DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

In the result the appeal of the revenue in ITA no

153D.\nIn the case of the assessee penalty order was passed on 28/08/2023 therefore,\nthe penalty order was passed without jurisdiction and time barred on 31-03-2023.\n5.2.7\nThus, the Ld. CIT (A) rightly deleted the penalty on the ground that the\nsame are beyond the limitation date. Therefore, on this aspect, we rely on the\nfinding

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

In the result the appeal of the revenue in ITA no

153D.\nIn the case of the assessee penalty order was passed on 28/08/2023 therefore,\nthe penalty order was passed without jurisdiction and time barred on 31-03-2023.\n5.2.7 Thus, the Ld. CIT (A) rightly deleted the penalty on the ground that the\nsame are beyond the limitation date. Therefore, on this aspect, we rely on the\nfinding

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

In the result the appeal of the revenue in ITA no

153D.\nIn the case of the assessee penalty order was passed on 28/08/2023 therefore,\nthe penalty order was passed without jurisdiction and time barred on 31-03-2023.\n5.2.7 Thus, the Ld. CIT (A) rightly deleted the penalty on the ground that the\nsame are beyond the limitation date. Therefore, on this aspect, we rely on the\nfinding

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

In the result the appeal of the revenue in ITA no

153D.\nIn the case of the assessee penalty order was passed on 28/08/2023 therefore,\nthe penalty order was passed without jurisdiction and time barred on 31-03-2023.\n5.2.7 Thus, the Ld. CIT (A) rightly deleted the penalty on the ground that the\nsame are beyond the limitation date. Therefore, on this aspect, we rely on the\nfinding

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

In the result the appeal of the revenue in ITA no

153D.\nIn the case of the assessee penalty order was passed on 28/08/2023 therefore,\nthe penalty order was passed without jurisdiction and time barred on 31-03-2023.\n5.2.7 Thus, the Ld. CIT (A) rightly deleted the penalty on the ground that the\nsame are beyond the limitation date. Therefore, on this aspect, we rely on the\nfinding

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

In the result the appeal of the revenue in ITA no

153D.\nIn the case of the assessee penalty order was passed on 28/08/2023 therefore,\nthe penalty order was passed without jurisdiction and time barred on 31-03-2023.\n5.2.7\nThus, the Ld. CIT (A) rightly deleted the penalty on the ground that the\nsame are beyond the limitation date. Therefore, on this aspect, we rely on the\nfinding

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

In the result the appeal of the revenue in ITA no

153D.\nIn the case of the assessee penalty order was passed on 28/08/2023 therefore,\nthe penalty order was passed without jurisdiction and time barred on 31-03-2023.\n5.2.7 Thus, the Ld. CIT (A) rightly deleted the penalty on the ground that the\nsame are beyond the limitation date. Therefore, on this aspect, we rely on the\nfinding

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

In the result the appeal of the revenue in ITA no

153D.\nIn the case of the assessee penalty order was passed on 28/08/2023 therefore,\nthe penalty order was passed without jurisdiction and time barred on 31-03-2023.\n5.2.7\nThus, the Ld. CIT (A) rightly deleted the penalty on the ground that the\nsame are beyond the limitation date. Therefore, on this aspect, we rely on the\nfinding

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

In the result the appeal of the revenue in ITA no

153D.\nIn the case of the assessee penalty order was passed on 28/08/2023 therefore,\nthe penalty order was passed without jurisdiction and time barred on 31-03-2023.\n5.2.7 Thus, the Ld. CIT (A) rightly deleted the penalty on the ground that the\nsame are beyond the limitation date. Therefore, on this aspect, we rely on the\nfinding

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

In the result the appeal of the revenue in ITA no

153D.\nIn the case of the assessee penalty order was passed on 28/08/2023 therefore,\nthe penalty order was passed without jurisdiction and time barred on 31-03-2023.\n5.2.7 Thus, the Ld. CIT (A) rightly deleted the penalty on the ground that the\nsame are beyond the limitation date. Therefore, on this aspect, we rely on the\nfinding

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)

271 and 273 were the two original penalty provisions, which require the penalty proceedings to be initiated during the course of relevant assessment proceedings or the other relevant proceedings, as the case may be. The penalty proceedings could also be initiated during the appellate proceedings arising out of the relevant assessment proceedings. It is only where the assessment proceedings

SHIVAM READYMIX PRIVATE LIMITED,NEEMUCH vs. THE PCIT(CENTRAL), JAIPUR

In the result, the appeal of the assessee is allowed

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

Penalty proceedings u/s 271(1)© of the Act is hereby initiated for concealed the particulars of income.” It is submitted that the ld.AO passed assessment order u/s 153A after obtaining prior approval u/s 153D of the Income Tax Act, 1961 of the Joint Commissioner of Income Tax, Central Range, Jaipur vide her office letter No. Jt. CIT/Central Range/JPR/2020-21/679 dated

SHRI AMBICA GARMENTS,JODHPUR vs. ACIT, CENTAL CIRCLE-3, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of\nthe above observations

U/s 271(1)(c), the penalty. The action is\nunjustified, illegal or excessive and deserves to be deleted in full.\n7.1 The ground is general in nature. The grounds are pre-mature as these are\nagainst mere initiation of penalty proceedings. Penalty proceedings are\nindependent proceedings and the appellant is required to make his submissions\nbefore the appropriate authority during

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, prosecution, rectification, approval etc. to the assessee or any other person, on or after the 01.10.2019 unless a computer generated DIN has been allotted and is duly quoted in the body of such communication. We note that para 3 of the said circular provides for certain exceptional circumstances when the communication is issued manually, in which case such manually

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, AJMER vs. M/S SHREE BHAGWATI MACHINE PVT. LTD., AJMER

In the results appeal of the revenue in ITA no

153D of the Act to the order passed u/s 153A is without application of mind, purely in a mechanical manner, without appreciating the facts and not following the provisions/mandate of the section, which makes the order passed u/s 153A nonest, void ab initio, bad in law, the same deserves to be quashed.. 5. That

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, AJMER vs. M/S SHREE BHAGWATI MACHINE PVT. LTD., AJMER

In the results appeal of the revenue in ITA no

153D of the Act to the order passed u/s 153A is without application of mind, purely in a mechanical manner, without appreciating the facts and not following the provisions/mandate of the section, which makes the order passed u/s 153A nonest, void ab initio, bad in law, the same deserves to be quashed.. 5. That

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, AJMER vs. M/S SHREE BHAGWATI MACHINE PVT. LTD., AJMER

In the results appeal of the revenue in ITA no

153D of the Act to the order passed u/s 153A is without application of mind, purely in a mechanical manner, without appreciating the facts and not following the provisions/mandate of the section, which makes the order passed u/s 153A nonest, void ab initio, bad in law, the same deserves to be quashed.. 5. That

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, AJMER vs. M/S SHREE BHAGWATI MACHINE PVT. LTD., AJMER

In the results appeal of the revenue in ITA no

153D of the Act to the order passed u/s 153A is without application of mind, purely in a mechanical manner, without appreciating the facts and not following the provisions/mandate of the section, which makes the order passed u/s 153A nonest, void ab initio, bad in law, the same deserves to be quashed.. 5. That