AJOY SHARMA,JAIPUR vs. DCIT CENTRAL CIRCLE-1, JAIPUR, JAIPUR

133(6) which was\neven prior to the serving of the notice u/s 148, resultantly it could not be a case of\nprior detection nor could be a case of intended wrong claim with a view to\nsuppress the income or to evade taxes.\n7.3. It must be appreciated that there has been no such allegations in the entire\nperiod

AJOY SHARMA ,JAIPUR vs. DCIT CENTRAL CIRCLE-1, JAIPUR, JAIPUR

133(6) which was\neven prior to the serving of the notice u/s 148, resultantly it could not be a case of\nprior detection nor could be a case of intended wrong claim with a view to\nsuppress the income or to evade taxes.\n7.3. It must be appreciated that there has been no such allegations in the entire\nperiod

AJOY SHARMA ,JAIPUR vs. DCIT CENTRAL CIRCLE-1, JAIPUR, JAIPUR

133(6) which was\neven prior to the serving of the notice u/s 148, resultantly it could not be a case of\nprior detection nor could be a case of intended wrong claim with a view to\nsuppress the income or to evade taxes.\n7.3. It must be appreciated that there has been no such allegations in the entire\nperiod

AJOY SHARMA ,JAIPUR vs. DCIT CENTRAL CIRCLE-1, JAIPUR, JAIPUR

133(6) which was\neven prior to the serving of the notice u/s 148, resultantly it could not be a case of\nprior detection nor could be a case of intended wrong claim with a view to\nsuppress the income or to evade taxes.\n7.3. It must be appreciated that there has been no such allegations in the entire\nperiod

AJOY SHARMA ,JAIPUR vs. DCIT CENTRAL CIRCLE-1, JAIPUR, JAIPUR

133(6) which was\neven prior to the serving of the notice u/s 148, resultantly it could not be a case of\nprior detection nor could be a case of intended wrong claim with a view to\nsuppress the income or to evade taxes.\n7.3. It must be appreciated that there has been no such allegations in the entire\nperiod

INCOME TAX OFFICER, JAIPUR vs. KEDIA BUILDERS AND COLONIZERS PRIVATE LIMITED, JAIPUR

In the result, all appeals of the revenue are stands dismissed

133(6) Issued\n32-33\n11\n09.09.2019\n142(1) To Assessee\n34-36\n12.\n13.09.2019\nITR filed assessee requested for reason\nreliance placed on GKN\n37-39\n13\n23.09.2019\n143(2) issued\n40\n14\n26.09.2019\nReasons were provided to\nassessee electronically\n41\nVide ITBA/AST/F/17/2019-\n20/1018317741(1) (First Page\nOnly)\n16.\n06.11.2019\n131 Director Harshratna\n42\n17\n06.11.2019\n131 Director Darshan

INCOME TAX OFFICER, JAIPUR vs. KEDIA BUILDERS AND COLONIZERS PRIVATE LIMITED, JAIPUR

In the result, all appeals of the revenue are stands dismissed

133(6) Issued\n142(1) To Assessee\nITR filed assessee requested for reason\nreliance placed on GKN\n143(2) issued\nReasons were provided to\nassessee electronically\n131 Director Harshratna\n131 Director Darshan\nEnclave\n131 Director Shareen Hire\nPurchase\nAssessee filed part reply\nAssessee filed objection

INCOME TAX OFFICER, JAIPUR vs. KEDIA BUILDERS AND COLONIZERS PRIVATE LIMITED, JAIPUR

133(6) Issued\n32-33\n11\n09.09.2019\n142(1) To Assessee\n34-36\n12.\n13.09.2019\nITR filed assessee requested for reason\nreliance placed on GKN\n37-39\n13\n23.09.2019\n143(2) issued\n40\n14\n26.09.2019\nReasons were provided to\nassessee electronically\n41\nVide ITBA/AST/F/17/2019-\n20/1018317741(1) (First\nPage Only)\n16.\n06.11.2019\n131 Director Harshratna\n42\n17\n06.11.2019\n131 Director Darshan

INCOME TAX OFFICER , SIKAR vs. BHASKAR CHAUHAN, JAIPUR

In the result the appeal of the revenue in ITA no

Bench: Him.

reassess total income for entire six years block assessment period even in case of completed/unabated assessment. In respect of completed assessments/unabated assessments no addition can be made by Assessing Officer in absence of any incriminating material found during course of search under section 132 or requisition under section 132A. Completed/unabated assessments can be reopened by Assessing Officer in exercise

LATE SHRI JITENDRA NAGAR THROUGH HIS L/R SMT. DEEPIKA NAGAR,BARAN vs. INCOME TAX OFFICER WARD BARAN, BARAN

In the result, appeal of the assessee is allowed

Bench: The Date Of Hearing.”

