DCIT, JAIPUR vs. GVK JAIPUR EXPRESSWAY PVT LTD, JAIPUR

In the result, the appeal of the revenue for the years [A

reassess under section 147 or pass an order\nenhancing the assessment or reducing a refund already made or\notherwise increasing the liability of the assessee under section 154, for\nany assessment year beginning on or before the 1st day of April, 2001.]\n\nThat the heading of section 14A, i.e. “Expenditure incurred in relation to\nincome not includible in total

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

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

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

section 147 of the I.T. Act, 1961.” 5.5. The appellant submitted that the AO has satisfied himself that appellant had taken accommodation entry in the shape of unsecured loans. The appellant submitted that it raised objections before AO against such reasons wherein it was categorically contended that appellant had not taken any unsecured loans from any of the party mentioned

POOJASHISH INFRASTRUCTURES PVT. LTD.,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, KOTA

In the result, appeal of the assessee is allowed

2. Briefly stated, the facts of the case are that the assessee filed its original return of income on 19.09.2010 declaring business loss of Rs 56,547. Thereafter, a search and seizure operations u/s 132 was carried out on 02.07.2015 at various premises of M/s Kota Dall Mill to which the assessee belongs. The notice u/s 153A was issued

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S BARAN ROLLER FLOUR MILLS PVT. LTD., KOTA

14A of the Act of Rs. 1250/- is unwarranted. Accordingly, the same is deleted and grounds No. 3 to 10 of appeals are allowed.” There is no dispute that the assessee’s own interest free fund was many times more than the investment made for both the assessment years to the tune of Rs. 15,00,000/- for assessment year

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S BARAN ROLLER FLOUR MILLS PVT. LTD., KOTA

14A of the Act of Rs. 1250/- is unwarranted. Accordingly, the same is deleted and grounds No. 3 to 10 of appeals are allowed.” There is no dispute that the assessee’s own interest free fund was many times more than the investment made for both the assessment years to the tune of Rs. 15,00,000/- for assessment year

M/S. MAHALAXMI SAWS PVT. LTD., H-39, ROAD NO.2B, RIICO INDUSTRIAL AREA, SIRSI ROAD, BINDAYAKA, JAIPUR,JAIPUR vs. INCOME TAX OFFICER WARD-4(2) JAIPUR, JAIPUR

In the result, this appeal of the assessee is allowed

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001.” From perusal of heading of section 14A, we observed that the "Expenditure incurred in relation to income

DCIT, JAIPUR vs. JAIPUR RUGS COMPANY (P) LTD., JAIPUR

In the result, the appeal filed by the assessee is partly allowed and appeal filed by the Revenue stands dismissed

2) by the eligible assessee. (14A) The provisions of this section shall not apply to any assessment or reassessment order

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, JAIPUR vs. M/S N. M. AGROFOOD PRODUCTS PVT. LTD., SRIGANGANAGAR

In the result the appeal of the revenue is dismissed

reassessment can be made." 32 DCIT vs. M/s N. M. Agrofood Products Pvt. Ltd. CIT VS. Kabul Chawla (2016) 380 ITR 573 (Del) (HC) "Completed assessments can be interfered with by the AO while making the assessment under s. 1534 only on the basis of some incriminating material unearthed during the course of search or requisition of documents or undisclosed

M/S. JHANDEWALA FOODS LIMITED 35, JOHARI BAZAR, JAIPUR,JAIPUR vs. ACIT CIRCLE-1, JAIPUR, CIRCLE-1, JAIPUR

In the result, the ground no

2) by the eligible assessee. 6 M/s Jhandewala Foods Ltd., Jaipur Vs. ACIT, Circle-01, Jaipur (14A) The provisions of this section shall not apply to any assessment or reassessment

URMILA RAJENDRA MUNDRA,AJMER vs. INCOME TAX OFFICER, WARD-2(2), AJMER, AJMER

In the result grounds raised by the assessee is allowed

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

2) of Act where the default arise for “Under Reported” 7 Urmila Rajendra Mundra vs. ITO Further refer LD/72/2018 MUMBAI ITA NO. 13/MUM/2023 in case of SALTWATER STUDIO LLP v/s NFAC date 22-05-23 where on A/c of Claim of EXPENDITURE disallowed; Penalty u/sec 270A was deleted. Further clause (3) to sec 270A sub clause (ii) to said section

