SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

139(5) and since the assessments under section 153A are in relation to undisclosed income, it is precisely for this reason that new claim of deduction or allowance cannot be made in the completed assessments The assessment or reassessment

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

139(5) and since the assessments under section 153A are in relation to undisclosed income, it is precisely for this reason that new claim of deduction or allowance cannot be made in the completed assessments The assessment or reassessment

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं. / ITA Nos.931 to 936/JP/2024 निर्धारण वर्ष / Assessment Years : 2012-13 & 2014-15 to 2018-19 Dheeraj Singh Sisodiya 005, (Nayagaun) Ram Ganmandi, Kota बनाम DCIT, Vill. Beedmandi Vs. Central Circle, Kota स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: APAPS 6392 E अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by : Sh. P. C. Parwal, CA राजस्व की ओर से / Revenue by : Mrs. Alka Gautam,

139(5) and since the assessments under section 153A are in relation to undisclosed income, it is precisely for this reason that new claim of deduction or allowance cannot be made in the completed assessments The assessment or reassessment

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

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

139(5) and since the assessments under section 153A are in relation to undisclosed income, it is precisely for this reason that new claim of deduction or allowance cannot be made in the completed assessments The assessment or reassessment

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं. / ITA Nos.931 to 936/JP/2024 निर्धारण वर्ष / Assessment Years : 2012-13 & 2014-15 to 2018-19 Dheeraj Singh Sisodiya 005, (Nayagaun) Ram Ganmandi, Kota बनाम DCIT, Vill. Beedmandi Vs. Central Circle, Kota स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: APAPS 6392 E अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by : Sh. P. C. Parwal, CA राजस्व की ओर से / Revenue by : Mrs. Alka Gautam,

139(5) and since the assessments under section 153A are in relation to undisclosed income, it is precisely for this reason that new claim of deduction or allowance cannot be made in the completed assessments The assessment or reassessment

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

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

139(5) and since the assessments under section 153A are in relation to undisclosed income, it is precisely for this reason that new claim of deduction or allowance cannot be made in the completed assessments The assessment or reassessment

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

5), the claim\r\nfor only such in a return 139(4), 142(1) date contemplated deduction under section\r\n80P could be made by an assessee in a return filed within the time prescribed for\r\nfliling such returns under any of the above provisions. The amendment to section\r\n80AC with effect from 1-4-2018, however, mandated

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

In the result the appeal no

139 or that of the time\nallowed in notice issued as per provision of section 148 of the Act and\ntherefore, it is clear case of misreporting of income.\n15. We have heard the rival contentions and perused the material placed\non record. The bench noted that the in this appeal the assessee\nchallenges the levy of penalty u/s.270A

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

In the result the appeal no

139 or that of the time\nallowed in notice issued as per provision of section 148 of the Act and\ntherefore, it is clear case of misreporting of income.\n15. We have heard the rival contentions and perused the material placed\non record. The bench noted that the in this appeal the assessee\nchallenges the levy of penalty u/s.270A

BHASKAR CHOUHAN,JAIPUR vs. INCOME TAX OFFICER, SIKAR

5\n6\nITA Nos.533 & 868/JPR/2024\nBhaskar Chouhan, Sikar\n3.3 Based on the information in possession of the Id. AO he\nnoted that the assessee maintained bank account with AXIS BANK\nhaving No.916020049304891 in the name of Murlidhar Impex\nduring the year under consideration. On perusal of the ITR filed, it\nis noticed that the Bank account is not disclosed

INCOME TAX OFFICER , SIKAR vs. BHASKAR CHAUHAN, JAIPUR

In the result the appeal of the revenue in ITA no

Bench: Him.

139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,- (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, A person other

DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR vs. SMT. SHEENA MATHUR, JAIPUR

In the result, revenue’s ground of appeal is dismissed

reassessment has to be made in the manner provided in section 153A. Section 153A provides that the AO shall issue the notice requiring to furnish return of income within a period as specified in the notice. The assessee was under the obligation to file the return of income in respect of each assessment year falling within six assessment years

DCIT, JAIPUR vs. VIMAL CHAND SURANA HUF, JAIPUR

In the result, the appeal of the revenue stands dismissed

139, 147, 148, 149, 151 and 153. It is submitted that Section 147 and 153C are not interchangeable but are mutually exclusive sections. It is not the choice of the revenue to invoke either of the two sections at its whims. The scope of the two sections have been legislated differently with a definite purpose. Reliance is placed

RAKESH KUMAR JAIN,JAIPUR vs. DCIT,CIRCLE-2, JAIPUR, JAIPUR

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

Bench: Or At The Time Of Hearing Of The Appeal & / Or Modify Any Of The Above Grounds.

reassessment cannot be declared as invalid in the penalty proceedings.” 8. We are not required to consider the other contingencies for examination of legality and validity of the penalty under Section 271(1)(c) of the Act, but clauses (p), (q) & (r) of the above referred observations are required to be considered. 9. As per the above referred decision

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)

139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, 81belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, AJMER vs. M/S SHRI RAJLAXMI DENIM, BHILWARA

In the result, appeal of the revenue is allowed

139; (b) assess or reassess the total income of six assessment years immediately preceding the assessment year relevant to the previous year in which such search is conducted or requisition is made 23[and for the relevant assessment year or years] : Provided that the Assessing Officer shall assess or reassess the total income in respect of each assessment year falling

SMT. REEMA HARISH BHATIA,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX. CENTRAL CIRCLE, KOTA

Sections 139 (return of income), 139(5) (revised return of income), 147 (income escaping assessment) and 263 (revision of orders) of the Act. 29 ITA Nos. 1284(4)/JP/2018 Smt. Reema Harish Bhatia, Kota. 26. The plea raised on behalf of the assessee that as the first proviso provides for assessment or reassessment

DEPUTY COMMISSIONER OF INCOME TAX. CENTRAL CIRCLE, KOTA vs. SMT. REEMA HARISH BHATIA, KOTA

Sections 139 (return of income), 139(5) (revised return of income), 147 (income escaping assessment) and 263 (revision of orders) of the Act. 29 ITA Nos. 1284(4)/JP/2018 Smt. Reema Harish Bhatia, Kota. 26. The plea raised on behalf of the assessee that as the first proviso provides for assessment or reassessment

SMT. REEMA HARISH BHATIA,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

Sections 139 (return of income), 139(5) (revised return of income), 147 (income escaping assessment) and 263 (revision of orders) of the Act. 29 ITA Nos. 1284(4)/JP/2018 Smt. Reema Harish Bhatia, Kota. 26. The plea raised on behalf of the assessee that as the first proviso provides for assessment or reassessment