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)

Section 147/148 of the Act, relying on the same judgment of Abhisar Buildwell (supra), CBDT Instruction No. 1/2023 (CLC 35-40), and the provisions of Section 150 of the Act. The assessee, while supporting the ultimate relief granted, is aggrieved by the directions given by the ld. CIT(A) in his order suggesting the AO initiate proceedings under Section 147/148

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)

Section 147/148 of the Act, relying on the same judgment of Abhisar Buildwell (supra), CBDT Instruction No. 1/2023 (CLC 35-40), and the provisions of Section 150 of the Act. The assessee, while supporting the ultimate relief granted, is aggrieved by the directions given by the ld. CIT(A) in his order suggesting the AO initiate proceedings under Section 147/148

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 for such years. However as per second proviso, only those assessments will abate which are pending on the date of search. Thus the assessment not pending on the date of search will not abate and assessment for such non pending years will be only on the basis of incriminating material found during search in respect

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 for such years. However as per second proviso, only those assessments will abate which are pending on the date of search. Thus the assessment not pending on the date of search will not abate and assessment for such non pending years will be only on the basis of incriminating material found during search in respect

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 for such years. However as per second proviso, only those assessments will abate which are pending on the date of search. Thus the assessment not pending on the date of search will not abate and assessment for such non pending years will be only on the basis of incriminating material found during search in respect

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 69C. IV. Judicial Precedents Supporting Revenue’s Case 1. CIT v. Sun Engineering Works (P.) Ltd. [198 ITR 297 (SC)] o The scope of reassessment includes assessing all income that has escaped taxation. 2. Majinder Singh Kang v. CIT [344 ITR 358 (P&H)] o Any income coming to the AO’s notice during reassessment can be validly taxed

INCOME TAX OFFICER, WARD-1(2), JAIPUR, JAIPUR vs. MUKESH KUMAR SONI, JAIPUR

In the result appeal of the revenue is dismissed and the cross

Bench: Moving Towards The Facts Of The Case We Would Like To Mention

reassessment under Section 147, 148 & 148A of the Act in a faceless manner. Proceedings under Section 147 and Section 148 of the Act would now have to be taken as per the 34 ITA No. 656/JP/2023 & CO No. 06/JP/2023 ITO vs. Mukesh Kumar Soni procedure legislated by the Parliament in respect of reopening/ re-assessment i.e., proceedings under Section 148A

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

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

Section 69C.\nIV. Judicial Precedents Supporting Revenue’s Case\n1. CIT v. Sun Engineering Works (P.) Ltd. [198 ITR 297 (SC)]\n- The scope of reassessment includes assessing all income that has\nescaped taxation.\n2. Majinder Singh Kang v. CIT [344 ITR 358 (P&H)]\n- Any income coming to the AO’s notice during reassessment can be validly\ntaxed

MRS. RENU SEHGAL,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, JAIPUR

In the result, the appeals of the assessee is allowed and that of the

Bench: : Shri Vijay Pal Rao, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 837/Jp/2018 Fu/Kzkj.K O"Kz@Assessment Year : 2012-13 Cuke The Acit Smt. Renu Sehgal Vs. Central Circle-3 27, Onkar Nagar, Civil Lines Jaipur Jaipur Lfkk;H Ys[Kk La-@Thvkbzvkj La-@Pan/Gir No.: Aepps 3048 M Vihykfkhz@Appellant Izr;Fkhz@Respondent Vk;Dj Vihy La-@Ita No. 708 & 709 Jp/2018 Fu/Kzkj.K O"Kz@Assessment Year : 2012-13 & 2015-16 Cuke Mrs. Renu Sehgal The Dcit Vs. 227-278, Nemisagar Colony Central Circle-3, Vaishali Nagar, Jaipur Jaipur Lfkk;H Ys[Kk La-@Thvkbzvkj La-@Pan/Gir No.: Aepps 3048 M Vihykfkhz@Appellant Izr;Fkhz@Respondent Jktlo Dh Vksj Ls@ Revenue By : Shri Varinder Mehta, Cit-Dr Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri P.C. Parwal, Ca Lquokbz Dh Rkjh[K@ Date Of Hearing : 06/08/2019 ?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 19/08/2019 Vkns'K@ Order Per Vijay Pal Rao, Jm There Are Cross Appeals For The Assessment Year 2012-13 Directed Against The Order Dated 09-04-2013 Of The Ld. Cit(A)-4, Jaipur. The 2 Smt. Renu Sehgal Vs Dcit, Central Circle-3, Jaipur

