MANGI LAL KANDOI ,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE – 2, JAIPUR, JAIPUR

In the result, appeal of the assessee is partly allowed

127 of the Income-tax Act, 1961 by the CIT, Jaipur-ll, Jaipur issued vide order No: CIT-II/JPR/127/Kandoi Group/12-13/1992 dated 24.12.2012. 4. Accordingly, notice u/s 142(1) of the IT Act, 1961 was issued on 12.12.2013 for filing of return of income. In compliance to the notice u/s 142(1) of the IT Act, 1961, return of income

M/S WHOLESALE CLOTH MERCHANT,KOTA vs. PR. COMMISSIONER OF INCOME TAX (CENTRAL), RAJASTHAN, JAIPUR

In the result, appeal of the assessee is allowed

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 688/Jp/2019 Assessment Year: ………………………… M/S Wholesale Cloth Merchant Cuke Pr.C.I.T. (Central), Vs. Association, Jaipur (Rajasthan) New Cloth Market, Kota. Pan No.: Aaatw 0127 C Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri Siddarth Ranka & Shri Shravan Kr. Gupta (Advs) Jktlo Dh Vksj Ls@ Revenue By : Shri Ambrish Bedi (Cit-Dr) Lquokbz Dh Rkjh[K@ Date Of Hearing : 14/10/2020 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 06/01/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. The Present Appeal Has Been Filed By The Assessee Against The Order Of The Ld. Pr.Cit(Central), Rajasthan, Jaipur Dated 22/03/2019 Passed U/S 12Aa(3) & 12Aa(4) Of The Income Tax Act, 1961 (In Short, The Act). Following Grounds Have Been Taken By The Assessee: “1. That In The Facts & In The Circumstances Of The Case & In Law, The Ld Pr. Cit(Central), Rajasthan, Jaipur Has Grossly Erred In Cancelling The Registration Of The Assessee Appellant Trust Under Section 12A Of The Act By Invoking Section 12Aa(4) Of The Act W.E.F. 01/04/2013. 2. The Appellant Craves Leave To Add, Alter, Modify Or Amend Any Ground On Or Before The Date Of Hearing.”

penalty proceedings initiated u/s 271F, 271(1)(b), 271(1)(c) may kindly be deleted. 4. The petitioner craves the right to add, alter or in any way amend the grounds of appeal at or before the hearing.” The assessee has also raised additional grounds of appeal and the same is reproduced as under: “1. That the impugned order dated

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

Bench: This Tribunal Are As Under :

penalty u/s 271(1)(c) of the Act 13. The appellant craves leave to add, amend, alter, revise and modify any of the grounds of appeal on, before or in the course of hearing of the appeal. 4. Succinctly, the facts as culled out from the records are that a Search & Seizure action u/s 132 of the Income

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

Bench: This Tribunal Are As Under :

penalty u/s 271(1)(c) of the Act 13. The appellant craves leave to add, amend, alter, revise and modify any of the grounds of appeal on, before or in the course of hearing of the appeal. 4. Succinctly, the facts as culled out from the records are that a Search & Seizure action u/s 132 of the Income

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

Bench: This Tribunal Are As Under :

penalty u/s 271(1)(c) of the Act 13. The appellant craves leave to add, amend, alter, revise and modify any of the grounds of appeal on, before or in the course of hearing of the appeal. 4. Succinctly, the facts as culled out from the records are that a Search & Seizure action u/s 132 of the Income

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

Bench: This Tribunal Are As Under :

penalty u/s 271(1)(c) of the Act 13. The appellant craves leave to add, amend, alter, revise and modify any of the grounds of appeal on, before or in the course of hearing of the appeal. 4. Succinctly, the facts as culled out from the records are that a Search & Seizure action u/s 132 of the Income

SH. ASHOK KUMAR PORWAL,JHALAWAR vs. JCIT, RANGE-1, KOTA, KOTA

In the result, appeal of the assessee is partly allowed

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

127 (SC)/[2021] 283 Taxman 285 (SC) 8.0 In result, the appeal of the appellant is hereby dismissed.” 5. Feeling dissatisfied from the order of the ld. CIT(A) the assessee has preferred this appeal on the grounds as reiterated here in above. To support the various grounds so raised the ld. AR appearing on behalf of the assessee

MANGI LAL KANDOI ,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE – 2, JAIPUR, JAIPUR

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

2. In the facts and circumstances of the case the learned CIT(A) has erred in confirming the action of the learned AO in passing the order under section 271(1)(c) of the Income Tax Act, 1961 without striking off the irrelevant portion of the printed show cause notice dated 15.09.2017 viz., furnished inaccurate particulars of income or concealed

MANGI LAL KANDOI ,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE – 2, JAIPUR, JAIPUR

