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

reassessment proceedings initiated under Section 148 be upheld as valid\nand in accordance with the law.\n2. The addition of ₹44,62,938/- under Section 2(22)(e) be upheld, as the\nAppellant has failed to disprove the findings of the AO.\n3.\nThe appeal of the Appellant be dismissed, and the order of the Ld. CIT(A)\nbe upheld

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SNEHLATA AGARWAL, SIKAR

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

reassessment could not be issued against a person\ndeemed to be an agent of a non-resident under section 43, after the expiry of one\nyear from the end of the assessment year. The section was amended by section\n18 of the Finance Act, 1956, extending this period of limitation to two years from\nthe end of the assessment year

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SNEHLATA AGARWAL, SIKAR

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

2) of section 150 as it stands, in our view, a fair and just\ninterpretation would be that the authority under the Act has been empowered only\nto reopen assessments, which have not already been closed and attained finality\ndue to the operation of the bar of limitation under section 149.\n19. This Court took similar view in the case

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SARITA DEWAN, SIKAR

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

2) of section 150 as it stands, in our view, a fair and just\ninterpretation would be that the authority under the Act has been empowered only\nto reopen assessments, which have not already been closed and attained finality\ndue to the operation of the bar of limitation under section 149.\n19. This Court took similar view in the case

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. VIPUL BANKA, SIKAR

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

2) of section 150 as it stands, in our view, a fair and just\ninterpretation would be that the authority under the Act has been empowered only\nto reopen assessments, which have not already been closed and attained finality\ndue to the operation of the bar of limitation under section 149.\n19. This Court took similar view in the case

DCIT, CENTRAL CIRCLE-1, JAIPUR , JAIPUR vs. USHA BANKA, SIKAR

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

2) of section 150 as it stands, in our view, a fair and just\ninterpretation would be that the authority under the Act has been empowered only\nto reopen assessments, which have not already been closed and attained finality\ndue to the operation of the bar of limitation under section 149.\n19. This Court took similar view in the case

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. PRIYA DEWAN, SIKAR

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

2) of section 150 as it stands, in our view, a fair and just\ninterpretation would be that the authority under the Act has been empowered only\nto reopen assessments, which have not already been closed and attained finality\ndue to the operation of the bar of limitation under section 149.\n19. This Court took similar view in the case

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. PRIYA DEWAN, SIKAR

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

2) of section 150 as it stands, in our view, a fair and just\ninterpretation would be that the authority under the Act has been empowered only\nto reopen assessments, which have not already been closed and attained finality\ndue to the operation of the bar of limitation under section 149.\n19. This Court took similar view in the case

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. TRILOK DEWAN, SIKAR

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

2) of section 150 as it stands, in our view, a fair and just\ninterpretation would be that the authority under the Act has been empowered only\nto reopen assessments, which have not already been closed and attained finality\ndue to the operation of the bar of limitation under section 149.\n19. This Court took similar view in the case

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SUBHASH CHANDRA BANKA, SIKAR

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

2) of section 150 as it stands, in our view, a fair and just\ninterpretation would be that the authority under the Act has been empowered only\nto reopen assessments, which have not already been closed and attained finality\ndue to the operation of the bar of limitation under section 149.\n19. This Court took similar view in the case

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. USHA BANKA, SIKAR

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

2) of section 150 as it stands, in our view, a fair and just\ninterpretation would be that the authority under the Act has been empowered only\nto reopen assessments, which have not already been closed and attained finality\ndue to the operation of the bar of limitation under section 149.\n19. This Court took similar view in the case

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SARITA DEWAN, SIKAR

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

2) of section 150 as it stands, in our view, a fair and just\ninterpretation would be that the authority under the Act has been empowered only\nto reopen assessments, which have not already been closed and attained finality\ndue to the operation of the bar of limitation under section 149.\n19. This Court took similar view in the case

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. ANIMESH AGARWAL, SIKAR

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

2) of section 150 as it stands, in our view, a fair and just\ninterpretation would be that the authority under the Act has been empowered only\nto reopen assessments, which have not already been closed and attained finality\ndue to the operation of the bar of limitation under section 149.\n19. This Court took similar view in the case

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

In the result, the appeal of the assessee is allowed

2, the order of reassessment passed by the\nTribunal is declared null and void. The questions are answered in favour of assessee and\nagainst the Department."\n\n30\nITA No. 654/JPR/2023\nMahendra Sharma vs. ITO .\n\nThus on the above legal position of law the notice under section 148 or\nproceedings under section 147/148 and consequent assessment order liable

DESH RAJ JAKHAR,GORDHANPURA vs. INCOME TAX OFFICER, WARD NEEM KA THANA

In the result, the appeal filed by the assessee is allowed for statistical purposes

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

Section 143(2) which is applicable for the assessment under consideration is being reproduced hereunder :- "Provided that no notice under clause (ii) shall be served on the assessee after the expiry of six months from the end of the financial year in which the return is furnished." Hence the 1.d. Assessing officer is having the time to initiate

ANSHU SAHAI (HUF), JAIPUR,JAIPUR vs. ACIT, CENTRAL CIRCLE 2, JAIPUR, JAIPUR

reassessment, if any, for such assessment year has been\nmade.\nThese amendments have been brought into effect retrospectively from 1st June,\n2003.\"\n(emphasis supplied)\nAs per the CBDT Gircular also, in case of section 163C of the Act, assessments\nof the preceding six years as pending on the date on which books of account or\ndocuments or assets seized

DCIT, CC-2, JAIPUR vs. SHRI VIMAL CHAND SURANA(HUF), JAIPUR

In the result, the appeal of the revenue stands dismissed

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

2) of section 143 has expired, or (c) assessment or reassessment, if any, has been made, before the date of receiving the books of account or documents or assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person, such Assessing Officer shall issue the notice and assess or reassess total income of such other person

LATE SH. BIRDI CHAND THROUGH LEGAL HEIR MUKESH SHARMA ,JAIPUR vs. ITO, WARD-7(2), JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

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

2-8-2018 to the Income Tax Officer objecting to the notices issued under section 148 as well as under section 142(1) of the Act and drew his attention to the earlier letter dated 27-4-2018 informing him about the death of his father and requesting him to drop the proceedings. The attention of the Income Tax Officer

INCOME TAX OFFICER, WARD-1(2), JAIPUR, JAIPUR vs. MUKESH KUMAR SONI, JAIPUR

In the result appeal of the revenue is dismissed and the cross

Bench: Moving Towards The Facts Of The Case We Would Like To Mention

reassessment proceedings even when intimation under section 143(1) had been issued........” Hence, the there was relevant and cogent material before the Ld. A.O before re- opening the assessement. The contention of the appellant in this regard is rejected. In view of the facts and the circumstances as narrated above No. 1,2,3,6 & 7 are hereby dismissed. Ground