DCIT, JAIPUR vs. RAJASTHAN FINANCIAL CORPORATION, JAIPUR

In the result, the appeal of the revenue is dismissed

Bench: The Hearing.”

47,61,511/- Aggrieved by this order, the appellant has preferred this appeal. The appellant has contended that the Hon'ble Rajasthan High Court has, in relation to an earlier AY, held that the MAT provisions would not be applicable in the case of the appellant. Thus, the appellant has contended that the action of the AO is contrary

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA, KOTA vs. CHAMBAL FERTILIZERS AND CHEMICALS LTD., KOTA

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

disallowance u/s 14A of the Act worked out to be Nil as the investment had its source in cash generated from business operation. o23 ITA No. 1090, 1097 TO 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota Nothing to the contrary has been argued before us on behalf of the department. Consequently, this ground raised by the department

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA, KOTA vs. CHAMBAL FERTILIZERS AND CHEMICALS LTD, KOTA

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

disallowance u/s 14A of the Act worked out to be Nil as the investment had its source in cash generated from business operation. o23 ITA No. 1090, 1097 TO 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota Nothing to the contrary has been argued before us on behalf of the department. Consequently, this ground raised by the department

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA, KOTA vs. CHAMBAL FERTILIZERS AND CHEMICALS LTD, KOTA

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

disallowance u/s 14A of the Act worked out to be Nil as the investment had its source in cash generated from business operation. o23 ITA No. 1090, 1097 TO 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota Nothing to the contrary has been argued before us on behalf of the department. Consequently, this ground raised by the department

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA, KOTA vs. CHAMBAL FERTILIZERS AND CHEMICALS LTD., KOTA

disallowance u/s 14A of the Act worked out\nto be Nil as the investment had its source in cash generated from business\noperation.\n023\nITA No. 1090, 1097 TO 1099 & 1091/JPR/2024\nChambal Fertilizers and Chemicals Ltd., Kota\nNothing to the contrary has been argued before us on behalf of the\ndepartment. Consequently, this ground raised by the department

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA, KOTA vs. CHAMBAL FERTILIZERS AND CHEMICALS LTD, KOTA

disallowance u/s 14A of the Act worked out\nto be Nil as the investment had its source in cash generated from business\noperation.\n023\nITA No. 1090, 1097 ΤΟ 1099 & 1091/JPR/2024\nChambal Fertilizers and Chemicals Ltd., Kota\nNothing to the contrary has been argued before us on behalf of the\ndepartment. Consequently, this ground raised by the department

ACIT, CIRCLE, BHARATPUR vs. M/S. JAGDAMBE STONE COMPANY, BHARATPUR

In the result, this appeal of the Revenue is dismissed

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am

47 (SC) 7. On the contrary, the ld AR of the assessee has reiterated the same arguments as were raised before the ld. CIT(A) and has further submitted that the AO has disallowed the Freight Expenses of Rs. 1,44,13,853/- [30% of 4,80,46,176/-] by wrongly invoking the Section

MAHENDRA SHARMA,JAIPUR vs. ITO, WARD-3(1), JAIPUR

In the result, the appeal of the assessee is allowed

47,600/-. The\nld. AO has issued the notice u/s 148 on 28.09.2016. In response thereto the assesssee\nhas filed the letter on 17.10.2016 at the Dak Counter of the AO, in response to the notice\nunder section 148 dt. 28.09.2016 and admittedly submitted that the return of income filed\nunder section 139 of the Act may be treated

CAREER POINT LIMITED,KOTA, RAJASTHAN vs. PRINCIPAL COMMISSIONER OF INCOME TAX, UDAIPUR, RAJASTHAN

In the result, the appeal of the assessee is allowed

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

2,53,26,820/- under section 14A of the IT Act read with Rule 8D of IT Rules, 1961. The assessee has explained source of investment by submitting that it has total investment in equities and mutual funds of Rs, 22384.52 lacs against which its share capital and reserves stands for Rs. 38508.89 lacs. As assessee had not used borrowed

OCEAN EXIM INDIA PRIVATE LTD,JAIPUR vs. ITO WARD 1(2), JAIPUR

In the result, the appeal of the assessee is dismissed

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

47. Likewise, this court underlined the rule, regarding interpretation of taxing statutes, in Commissioner of Income Tax-III v Calcutta Knitwears, Ludhiana. 18 Recently, in Union of India & Ors. vs. Exide Industries Limited & Ors, this court examined, and repelled a challenge to the constitutionality of Section 43B, especially the provision requiring actual payment, in respect of leave encashment benefit

