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

disallowable the bench\nnoted as on 31.03.2019 Rs.1,72,47,207/- was outstanding and the\nassessee paid Rs.1,30,43,654/- on 30.10.2019 the same is allowable as\nper provision of section

M/S. CHAMBAL FERTILIZERS AND CHEMICALS LIMITED,KOTA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA

In the result, appeal of the revenue is dismissed

section 145(3). 28.7. Assessee has also provided details of 2 comparable companies where their profit had also shown a reduction in AY 2012-13. CRISIL data also revealed that the entire industry was suffering. Assessee's entries in the books are based on invoice. Agents and dealers billed same rate to assessee. Further, the downward fall in gross profit

CHAMBAL FERTILISERS AND CHEMICALS LIMITED,KOTA vs. DCIT, KOTA

In the result, appeal of the revenue is dismissed

section 145(3). 28.7. Assessee has also provided details of 2 comparable companies where their profit had also shown a reduction in AY 2012-13. CRISIL data also revealed that the entire industry was suffering. Assessee's entries in the books are based on invoice. Agents and dealers billed same rate to assessee. Further, the downward fall in gross profit

CHAMBAL FERTILISERS AND CHEMICALS LIMITED,KOTA vs. ACIT, KOTA

In the result, appeal of the revenue is dismissed

section 145(3). 28.7. Assessee has also provided details of 2 comparable companies where their profit had also shown a reduction in AY 2012-13. CRISIL data also revealed that the entire industry was suffering. Assessee's entries in the books are based on invoice. Agents and dealers billed same rate to assessee. Further, the downward fall in gross profit

LALIT KUMAR ARORA,JAIPUR vs. ACIT, CR-2, , JAIPUR

In the result, the appeal of the assessees is allowed

Bench: Furnishing The Return Of Income Under Section 139(1) Of The Act. When The Matter Was Taken To The Ld. Cit(A) The Said Disallowance Was Sustained.

section 2 applies. These amendments will take effect from 1st April, 2021 and will accordingly apply to the assessment year 2021-22 and subsequent assessment years.” 15. The present appeal is filed by the assessee against disallowance of Rs. 56,207

RAJASTHAN EX-SERVICEMEN CORPORATION LIMITED,JAIPUR vs. ASSISTANT DIRECTOR INCOME TAX, CPC,, JAIPUR

In the result, the appeal of the assessee is allowed

section 139(1) of the IT Act. It was submitted that the said fact is not 4 Rajasthan Ex-Servicemen Corpn. Ltd., Jaipur. under dispute and where such contribution has been deposited before the due date of filing of the return of income, no disallowance U/s 36(1)(va) of the Act can be made and in support thereof

CLASSIC AIRCON,JAIPUR vs. DCIT CPC / ITO, WD-5(2), JAIPUR

In the result, the appeal of the assessee is allowed

Bench: Hearing Of This Appeal.

section 139(1) of the IT Act. It was submitted that the said fact is not under dispute and where such contribution has been deposited before the due date of filing of the return of income, no disallowance U/s 36(1)(va) of the Act can be made and in support thereof, the ld. A/R submitted that recently the Coordinate

PINK CITY JEWEL HOUSE PRIVATE LIMITED ,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), JAIPUR

section 80IA(10)\nand passed the assessment order dated 28.03.2013 [PB 48-49] without\nmaking any additions and accepted the returned Income of the assessee and\nby allowing the claim of deduction u/s 10AA of the assessee company.\n1.10. That thereafter scrutiny assessment orders u/s. 143(3) of the Act for\n assessment year 2011-2012 was passed

M/S. RATAN CONDUCTORS,JAIPUR vs. ACIT, CIRCLE-4, JAIPUR

In the result, this appeal of the assessee is allowed for statistical purposes only

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 1259/Jp/2019 Assessment Year: 2012-13 M/S Ratan Conductors, Cuke A.C.I.T., Vs. H-377(B), Road No. 17, Vki Area, Circle-4, Jaipur. Jaipur. Pan No.: Aabfr 8166 P Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri Ashok Kr. Gupta (Adv) Jktlo Dh Vksj Ls@ Revenue By : Smt. Monisha Choudhary (Jcit) Lquokbz Dh Rkjh[K@ Date Of Hearing : 05/08/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 02/09/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. The Present Appeal Has Been Filed By The Assessee Against The Order Of The Ld. Cit(A)-2, Jaipur Dated 21/08/2019 For The A.Y. 2012-13 Wherein Following Grounds Have Been Taken By The Assessee: “1. Disallowance Of Interest Of Rs. 17,73,769/- On Account Of Non Tds:- That On The Facts & In The Circumstances Of The Case Ld. Cit(A) Has Grossly Erred In Law & Facts In Confirming Disallowance Of Interest Of Rs.17,73,769/- Paid To M/S Barelays Investment & Loan (India) Ltd. (Rs. 298826/-) & M/S Future Capital (Rs. 1474943/-) On Account Of Non Deduction Of Tds Thereon By Invoking Provisions Of Section 40(A)(Ia) Of The It Act 1961. (A) The Assessee Firm Paid, Interest Of Rs. 2,98,826/- To Nbfc. M/S Barelays Investment & Loan (India) Ltd. & Rs.14,74,943/- To M/S Future Capital Another Nbfc. The Assessee Firm Raised Loan

section 40 (a) (ia) of the Act, the disallowance shall be restricted to 30% of the amount of expenditure claimed." The Finance Minister while introducing the amendment in Para 207

