DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. VIPUL BANKA, SIKAR

In the result, the appeals of the revenue stands dismissed, and the

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

reassessment proceedings under Section 147/148 of the Act—by invoking Section 150 and relying on CBDT Instruction No. 1/2023— is ex-facie without jurisdiction, contrary to binding judicial precedent, and violative of the appellate framework under Sections 250/251 of the Act. 4. It is therefore humbly prayed that this Hon’ble Tribunal, in exercise of its plenary powers under Section

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. VAIBHAV BANKA, SIKAR

In the result, the appeals of the revenue stands dismissed, and the

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

reassessment proceedings under Section 147/148 of the Act—by invoking Section 150 and relying on CBDT Instruction No. 1/2023— is ex-facie without jurisdiction, contrary to binding judicial precedent, and violative of the appellate framework under Sections 250/251 of the Act. 4. It is therefore humbly prayed that this Hon’ble Tribunal, in exercise of its plenary powers under Section

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)

reassessments contemplated under section 153A. There is also no requirement under section 153A and other provisions requiring the Department to collect information and evidence for each and every year for six previous years under section 153A. Therefore, the argument of assessee that the information gathered either during pre-search enquiry or during the course of search cannot be made

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)

reassessments contemplated under section 153A. There is also no requirement under section 153A and other provisions requiring the Department to collect information and evidence for each and every year for six previous years under section 153A. Therefore, the argument of assessee that the information gathered either during pre-search enquiry or during the course of search cannot be made

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)

reassessments contemplated under section 153A. There is also no requirement under section 153A and other provisions requiring the Department to collect information and evidence for each and every year for six previous years under section 153A. Therefore, the argument of assessee that the information gathered either during pre-search enquiry or during the course of search cannot be made

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SUBHASH CHANDRA BANKA, JAIPUR

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

reassessment proceedings under Section\n147/148 of the Act—by invoking Section 150 and relying on CBDT Instruction No. 1/2023—\nis ex-facie without jurisdiction, contrary to binding judicial precedent, and violative of the\nappellate framework under Sections 250/251 of the Act.\n4. It is therefore humbly prayed that this Hon'ble Tribunal, in exercise of its plenary powers\nunder Section

SH. HARI PRAKASH GUPTA,JAIPUR vs. ITO, WARD-1(2), JAIPUR, JAIPUR

The appeal stands allowed

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

reassessment or recomputation under section 147, the Income- tax Officer shall serve on the assessee a notice containing all or any of the requirements which may be included in a notice under sub-section (2) of section 139; and the provisions of this Act shall, so far as may be, apply accordingly as if the notice were a notice issued

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. TRILOK DEWAN, SIKAR

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

reassessment proceedings under Section\n147/148 of the Act—by invoking Section 150 and relying on CBDT Instruction No. 1/2023—\nis ex-facie without jurisdiction, contrary to binding judicial precedent, and violative of the\nappellate framework under Sections 250/251 of the Act.\n\n4. It is therefore humbly prayed that this Hon'ble Tribunal, in exercise of its plenary powers\nunder

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, INCOME TAX OFFICE vs. SUPREME POLYMERS PRIVATE LIMITED, JAIPUR

In the results the appeal of the

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं. / ITA No. 189/JP/2025 निर्धारण वर्ष / Assessment Year : 2015-16 DCIT, Central Circle-03, Jaipur बनाम Vs. Supreme Polymers Pvt. Ltd. 137-138, Industrial Area, Jhotwara, Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AACCS 5773 P अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by: Shri Gaurav Nahata, CA राजस्व की ओर से / Revenue by : Mrs. Anita Rinesh, JCIT, Sr. DR सुनवाई की ता

reassessment under Sections 139, 147, 148, 149, 151 8 153. ………………….. 30. The argument that by enactment of Section 153A to 153D has not eclipsed Section 148 does not enhance the case of respondent to initiate the proceedings under Section 148. On fulfillment of two conditions for invoking Section 153C the proceeding in accordance with Section 153A are to be initiated

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

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

166 taxlok.com (IT) 663 (Jaipur) and Pradeep Kumar Dhanraj vs ITO [2023] 196 TAXLOK.COM (IT) 229 (Jaipur) squarely cover the case of the assessee and are most relevant. In light of the above submissions, facts on record and position of the law, the Appellant respectfully prays that: • The reassessment proceedings initiated under section

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

SH. HARI PRAKASH GUPTA,JAIPUR vs. ITO, WARD-1(2), JAIPUR, JAIPUR

reassessment or recomputation under section 147, the Income-\ntax Officer shall serve on the assessee a notice containing all or any of the\nrequirements which may be included in a notice under sub-section (2) of section\n139; and the provisions of this Act shall, so far as may be, apply accordingly as if\nthe notice were a notice issued

DINESSH KUMAR SHARMA,JAIPUR vs. ITO, WARD4(2), JAIPUR

In the result, appeal of the assessee is allowed

reassess such income and also any other income chargeable to tax which has escaped\nassessment and which comes to his notice subsequently in the course of the proceedings under\nthis section, or recomputed the loss or the depreciation allowance or any other allowance, as the\ncase may be, for the assessment year concerned (hereafter in this section and in sections

BABU LAL SHARMA,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JAIPUR

In the result, appeal of the assessee is allowed

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

reassess’ have been used at more than one place in the Section and a harmonious construction of the entire provision would lead to an irresistible conclusion that the word ‘assess’ has been used in the context of an abated proceedings and word “reasons” has been used for completed assessment proceedings, which would not abate as they are not pending

DEPUTY COMMISSINER OF INCOME TAX, LIC BUILDING vs. M/S GEE VEE DEVELOPERS PVT. LTD., JAIPUR

In the result, the appeals of the revenue stands dismissed

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

reassessment completed u/s 153A without any reference to the incriminating material, following the binding precedents as cited above including that of the Jurisdictional High Court, the addition made by the AO u/s 40(A)(3) is not sustainable and the same is hereby deleted. b) DCIT Vs Venus Overseas Pvt. Ltd. (ITAT Delhi) ITA Nos. 276, 277, 278 & 280/DEL/2015 dated

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, JAIPUR vs. M/S VISION ESTATES PVT. LTD., JAIPUR

In the result, the appeals of the revenue stands dismissed

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

reassessment completed u/s 153A without any reference to the incriminating material, following the binding precedents as cited above including that of the Jurisdictional High Court, the addition made by the AO u/s 40(A)(3) is not sustainable and the same is hereby deleted. b) DCIT Vs Venus Overseas Pvt. Ltd. (ITAT Delhi) ITA Nos. 276, 277, 278 & 280/DEL/2015 dated

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. M/S CHOKHI DHANI DEVELOPERS PVT. LTD., JAIPUR

In the result, the appeals of the revenue stands dismissed

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

reassessment completed u/s 153A without any reference to the incriminating material, following the binding precedents as cited above including that of the Jurisdictional High Court, the addition made by the AO u/s 40(A)(3) is not sustainable and the same is hereby deleted. b) DCIT Vs Venus Overseas Pvt. Ltd. (ITAT Delhi) ITA Nos. 276, 277, 278 & 280/DEL/2015 dated