SHRI KESHORAIPATAN SAHKARI SUGAR MILLS LIMITED,KOTA vs. PCIT, UDAIPUR

In the result, appeal of the assessee is allowed

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

disallowance of the assessee's claim for deduction under section 80P(2)(d) is vacated. Thus, this Ground of appeal is allowed in terms of the aforesaid observations. [Para 22] ii. Solitaire CHS Ltd. vs. Pr. CIT [IT Appeal No. 3155 (Mum.) of 2019, dated 29-11-2019]; (ITAT "G" Bench, Mumbai); iii. Kaliandas Udyog Bhavan Premises Co-Op. Society

GURUVENDRA SINGH ,KOTA vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1, KOTA, KOTA

In the result, appeal of the assessee is allowed

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

v) The date of purchase of the land pertaining is for A. Y. 2018-19. vi) Against the claim of the assessee that he earns income agricultural income on that ld. AO noted that it is immaterial for the purpose of section 54B that assessee earning income from the other lands or not. Based on the above observations

M/S. AJMER ZILA DUGDH UTPADAK SAHAKARI SANGH LTD.,AJMER vs. PR.CIT, AJMER

In the result, the appeal of the assessee is partly allowed

47,540.00 u/sec. 139 of Act. The assessment was completed u/sec. 143(3) of Act on 02.03.2015 on returned income. Later on, notice u/sec. 148 was issued & order u/sec. 143(3) / 147 was passed by A.O. on 07.12.2017 on returned income itself. Thereafter, a show-cause notice u/sec. 263 has been issued on 05.03.2020 considering the assessment orders erroneous & prejudicial

AHLUWALIA ERECTORS & FABRICATORS PRIVATE LIMITED, KOTA,KOTA vs. DCIT/ACIT CIR-2, KOTA, KOTA

In the result the appeal of\nthe assessee in ITA no 199/JP/2025 is allowed for statistical purposes

2 to 4 of appeal are allowed.”\n1.4.5 ACIT v. India Carbon Ltd. [1993] 200 ITR 759 (Gauhati) held that,\n"Section 43B declares that taxes and duties shall not be allowed as deduction from the\nincome unless they are actually paid. It removes the doubt as to the meaning of the word\n\"paid\" according to the method

AHLUWALIA ERECTORS & FABRICATORS PRIVATE LIMITED, KOTA,KOTA vs. DCIT/ACIT CIR-2, KOTA

In the result the appeal of\nthe assessee in ITA no 199/JP/2025 is allowed for statistical purposes

2 to 4 of appeal are allowed.”\n1.4.5 ACIT v. India Carbon Ltd. [1993] 200 ITR 759 (Gauhati) held that,\n\"Section 43B declares that taxes and duties shall not be allowed as deduction from the\nincome unless they are actually paid. It removes the doubt as to the meaning of the word\n\"paid\" according to the method

AHLUWALIA ERECTORS & FABRICATORS PRIVATE LIMITED,KOTA vs. DCIT/ACIT CIR-2, KOTA

In the result the appeal of\nthe assessee in ITA no 199/JP/2025 is allowed for statistical purposes

2 to 4 of appeal are allowed.”\n1.4.5 ACIT v. India Carbon Ltd. [1993] 200 ITR 759 (Gauhati) held that,\n\"Section 43B declares that taxes and duties shall not be allowed as deduction from the\nincome unless they are actually paid. It removes the doubt as to the meaning of the word\n\"paid\" according to the method

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

47,549/- under chapter VIA. A notice u/s 143(2) of the Act was issued\r\nto the assessee on 06.10.2023. Ld. AO in the assessment proceeding\r\nnoted that assessee claimed deduction u/s.80P(2)(a)(iv) and u/s 80P(2)(d)\r\nof the Act. The assessee's claim of deduction under chapter VIA was not\r\nallowable

HOLIDAY TRIANGLE TRAVEL PRIVATE LIMITED,GURGAON vs. INCOME TAX OFFICER, JAIPUR

In the result, appeal of the assessee is allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

disallowance vide his order dated 05.12.2023. 4. Aggrieved by the said order of the CIT(A), the assessee preferred appeal before us. At the time of hearing before us, the ld. A/R of the assessee has submitted his written submission as under :- “ The assessee, during the year had sold 1013 equity shares of the company, and had received share premium