DCIT, CC-2, JAIPUR vs. M/S. ROYAL JEWELLERS, JAIPUR

In the result, appeals of the revenue stands dismissed

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

reassess the “total income” of the six years in separate assessment orders for each of the six years. In other words, there will be only one assessment order in respect of each of the six assessment years in which both the disclosed and the undisclosed income would be brought to tax. (iv) Although section 153A does not say that additions

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

156, for the apparent purpose of making machinery provisions relating to recovery of tax applicable. By such application only recovery indicated to be payable in the intimation became permissible. And nothing more can be inferred from the deeming provision. Therefore, there being no assessment under Section 143(1)(a), the question of change of opinion, as contended, does not arise

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

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

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

sections of Mulla's Principles of Mohammedan\nLaw including sec. 268 and submitted that in the circumstances of the case it must be\npresumed that the three ladies were the legally wedded wives of the respondent. The law\nhas not changed since the original assessments were made and it was open to the\nIncome Tax Officer to make that presumption

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

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

reassessment is not legally invalid. The\nappellant relied on various judicial decisions that the AO cannot reopen concluded\nassessment merely to re-examine any transaction for non-application of his mind on the\nmaterials already with him.\n\n5.13 The Hon’ble Supreme Court in the case of Calcutta Discount co. v. ITO (1961)\n41 ITR 191 held that once

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)

reassessment, referred to in clause (a) of sub-section (1), in a case where an order under sub- section (4) has been made accepting the application." 20. Sub-section (18) of Section 155 of the Income-tax Act is inserted vide Finance Act, 2022 w.e.f. 1-4-2022. The above referred provisions provide that deduction of any surcharge, cess, which

PINK CITY JEWEL HOUSE PRIVATE LIMITED ,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), JAIPUR

reassess the earlier\nassessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can't\nusurp the power of the CIT and recommend a revision.\nNo overlapping of powers of the authorities under the Act can be permitted. As the\nrevision proceedings in this case have triggered with the AO sending a proposal

SH. MUKUT BEHARI AGARWAL,JAIPUR vs. THE DCIT, CIRCLE 1, JAIPUR

In the result, the appeals of the assessee is allowed as indicated hereinabove

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

section 147 of the Act is bad in law and the re- assessment order is quashed. As we have quashed the reassessment on the preliminary legal ground of jurisdiction, various other grounds raised by the assessee on merits are not decided as they become only academic at this stage. Ground nos. 1 to 5 are allowed.” Further we rely

DCIT, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. KAMLAPRABHA L/H OF LATE SHRI GOPAL LAL JI GOSWAMI, KOTA

In the result, the appeal of the revenue is dismissed and the Cross objection of the assessee is disposed off in terms of the observation made herein above

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

Section 153C of the Income-tax Act, 1961 - Search and seizure - Assessment of any other person (Validity of) - Assessment year 2007- 08 - In appellate proceedings, Tribunal recorded a finding that satisfaction for initiation of proceedings under section 153C was recorded by Assessing officer on 02-02-2015 - Tribunal thus opined that Assessing Officer could not have initiated and passed

M/S. BANSIWALA IRON & STEEL ROLLING MILLS,JAIPUR vs. DCIT, CIRCLE-3,, 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. 1388/Jp/2019 Fu/Kzkj.K O"Kz@Assessment Year :2008-09 Cuke M/S Bansiwala Iron & Steel Rolling Mills, D.C.I.T., 2Nd Floor, Somani Building, S.C. Link Vs. Circle-3, Road, Loha Mandi, Jaipur. Jaipur. Lfkk;H Ys[Kk La-@Thvkbzvkj La-@Pan/Gir No.: Aadfb 2375 A Appellant Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By: Shri Mahendra Gargieya & Shri Dewang Gargieya (Advs) Jktlo Dh Vksj Ls@ Revenue By: Shri Rajendra Singh (Cit-Dr) Lquokbz Dh Rkjh[K@ Date Of Hearing : 06/09/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 15/09/2021 Vkns'K@ Order

reassessment proceedings were initiated only on the basis of information received from the investigation wing of the department. In the present case, the satisfaction regarding the escapement of income, was not of the Assessing Officer, therefore, without applying his mind, the Assessing Officer was not justified in invoking the provisions of Section 147 of the Act by issuing notice

GOBIND CHHANGOMAL SAJNANI,JAIPUR vs. INCOME TAX OFFICER, JAIPUR

sections": ["144", "147", "271(1)(c)", "142(1)", "143(2)", "156", "69A", "194A", "253", "249(3)"], "issues": "Whether the reassessment

VIKAS DUGAR L/H OF LATE SHRI KESHARI SINGH DUGAR,JAIPUR vs. PCIT (CENTRAL) JAIPUR, JAIPUR

In the result, the all the three appeals of the assessee are allowed

Bench: or in the course of hearing of the appeal.”