133(6) was called for from the bank. On perusal of the bank account statements, it was found that the assessee deposited cash of Rs. 16,90,000/- in his bank account on 24.11.2015 relevant to A.Y. 2016-17. Therefore, the AO had reason to believe that income amounting to Rs. 16,90,000/- escaped assessment in the hands

BHASKAR CHOUHAN,JAIPUR vs. INCOME TAX OFFICER, SIKAR

section 147/148 of the Act are not applicable in\nsuch cases. No contrary decision has been brought to our notice.\nAccordingly, we hold that initiation of proceedings u/s 147/148 by A.O.\nto reassess the income is illegal being without jurisdiction and\nconsequently the reassessment order passed u/ s 147 r.w.s.143(3) is\nalso illegal and void above said initio

VINITA BAJORIA,JAIPUR vs. INCOME-TAX OFFICER, JAIPUR

In the result, the appeal of the assessee is allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकर अपील सं./ITA No. 370/JP/2025 निर्धारण वर्ष / Assessment Year : 2016-17 Vinita Bajoria 1, Ganesh Colony Moti Doongri Road, Jaipur बनाम Income Tax Officer, Ward 5(2), Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AEBPB4873M अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by: Sh. Manoj Choudhary, CA राजस्व की ओर से / Revenue by : Sh. Gorav Avasthi, JCIT सुनवाई की तारीख / Date of Hear

section 147, and • The reassessment order passed u/s 147 r.w.s. 144 be kindly held to be without jurisdiction, bad in law and liable to be quashed. 6. To support the contention so raised in the written submission reliance was placed on the following evidence / records / decisions: S. No. Particulars Page Nos. 1. Synopsis of the Case

SHRI MADHO LAL SAINI,JAIPUR vs. ITO, WARD-2(3), JAIPUR

In the result, the appeals of the assessees are allowed

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

Reassessment pursuant to material found in search can be done through recourse to section 153C only and not by invoking the provisions of section 147/148. 1.12. The provisions of section 153C are over-riding in nature and contain non obstante clause for sections 139,147,148,149,151 and 153. 1.13. Section 147 and 153C are not interchangeable

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)

133(6) of the Act to M/s Sidhi Vinayak Metal & Salt Company Pvt. Ltd. received no response, and there is no evidence of that company filing its income tax return for the relevant assessment year. These facts severely impair the credibility of the transactions. The Assessing Officer has correctly invoked the provisions of section 69C of the Act. Section

SAVITA GUPTA,KOTA vs. ITO, DELHI

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

133(6) of the Act was issued which was duly complied by the appellant. 3. The appellant had purchased a residential plot bearing No. E-13, Landmark City, Kota, from Bhatia Colonisers for a total consideration of Rs. 16,20,000/-, as duly recorded in the books of the seller. 4. However, the assessment was subsequently reopened

APOORVA SHARMA,JAIPUR vs. ITO, WARD-6(4), JAIPUR

reassessment action has been taken on the factually incorrect assumption of fact because instead of commission receipts of Rs.21,60,840/- (as alleged in reasons recorded), the actual receipts of appellant are Rs.14,28,318/- only (as evident from copy of bank statements submitted by assesse and obtained by AO u/s 133(6) of the act). Therefore, the meaning

RMS KARAMCHARI BACHAT AND SAKH SAHAKARI SAMITI LIMITED JAIPUR,JAIPUR vs. ITO WARD-1(2), JAIPUR, JAIPUR

In the result, the appeals of the assessee are allowed

133(6) proceedings for A.Y. 2014-15 and the subsequent issuance of the\nnew PAN, the AO proceeded to issue notice under section 148 on 27.03.2021\nusing the old and incorrect PAN :AADCR1819C. In this regard, the ld. AR placed\nreliance on the following judgments :-\nCIT vs. Lovely Exports Pvt. Ltd. (2008) 216 CTR (SC) 195:\nwherein

RMS KARAMCHARI BACHAT AND SAKH SAHAKARI SAMITI LIMITED JAIPUR,JAIPUR vs. ITO WARD-1(2), JAIPUR, JAIPUR

In the result, the appeals of the assessee are allowed

133(6) proceedings for A.Y. 2014-15 and the subsequent issuance of the\nnew PAN, the AO proceeded to issue notice under section 148 on 27.03.2021\nusing the old and incorrect PAN :AADCR1819C. In this regard, the ld. AR placed\nreliance on the following judgments :-\nCIT vs. Lovely Exports Pvt. Ltd. (2008) 216 CTR (SC) 195:\nwherein