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.”

2. These extended reassessment notices were issued by the Assessing Officers under the provision of section 148 of the Income-tax Act. 1961 (hereinafter referred to as "the Act") following the procedure prescribed under various sections pertaining to reassessment namely sections 147 to 151

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

RSD CONTAINERS PRIVATE LIMITED,JAIPUR vs. ITO, WARD 7(1), JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

151(ii) for cases beyond 3 years. 4. Natural Justice Fully Complied With - No Violation Contrary to the assessee's repeated assertions, all statutory notices under Sections 148A, 148, 143(2), and 142(1) were duly issued and responded to. The assessee has mischaracterized the absence of "incriminating documents": The reassessment

SHRI RAI SINGH SIHAG,JAIPUR vs. INCOME TAX OFFICER, WARD-3-1, JAIPUR

In the result, this appeal of the assessee is allowed

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 441/Jp/2019 Assessment Year: 2007-08 Shri Rai Singh Sihag, Cuke I.T.O. Vs. B-105, Vaishali Nagar, Ward- 3(1), Jaipur. Jaipur. Pan No.: Bgvps 4485 F Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri Ashok Kr. Gupta & Shri S.L. Jain (Advs.) Jktlo Dh Vksj Ls@ Revenue By :Shri A.S. Nehra (Addl.Cit) Lquokbz Dh Rkjh[K@ Date Of Hearing : 02/11/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 15/11/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. The Present Appeal Has Been Filed By The Assessee Against The Order Of The Ld. Cit(A)-1, Jaipur Dated 13/07/2017 For The A.Y. 2007-08. Following Grounds Have Been Taken By The Assessee: “1. The Reasons For Reopening Of The Assessment Not Valid :- That On The Facts & In The Circumstances Of The Case Ld. Ao Has Grossly Erred In Law & Facts In Invoking Action U/S 147.The Notice For Reassessment Is So Hastily Issued Without Examining The Correct Factual & Legal Position. The Action For Reassessment Is Often Made Without Application Of Mind Fairly & Objectively The Ao. Lakhmani Mewal Das 103 Itr 437 (Sc)

reassessment proceedings against the assessee. CIT Vs. Shree Rajasthan Syntex Ltd. (2009) 313 ITR 231 (Raj) SLP dismissed :(2009) 313 ITR (St.) 27 (SC) Sun Pharmaceutical Industries Lt. Vs. Dy. CIT (2016)287 CTR ( Del.) 621 2. Re- assessment without issue of notice u/s 143(2) :- That on the facts and in the circumstances of the case

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

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

151 as it is, as under :\n\n\"150. (1) Notwithstanding anything contained in s.149 the notice under s.148 may\nbe issued at any time of the purpose of making an assessment or reassessment or\n\n60\nITA No. 301 and others /JP/2025 & CO No. 2 and others-JP-2025\nDCIT vs. Vaibhav Banka and others\nrecomputation in consequence

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. 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. 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. 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. 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. 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. 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. 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. 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. 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

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). After the introduction of the group of Sections namely, 153A to 153C, the single block assessment concept was given a go-by. Under the new Section 153A, in a case where a search is initiated under Section 132 or requisition of books of account, documents or assets is made under Section 132A after 31.5.2003, the Assessing Officer is obliged

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

ACIT, NCR BUILDING, JAIPUR vs. HANS RAJ AGARWAL, VIDHYADHAR NAGAR JAIPUR

39. In view of the above discussion and findings, memorandum of cross objections No 1/JP/2025 filed by the assessee is allowed

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

2) the old Before expiry of four years Joint Commissioner regime from the end of the relevant assessment year Section 151(1) the old After expiry of four years Principal Chief regime from the end of the relevant Commissioner or Chief assessment year Commissioner or Principal Commissioner or Commissioner Section 151(i) the new Three years or less than Principal