URMILA RAJENDRA MUNDRA,AJMER vs. INCOME TAX OFFICER, WARD-2(2), AJMER, AJMER

In the result grounds raised by the assessee is allowed

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

section 270A” the fact of AO cannot be considered for “MISREPORTING” and thus the AO was suppose to grant immunity u/sec. 270AA and this order of AO is requested to be quashed. The assessee has applied for immunity u/sec. 270AA by filing form 68 (Rule 129) which also has been denied by AO since considered such disallowances as “MISREPORTING” enclosed

GUNMALA JAIN,AJMER vs. INCOME TAX OFFICER, WD-2(2), AJMER, AJMER

Appeal of the assessee is dismissed

Bench: SMT. ANNAPURNA GUPTA, AM आयकर अपील सं. / ITA No.1262/JPR/2025 निर्धारणवर्ष / AssessmentYears :2019-20 Gunmala Jain, बनाम 28 Abhi Lash Nikunj, Kalyan Vs. Income Tax Officer, Ward-2(2) Colony, Ajmer Road Kekri, Ajmer स्थायीलेखा सं. / जीआईआर सं./ PAN/GIR No.: ABRPJ 4764E Ajmer अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से/Assesseeby :Sh. Sunil Porwal, CA (Thr.V.C.) राजस्व की ओर से / Revenue by : Sh. Gautam Singh Choudhary (Addl. CIT) सुनवाई की तारीख / Date of Hearing : 18/1

disallowance; (d) the amount of under-reported income represented by any addition made in conformity with the arm's length price determined by the Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, ALWAR, ALWAR vs. MAN MOHAN KRISHNA, ALWAR

18. As a result, this appeal deserves to be dismissed

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

270A of the Act came to be passed on 29.01.2022 subsequent to the assessment order of even date, relating to the same assessment year 2019-20, whereby the Assessing Officer had disallowed expenditure expenses and also disallowed a sum of Rs. 64,47,267/- due to non deduction of TDS, and also while applying provisions of Section

PRIME ROSE CITY SCHOOL SAMITI,JAIPUR vs. ITO WD 1(1), JAIPUR

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

section 10(23C)(iiiad), whereas the two provisions are independent and mutually exclusive. 6. Under the facts and circumstances of the case and in law the learned CIT(A) erred in ignoring the assessee's submission that similar institutions facing the same issue were granted relief in appeal, and that the principle of parity should be applied. 7. Under

SUNIL CHABLANI,AJMER, RAJASTHAN vs. CIRCLE (INTL TAX), JAIPUR, JAIPUR, RAJASTHAN

disallowed due to\nreason that assessee has failed to submit any documentary evidence in support\nof his claim. Therefore, the whole consideration of Rs. 69,90,000/- is considered\nas Long Term Capital Gain in the hands of the assessee. Penalty proceedings\nu/s 270A of the Act is initiated on this issue for underreporting of income.\nFurther, the assessee

SHRI SHYAM CONSTRUCTION COMPANY,JAIPUR vs. ITO WD 1(1), JAIPUR, JAIPUR

The appeal of the assessee is dismissed

Bench: SMT. ANNAPURNA GUPTA (Accountant Member)

10. At this juncture the attention of the learned counsel for the assessee was drawn to the provision of Section 270A of the Act and it was pointed out that as per the provision of Section 270A(2)(a) of the Act the addition made to the income of the assessee qualified as ‘underreporting of income’. The provisions of Section

SHRI SHYAM CONSTRUCTION COMPANY,JAIPUR vs. ITO WD 1(1), JAIPUR, JAIPUR

The appeal of the assessee is dismissed

Bench: SMT. ANNAPURNA GUPTA (Accountant Member)

10. At this juncture the attention of the learned counsel for the assessee was drawn to the provision of Section 270A of the Act and it was pointed out that as per the provision of Section 270A(2)(a) of the Act the addition made to the income of the assessee qualified as ‘underreporting of income’. The provisions of Section

GOVINDAM BRJ INFRA PROJECTS PRIVATE LIMITED,JAIPUR vs. ACIT/DCIT CIR-6,JPR, JAIPUR

The appeals of the assessee are allowed

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

10% of labour expenses i.e. Rs. 9,71,272/- without pointing out specific defects or conducting proper verification. The disallowance is arbitrary and not based on any material evidence establishing that the expenses were not genuine or inflated. 2. On the facts and in the circumstances of the case and in law, the learned AO and CIT (A) have erred