ACIT, JAIPUR vs. RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORP., JAIPUR

In the result, appeals of the assessee are partly allowed and appeals of the Revenues are dismissed

reassessment order: 15. The Revenue has raised the following grounds:- “1. Whether on the facts and in the circumstances of the case and in law, the CIT(A) has erred in allowing deduction of Rs. 8,83,09,666/- on interest income (including penal interest income Rs. 8,83,09,666/- and other income of Rs. 56,05,249/-) 2

DCIT, JAIPUR vs. RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORPORTATION LTD., JAIPUR

In the result, appeals of the assessee are partly allowed and appeals of the Revenues are dismissed

reassessment order: 15. The Revenue has raised the following grounds:- “1. Whether on the facts and in the circumstances of the case and in law, the CIT(A) has erred in allowing deduction of Rs. 8,83,09,666/- on interest income (including penal interest income Rs. 8,83,09,666/- and other income of Rs. 56,05,249/-) 2

ACIT, JAIPUR vs. RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORP., JAIPUR

In the result, appeals of the assessee are partly allowed and appeals of the Revenues are dismissed

reassessment order: 15. The Revenue has raised the following grounds:- “1. Whether on the facts and in the circumstances of the case and in law, the CIT(A) has erred in allowing deduction of Rs. 8,83,09,666/- on interest income (including penal interest income Rs. 8,83,09,666/- and other income of Rs. 56,05,249/-) 2

RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORP. LTD.,JAIPUR vs. ACIT, JAIPUR

In the result, appeals of the assessee are partly allowed and appeals of the Revenues are dismissed

reassessment order: 15. The Revenue has raised the following grounds:- “1. Whether on the facts and in the circumstances of the case and in law, the CIT(A) has erred in allowing deduction of Rs. 8,83,09,666/- on interest income (including penal interest income Rs. 8,83,09,666/- and other income of Rs. 56,05,249/-) 2

RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORP. LTD.,JAIPUR vs. ACIT, JAIPUR

In the result, appeals of the assessee are partly allowed and appeals of the Revenues are dismissed

reassessment order: 15. The Revenue has raised the following grounds:- “1. Whether on the facts and in the circumstances of the case and in law, the CIT(A) has erred in allowing deduction of Rs. 8,83,09,666/- on interest income (including penal interest income Rs. 8,83,09,666/- and other income of Rs. 56,05,249/-) 2

RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORP. LTD.,JAIPUR vs. DCIT, JAIPUR

In the result, appeals of the assessee are partly allowed and appeals of the Revenues are dismissed

reassessment order: 15. The Revenue has raised the following grounds:- “1. Whether on the facts and in the circumstances of the case and in law, the CIT(A) has erred in allowing deduction of Rs. 8,83,09,666/- on interest income (including penal interest income Rs. 8,83,09,666/- and other income of Rs. 56,05,249/-) 2

DCIT, JAIPUR vs. RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORPORTATION LTD., JAIPUR

In the result, appeals of the assessee are partly allowed and appeals of the Revenues are dismissed

reassessment order: 15. The Revenue has raised the following grounds:- “1. Whether on the facts and in the circumstances of the case and in law, the CIT(A) has erred in allowing deduction of Rs. 8,83,09,666/- on interest income (including penal interest income Rs. 8,83,09,666/- and other income of Rs. 56,05,249/-) 2

RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORP. LTD.,JAIPUR vs. ACIT, JAIPUR

In the result, appeals of the assessee are partly allowed and appeals of the Revenues are dismissed

reassessment order: 15. The Revenue has raised the following grounds:- “1. Whether on the facts and in the circumstances of the case and in law, the CIT(A) has erred in allowing deduction of Rs. 8,83,09,666/- on interest income (including penal interest income Rs. 8,83,09,666/- and other income of Rs. 56,05,249/-) 2