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

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

153 has also been done away with in a case covered by Section 153A. With all the stops having been pulled out, the Assessing Officer under Section 153A has been entrusted with the duty of bringing to tax the total income of an assessee whose case is covered by Section 153A, by even making reassessments without any fetters, if need

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

153 has also been done away with in a case covered by Section 153A. With all the stops having been pulled out, the Assessing Officer under Section 153A has been entrusted with the duty of bringing to tax the total income of an assessee whose case is covered by Section 153A, by even making reassessments without any fetters, if need

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

153 has also been done away with in a case covered by Section 153A. With all the stops having been pulled out, the Assessing Officer under Section 153A has been entrusted with the duty of bringing to tax the total income of an assessee whose case is covered by Section 153A, by even making reassessments without any fetters, if need

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

153 has also been done away with in a case covered by Section 153A. With all the stops having been pulled out, the Assessing Officer under Section 153A has been entrusted with the duty of bringing to tax the total income of an assessee whose case is covered by Section 153A, by even making reassessments without any fetters, if need

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

153 has also been done away with in a case covered by Section 153A. With all the stops having been pulled out, the Assessing Officer under Section 153A has been entrusted with the duty of bringing to tax the total income of an assessee whose case is covered by Section 153A, by even making reassessments without any fetters, if need

DCIT, CENTRAL CIRCLE, AJMER vs. M/S SILVERTOSS COMMODITIES PVT. LTD., KOLKATA

The appeals of the revenue stand dismissed and the cross objections of the assessee are partly allowed

153 has also been done away with in a case covered by Section 153A. With all the stops having been pulled out, the Assessing Officer under Section 153A has been entrusted with the duty of bringing to tax the total income of an assessee whose case is covered by Section 153A, by even making reassessments without any fetters, if need

SMT. JAYA PREM BHATIA,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

In the result, the appeal of the assessee for A

153 has also been done away with in a case covered by Section 153A. With all the stops having been pulled out, the Assessing Officer under Section 153A has been entrusted with the duty of bringing to tax the total income of an assessee whose case is covered by Section 153A, by even making reassessments without any fetters, if need

SMT. JAYA PREM BHATIA,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

In the result, the appeal of the assessee for A

153 has also been done away with in a case covered by Section 153A. With all the stops having been pulled out, the Assessing Officer under Section 153A has been entrusted with the duty of bringing to tax the total income of an assessee whose case is covered by Section 153A, by even making reassessments without any fetters, if need

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

In the result, appeal of the revenue is allowed

153, the assessment or reassessment relating to any assessment year which has abated under the second proviso to sub-section (1), shall stand revived with effect from the date of receipt of the order of such annulment by the 30[Principal Commissioner or] Commissioner: Provided that such revival shall cease to have effect, if such order of annulment

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S KOTA DALL MILL, KOTA

153 has also been done away with in a case covered by Section 153A. With all the stops having been pulled out, the Assessing Officer under Section 153A has been entrusted with the duty of bringing to tax the total income of an assessee whose case is covered by Section 153A, by even making reassessments without any fetters, if need

M/S KOTA DALL MILL,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

153 has also been done away with in a case covered by Section 153A. With all the stops having been pulled out, the Assessing Officer under Section 153A has been entrusted with the duty of bringing to tax the total income of an assessee whose case is covered by Section 153A, by even making reassessments without any fetters, if need

M/S KOTA DALL MILL,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

153 has also been done away with in a case covered by Section 153A. With all the stops having been pulled out, the Assessing Officer under Section 153A has been entrusted with the duty of bringing to tax the total income of an assessee whose case is covered by Section 153A, by even making reassessments without any fetters, if need

M/S KOTA DALL MILL,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

153 has also been done away with in a case covered by Section 153A. With all the stops having been pulled out, the Assessing Officer under Section 153A has been entrusted with the duty of bringing to tax the total income of an assessee whose case is covered by Section 153A, by even making reassessments without any fetters, if need

DCIT, JAIPUR vs. VIMAL CHAND SURANA HUF, JAIPUR

In the result, the appeal of the revenue stands dismissed

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 on the following judicial pronouncements, the relevant extracts

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)

5) The Hon’ble High Court of Rajasthan in the case of CIT v. Uttam Chand Nahar [2007] 295 ITR 403 (Rajasthan) observed that “the initial satisfaction about the escapement of income, which requires initiation of proceedings under section 147, must be of the Assessing Officer himself”. If the conditions under section 151(1) or (2) require the satisfaction

SHRI BANNA LAL JAT,BHILWARA vs. ASSISTANT COMMISSIONER OF INCOME TAX, AJMER

In the result, theses appeals filed by the assessee are allowed

153 has also been done away with in a case covered by Section 153A. With all the stops having been pulled out, the Assessing Officer under Section 153A has been entrusted with the duty of bringing to tax the total income of an assessee whose case is covered by Section 153A, by even making reassessments without any fetters, if need

SHRI BANNA LAL JAT,BHILWARA vs. ASSISTANT COMMISSIONER OF INCOME TAX, AJMER

In the result, theses appeals filed by the assessee are allowed

153 has also been done away with in a case covered by Section 153A. With all the stops having been pulled out, the Assessing Officer under Section 153A has been entrusted with the duty of bringing to tax the total income of an assessee whose case is covered by Section 153A, by even making reassessments without any fetters, if need

SHRI BANNA LAL JAT,BHILWARA vs. ASSISTANT COMMISSIONER OF INCOME TAX, AJMER

In the result, theses appeals filed by the assessee are allowed

153 has also been done away with in a case covered by Section 153A. With all the stops having been pulled out, the Assessing Officer under Section 153A has been entrusted with the duty of bringing to tax the total income of an assessee whose case is covered by Section 153A, by even making reassessments without any fetters, if need