SAKET AGARWAL,JAIPUR vs. INCOME TAX OFFICER WARD 1(3) JAIPUR, JAIPUR

10 (Delhi - Trib.)\nheld that "Section 6 of the Income-tax Act, 1961, read with\nArticle 17 of OECD Model Tax Convention Residential\nstatus (Artistes and sportsmen) - Assessment year 2009-10\nWhether going abroad for purpose of employment also\nmeans going abroad to take up employment or any\nallocation which takes in self employment like business or\nprofession Held

J.S.FOURWHEEL MOTORS (P) LTD ,ALWAR vs. ACIT. CIRCLE 1 ALWAR, ALWAR

In the result, the appeals of the assessee are allowed for statistical purposes

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

disallowance so made is just on presumption, assumption and surmises of the ld. Assessing Officer and the Commissioner of Income-Tax (Appeals), has erred in not giving any finding thereon and also erred in not disposing off the this ground on merit. 10. Section 156 Creation of Demand That the ld. Assessing Officer has erred in law as well

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

270A of the Act for under reported income are being initiated\r\nseparately. Copy enclosed (PB19-23).\r\nIn response thereto the assessee has filed the reply on 20.02.2024(PB24-32)\r\nwith the legal position and case laws, also reproduced at page 14-19 of the\r\nassessment order. However the Id. AO did not feel satisfy with

GOVINDAM BRJ INFRA PROJECTS PRIVATE LIMITED,JAIPUR vs. ACIT/DCIT CIR-6,JPR, JAIPUR

The appeals of the assessee are allowed

section 250 of the I.T. Act, 1961, for the assessment years 2017-18 and 18-\n19.\n2.\nThe assessee has raised the following grounds of appeal :-\nITA No. 1114/JPR/2025 AY 2017-18 :\n\"1. On the facts and in the circumstances of the case and in law, the learned AO and\nCIT (A) erred in making ad-hoc disallowance

SINCERE ARCHITECTS ENGINEERS PVT. LTD.,JAIPUR vs. ACIT, CIRLCE-7, JAIPUR

In the result the appeal no

270A of the\nAct can be levied or not. As the issue touches upon the levy of penalty u/s.\n270A of the Act it would be appropriate to deal with the provision of section\n270A of the Act which reads as under ;\n[Penalty for under-reporting and misreporting of income.\n15270A. (1) The Assessing Officer or 16 [the Joint

SINCERE ARCHITECTS ENGINEERS PVT. LTD.,JAIPUR vs. ACIT, CIRCLE-7, JAIPUR

In the result the appeal no

270A of the\nAct can be levied or not. As the issue touches upon the levy of penalty u/s.\n270A of the Act it would be appropriate to deal with the provision of section\n270A of the Act which reads as under ;\n[Penalty for under-reporting and misreporting of income.\n15270A. (1) The Assessing Officer or 16 [the Joint

PRADEEP SHARMA,JAIPUR vs. INCOME TAX OFFICER, JAIPUR

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

10% as made by Id.AO out of\nfollowing expenses:\nParticulars\nAmount\nMobile expenses\n78,918\nTelephone expenses\n63,108\n3\nITA No. 1522/JP/2024\nPradeep Sharma vs. ITO\nBusiness promotion\n79,666\nConveyance\n5,52,561\nMisc and general exp.\n1,11,075\nTravelling expenses\n91,457\nVehicle maintenance exp\n3,32,268\nTotal\n13,09,053\nAppellant prays that disallowance

NARAIN LAL AGRAWAL,JAIPUR vs. DCIT CIRCLE 1 JAIPUR, JAIPUR

In the result the appeal of the assessee is allowed

270A. Therefore the ground\nraised is dismissed.\nGround No. 3: The appellant craves the right to add, delete or amend any of the\ngrounds of appeal either before or at the time of hearing of appeal.\nThis is a general ground raised that does not require adjudication.\n6.\nIn the result, the appeal of the appellant is treated as dismissed

ACIT, CC-4, JAIPUR vs. SMT. SUNITA AGARWAL, JAIPUR

In the result appeals of the revenue are dismissed

270A and 271AAB as explained above while considering as to what material would constitute incriminating for the purposes of assessment of total income under section153A /C. 2.4 The provisions of section 153A/153C are not the normal assessment provisions like 143(3); rather they are curative provisions to plug the mischief of evasion of taxable income based on evidences found

ACIT, CC-4, JAIPUR vs. SHRI MUKUT BEHARI AGARWAL, JAIPUR

In the result appeals of the revenue are dismissed

270A and 271AAB as explained above while considering as to what material would constitute incriminating for the purposes of assessment of total income under section153A /C. 2.4 The provisions of section 153A/153C are not the normal assessment provisions like 143(3); rather they are curative provisions to plug the mischief of evasion of taxable income based on evidences found