Section 153 A is relatable to abated proceedings (i.e. those pending on the date of search) and the word 'reassess' to completed assessment proceedings. 18. Similarly, in the case of Pr. Commissioner of Income Tax, Central-2 Vs. Meeta Gutgutia (2017) 395 ITR 526 (Del.), The Hon’ble Delhi High Court, held that : “47. What

VIKAS DUGAR L/H OF LATE SHRI KESHARI SINGH DUGAR,JAIPUR vs. PCIT (CENTRAL), JAIPUR

In the result, the all the three appeals of the assessee are allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

Section 153 A is relatable to abated proceedings (i.e. those pending on the date of search) and the word 'reassess' to completed assessment proceedings. 18. Similarly, in the case of Pr. Commissioner of Income Tax, Central-2 Vs. Meeta Gutgutia (2017) 395 ITR 526 (Del.), The Hon’ble Delhi High Court, held that : “47. What

VIKAS DUGAR LEGAL HEIR OF LATE SHRI KESHARI SINGH DUGAR,JAIPUR vs. PCIT (CENTRAL), JAIPUR

In the result, the all the three appeals of the assessee are allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

Section 153 A is relatable to abated proceedings (i.e. those pending on the date of search) and the word 'reassess' to completed assessment proceedings. 18. Similarly, in the case of Pr. Commissioner of Income Tax, Central-2 Vs. Meeta Gutgutia (2017) 395 ITR 526 (Del.), The Hon’ble Delhi High Court, held that : “47. What

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

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

156-159 Paigah House, Sardar Patel Road, Secunderabad, Telangana. |\n|---|---|---|\n| स्थायी लेखा सं./ जीआईआर सं./PAN/GIR No.: AABCG5541J | अपीलार्थी / Appellant | प्रत्यर्थी / Respondent |\n\nCO. No. 1 & 2/JPR/2022\n(Arising out of ITA. No. 306 & 307/JPR/2021)\nनिर्धारण वर्ष / Assessment Years : 2016-17 & 2017-18\n\n| M/s GVK Jaipur Expressway Pvt. Ltd. Toll Plaza, Ajmer Road, NH-8, Village Thikaria

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

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

156-159 Paigah House, Sardar Patel\n| Road, Secunderabad, Telangana.\n| स्थायी लेखा सं./ जीआईआर सं./PAN/GIR No.: AABCG5541J\n| अपीलार्थी / Appellant\n| प्रत्यर्थी / Respondent\n\nCO. No. 1 & 2/JPR/2022\n(Arising out of ITA. No. 306 & 307/JPR/2021)\nनिर्धारण वर्ष / Assessment Years : 2016-17 & 2017-18\n\n| M/s GVK Jaipur Expressway Pvt. Ltd.\n| Toll Plaza, Ajmer Road

SDC CONSTRUCTION,JAIPUR vs. ITO, WD 1(3), JIAPUR

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

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

reassessment proceedings initiated against the assessee under Section 147. 4. In the facts and circumstances the case and in law, Id. CIT(A)/NFAC has erred in confirming the action of the ld. AO, in making additions of Rs. 97,00,000, under Section 68, treating the cash credits of Rs. 72,00,000 from M/s Sanmati Gems

RAGHAV KUMAR DHOOT,JAIPUR vs. DCIT CENTRAL CIRCLE 1, JAIPUR

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

reassessment notice upon him-Held, yes-\n2.4 With regard to the contention of the assessee that the assessment\ncompleted is invalid in absence of notice u/s 143(2) by the DOT, Central\nCircle-1, Jaipur who had completed the assessment u/s 143(3) of the IT\nAct, 1961 on 18/04/2021, it is to be stated here that notice