separately. 7. The Assessing Officer has not recorded satisfaction about incriminating nature of the Books

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

153C of the Act. The action of\nthe Id. CIT(A) is illegal, unjustified arbitrary, and against the facts of the case and\ndeserves to be quashed.\n4\nITA Nos.709/JP/2025\nDCIT vs. Sapna Karnani\n5.\nSuccinctly, the fact as culled out from the records is that in this case,\noriginal return of income was e-filed

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

153C of the Act. The action of\nthe Id. CIT(A) is illegal, unjustified arbitrary, and against the facts of the case and\ndeserves to be quashed.\n4\nITA Nos.709/JP/2025\nDCIT vs. Sapna Karnani\n5.\nSuccinctly, the fact as culled out from the records is that in this case,\noriginal return of income was e-filed

RAM SHRAN KATTA, 257, KATTA STREET, JAIN MANDIR WALI GALI, DURGAPURA, JAIPUR,JAIPUR vs. ITO WARD-6(4), JAIPUR

In the result, the appeals of the assessee are allowed

section 153C of the Act is different from regular assessment\nor it is not substitute for regular assessment. Being so, the AO shall frame\nassessment on the basis of incriminating material found during the course of\nsearch action under sec. 153C of the Act. The Assessing Officer was not\njustified in making additions by way of disallowance

MACRO TOWNSHIP PVT LTD,288-289 MAHAVEER NAGAR DURGAPURA JAIPUR vs. DCIT CC -2 JAIPUR, LIC BUILDING JAIPUR

In the result, the appeals of the assessee are allowed

Bench: HON’BLE SHRI SANDEEP GOSAIN, JM & HON’BLE SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

Section 153C of the Income Tax Act. 6. The Assessing Officer has not recorded satisfaction in respect of each of the assessment years before issuing notice u/s 153C of the Income Tax Act relating seized Books of accounts or documents to each assessment year separately. M/s. Macro Township Pvt. Ltd., Jaipur. 7. The Assessing Officer has not recorded satisfaction about

MACRO TOWNSHIP PVT LTD,288-289 MAHAVEER NAGAR DURGAPURA JAIPUR vs. DCIT CC-2 JAIPUR, LIC BUILDING JAIPUR

In the result, the appeals of the assessee are allowed

Bench: HON’BLE SHRI SANDEEP GOSAIN, JM & HON’BLE SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

Section 153C of the Income Tax Act. 6. The Assessing Officer has not recorded satisfaction in respect of each of the assessment years before issuing notice u/s 153C of the Income Tax Act relating seized Books of accounts or documents to each assessment year separately. M/s. Macro Township Pvt. Ltd., Jaipur. 7. The Assessing Officer has not recorded satisfaction about

MACRO TOWNSHIP PVT LTD,288-289 MAHAVEER NAGAR DURGAPURA JAIPUR vs. DCIT CC -2 JAIPUR , LIC BUILDING JAIPUR

In the result, the appeals of the assessee are allowed

Bench: HON’BLE SHRI SANDEEP GOSAIN, JM & HON’BLE SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

Section 153C of the Income Tax Act. 6. The Assessing Officer has not recorded satisfaction in respect of each of the assessment years before issuing notice u/s 153C of the Income Tax Act relating seized Books of accounts or documents to each assessment year separately. M/s. Macro Township Pvt. Ltd., Jaipur. 7. The Assessing Officer has not recorded satisfaction about

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, INCOME TAX OFFICE vs. SUPREME POLYMERS PRIVATE LIMITED, JAIPUR

In the results the appeal of the

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं. / ITA No. 189/JP/2025 निर्धारण वर्ष / Assessment Year : 2015-16 DCIT, Central Circle-03, Jaipur बनाम Vs. Supreme Polymers Pvt. Ltd. 137-138, Industrial Area, Jhotwara, Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AACCS 5773 P अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by: Shri Gaurav Nahata, CA राजस्व की ओर से / Revenue by : Mrs. Anita Rinesh, JCIT, Sr. DR सुनवाई की ता

153C is to be resorted to." This ground of appeal of the appellant is allowed in the above terms. 29 DCIT vs. Supreme Polymers Pvt. Ltd. 5. The above finding of the ld. CIT(A) was not accepted by the revenue and thereby the revenue challenges that finding of the ld. CIT(A) before this tribunal on the grounds

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

153C of the Act. The action of\nthe Id. CIT(A) is illegal, unjustified arbitrary, and against the facts of the case and\ndeserves to be quashed.\n\n4\nITA Nos.709/JP/2025\nDCIT vs. Sapna Karnani\n5.\nSuccinctly, the fact as culled out from the records is that in this case,\noriginal return of income was e-filed

RAM SHARAN KATTA, 257, KATTA STREET, JAIN MANDIR WALI GALI, DURGAPURA, JAIPUR,JAIPUR vs. ITO WARD-6(4), JAIPUR, WARD-6(4), JAIPUR

In the result, the appeals of the assessee are allowed

section 153C of the Act is different from regular assessment\nor it is not substitute for regular assessment. Being so, the AO shall frame\nassessment on the basis of incriminating material found during the course of\nsearch action under sec. 153C of the Act. The Assessing Officer was not\njustified in making additions by way of disallowance

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)

disallowance and deleting the said addition of Rs.63,95,407. 4. In the facts and circumstances of the case and in law the ld. CIT(A) has erred in confirming the action of Id. AO of making addition of Rs. 4,24,14,300 u/s 69. The action of the ld. CIT (A) is illegal, unjustified and arbitrary and against

PRADEEP KUMAR DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE 2, JAIPUR

In the result the appeal of the assessee is allowed and that\nrevenue stands dismissed

153C the assessment deserves to\nbe quashed.\n3. That in the facts and circumstance of the case and in law the learned\nCIT(A) has erred in not deleting the addition made by the learned AO in\nviolation of principles of natural justice.\n4. That in the facts and circumstances of the case and in law the learned\nCIT