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

2. In the facts and circumstances of the case the learned CIT(A) has erred in confirming the action of the learned AO in passing the order under section 271(1)(c) of the Income Tax Act, 1961 without striking off the irrelevant portion of the printed show cause notice dated 15.09.2017 viz., furnished inaccurate particulars of income or concealed

MANGI LAL KANDOI ,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE – 2, JAIPUR, JAIPUR

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

2. In the facts and circumstances of the case the learned CIT(A) has erred in confirming the action of the learned AO in passing the order under section 271(1)(c) of the Income Tax Act, 1961 without striking off the irrelevant portion of the printed show cause notice dated 15.09.2017 viz., furnished inaccurate particulars of income or concealed

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

penalty u/s 271(1)(c) of the Act\n13. The appellant craves leave to add, amend, alter, revise and modify any of\nthe grounds of appeal on, before or in the course of hearing of the appeal.\n4. Succinctly, the facts as culled out from the records are that a Search\n& Seizure action u/s 132 of the Income

PARAS MAL JAIN,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JAIPUR

In the result, the appeal of the assessee is allowed

271(1)(c), the\ncontentions of voluntary surrender to buy peace and avoid litigation\netc. are liable to be rejected and in the context of section 271AAB\neven the question of considering such contentions does not arise.\nFrom the perusal of the statement of the assessee recorded in the\ncourse of search and seizure action it is seen that

LOVELY PROMOTERS PRIVATE LIMITED,KOLKATA vs. ACIT, CENTRAL CIRCLE, AJMER, AJMER

In the result, the appeal filed by the assessee is allowed

Bench: him regarding non mentioning of Document Identification Number (DIN) in the body of the order u/s. 127 of the Act dated 08-09-2021 and various other technical pleas raised in grounds of appeal regarding validity of notice u/s. 148 of the Act, thereby appellate order passed by the CIT(A) is non-speaking order and deserves to be quashed. 4. On the facts and in circumstances of the case and in law, the AO erred in issuing notice u/s. 148 of the Act as it was a search related case u/s. 132 r/w

penalty proceedings u/s. 271(1)(c) of the Act. 10. The appellant craves leave to add or to amend the foregoing ground of appeal, if it becomes necessary to do so in the interest of justice.” 3. The fact as culled out from the record is that in this case originally return of income was e-filed on 30.09.2013 declaring

AJAY BAKLIWAL,KOTA vs. ACIT, CENTRAL CIRCLE, KOTA, KOTA

In the result, the appeal of the assessee is allowed

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

127 (SC)/(2021) 283 Taxman 285 (SC)[14-09-2021] held that assessee failed to discharge its burden in proving that there was a reasonable cause in accepting deposits from staff members in violation of section 269SS, the SLP filed by the aseessee was dismissed. The head notes of the decision read as under- "Section 269SS, read with sections

DIESH KUMAR GOYAL,KOTA vs. ITO, WARD-1(1), KOTA, KOTA

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

2) of rule 127.\n1.3 In view of the above instructions of CBDT, the hearing notices were required to\nbe sent on (i) email address available in the income-tax return furnished by the\naddressee to which the communication relates ITR of AY 2010-11,\ni.e.carajendra@rediffmail.com, or (ii) the email address available in the last\nincome-tax return furnished

KOSHAL KISHOR SHARMA,JAIPUR vs. DCIT(INTL. TAX), JAIPUR, JAIPUR

In the result, appeals of the assessee are allowed

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

Penalty of Rs.18,55,307/- u/s 271(1)(c) FACTS: 1. The brieffacts of the case as stated by our client are that the applicant assessee is an NRI residing in Japan from last 25 years and having his own business at Japan and not filed his ROI for the A.Y. 2015-16 being no taxable income in India originally

KOSHAL KISHOR SHARMA,JAIPUR vs. DCIT(INTL. TAX.) JAIPUR, JAIPUR

In the result, appeals of the assessee are allowed

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

Penalty of Rs.18,55,307/- u/s 271(1)(c) FACTS: 1. The brieffacts of the case as stated by our client are that the applicant assessee is an NRI residing in Japan from last 25 years and having his own business at Japan and not filed his ROI for the A.Y. 2015-16 being no taxable income in India originally

RANJAN SHARMA,JAIPUR vs. ITO WARD 6(2), JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

2), Jaipur fixing the case for hearing on 12.10.2015. This notice was duly served upon the assessee through registered post. Thereafter vide order U/s 127 dated 10.06.2016, the Pr.CIT-2, Jaipur assigned this case to ACIT, Circle-4, Jaipur and in consequence to order U/s 127 the ACIT, Circle-6 transferred this case to ACIT, Circle 4, Jaipur. Notice U/s