SHRI SATISH CHANDRA KATTA,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR

section 40(a)(ia) made by Finance Act, 2014 w.e.f. 01.04.2015\nprovides that 30% of any sum payable to a resident shall be disallowed if tax is not\ndeducted at source under Ch. XVIIB as against 100% made prior to this amendment.\n3.4\nThe purpose of this amendment was explained in the memorandum as under:-\n“the disallowance of whole

ASHOK SHARMA,KOTA vs. DY. COMMISSIONER OF INCOME TAX CIRCLE-2 - KOTA, KOTA

disallowance was already made in the original opinion of the\nld. AO, amounting to Rs.8,000.\nIt may, thus, please be appreciated your honour(s) that earlier an opinion of 1%\ndisallowance was made, while under proceedings u/s 147/148 the opinion has changed.\n1.2) Opinion while issuing Notice for rectification of mistake apparent on record u/s 154\ndated 21/11/2017

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, JAIPUR vs. NARESH KUMAR GUPTA, SRIGANGANAGAR

In the results the appeal of the revenue stands dismissed and the

Bench: Him The Order Passed Under Section 143(3) Of The Income Tax Act, [ For Short “Act” ] By The Acit, Circle, Sri Ganganagar [

disallowed in view of the provisions of section 36(1) (iii) of the Act as also in view of the judgments of Hon'ble Superme Court in the case of S.A. Builders and that of Hon'ble Punjab & Haryana High Court of in the case of Abhisekh Industries. 6. Feeling dissatisfied the finding so recorded in the assessment order

CASTAMET WORKS PRIVATE LIMITED,KHARWA vs. PRINCIPLE COMMISSIONER OF INCOME TAX, UDAIPUR

207 (Andhra Pradesh and Telangana) 42. Furthermore, the second limb to invoke Section 263 of the Act is that the order passed by the Assessing Officer should be "prejudicial to the interests of the revenue". Therefore, the said limb ought to be understood so as to understand what can be classified as 'prejudicial to the interests of revenue

ASSISSTANT COMMISSIONER OF INCOME TAX, AJMER vs. SHREE CEMENT LTD, BEAWAR

section 80IA(8) of the Act.\n30.10. Considering that TPO has disputed the Grid rate not to be\nthe market value in terms of provisions of Section 80A(6) of the\nAct, we would like to state here that that unlike Section 80IA(8),\nthe word \"OR\" is missing in provisions of Section 80A(6) of the\nAct

DURGA PRASAD SHARMA,JAIPUR vs. I.T.O. WARD 1(1), JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

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

disallowed under section 69C despite banking transactions. The appellant also relied on certain decisions including CIT v. Sunrise ToolingSystems (2014) 361 ITR 206 (Del) and Pr. CIT v. Shapoorji Pallonji & Co. Ltd. (2020) 423 ITR 220 (Bom), which are distinguishable on facts. Those cases involved parties where the suppliers were traceable, transactions were verified, and books were not rejected

SH. KRISHNA KUMAR PODDAR,JAIPUR vs. ACIT, CIRCLE-2, JAIPUR, JAIPUR

In the result, appeal of the assessee is allowed

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

section 142(1) of the I.T. Act, 1961 along with questionnaire was issued on 19.09.2019 asking the assessee to furnish certain information / details. In response thereof, the assessee filed requisite details/information through e-file portal. During the course of assessment proceedings the AO noticed that in the year under consideration the assessee has shown payment of interest

SIYARAM EXPORTS INDIA PVT. LTD.,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR

section 40(a)(ia) made by Finance Act, 2014 w.e.f. 01.04.2015\nprovides that 30% of any sum payable to a resident shall be disallowed if tax is not\ndeducted at source under Ch. XVIIB as against 100% made prior to this amendment.\n\n3.4\nThe purpose of this amendment was explained in the memorandum as under:-\n\n“the disallowance

RAMDULARI BANSAL WELFARE SOCIETY,JAIPUR vs. CIT(E), JAIPUR, JAIPUR

In the result, appeal of the assessee society is dismissed

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

207 (Kerala) and also the decision of coordinate bench in the case of Eternal Foundation in ITA No. 1504 & 1505/ JP/ 2018. Ultimately, the application of the assessee in Form No. 10AB is rejected and consequential rejection is there of application filed in Form No. 10AC also. 4. The assessee society being aggrieved with this order