reassess the total income for such years. However as per second proviso, only those assessments will abate which are pending on the date of search. Thus the assessment not pending on the date of search will not abate and assessment for such non pending years will be only on the basis of incriminating material found during search. In respect

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

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

Section 69C.\n\nIV. Judicial Precedents Supporting Revenue’s Case\n\n1. CIT v. Sun Engineering Works (P.) Ltd. [198 ITR 297 (SC)]\n• The scope of reassessment includes assessing all income that has\nescaped taxation.\n\n2. Majinder Singh Kang v. CIT [344 ITR 358 (P&H)]\n• Any income coming to the AO’s notice during reassessment

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

Section 69C.\nIV. Judicial Precedents Supporting Revenue’s Case\n1. CIT v. Sun Engineering Works (P.) Ltd. [198 ITR 297 (SC)]\no The scope of reassessment includes assessing all income that has\nescaped taxation.\n2. Majinder Singh Kang v. CIT [344 ITR 358 (P&H)]\no Any income coming to the AO’s notice during reassessment can be validly\ntaxed

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result of the appeal of the assessee are disposed off as under

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

Section 33(4) of the 1922 Act, analogous to Section 250/254 of the 1961 Act) do not confer on the appellate authority a power to make any direction on matters not arising in the appeal, especially as the Act provides separate mechanisms (like Section 34 of 1922 Act, now Section 147) to deal with escaped income. Accordingly, the Apex Court

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result of the appeal of the assessee are disposed off as under

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

Section 33(4) of the 1922 Act, analogous to Section 250/254 of the 1961 Act) do not confer on the appellate authority a power to make any direction on matters not arising in the appeal, especially as the Act provides separate mechanisms (like Section 34 of 1922 Act, now Section 147) to deal with escaped income. Accordingly, the Apex Court

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result of the appeal of the assessee are disposed off as under

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

Section 33(4) of the 1922 Act, analogous to Section 250/254 of the 1961 Act) do not confer on the appellate authority a power to make any direction on matters not arising in the appeal, especially as the Act provides separate mechanisms (like Section 34 of 1922 Act, now Section 147) to deal with escaped income. Accordingly, the Apex Court

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result of the appeal of the assessee are disposed off as under

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आंकड़ुठरधारी आइटीएए सं.र@ITA Nos.493, 495 to 498, 500/JP/2025 निर्धारण वर्ष@Assessment Years : 2014-15 to 2016-17, 2018-19 to 2020-21 Mahendra Kumar Goyal चुके Vs. ACIT/DCIT Ward No. 2, Shahpura Road Neem Ka Thana, Sikar Central Circle-03, Jaipur लेखा संख्याल्लेय सं.जीआइआर सं.पान@PAN/GIR No.: ACFPG0306G अपीलार्थी@Appellant प्रत्यार्थी@Respondent निर्धारीती की आर से@ Assessee by : Shri P. C. Parwal, CA राजस्व की आर से@ R

Section 33(4) of the 1922 Act, analogous to Section 250/254 of the 1961 Act) do not confer on the appellate authority a power to make any direction on matters not arising in the appeal, especially as the Act provides separate mechanisms (like Section 34 of 1922 Act, now Section 147) to deal with escaped income. Accordingly, the Apex Court

ACIT, CENTRAL CIRCLE-3, JAIPUR vs. LAXMI NARAIN AGARWAL, JAIPUR

In the result, for the assessment years 2009-10 and 2010-11

191 CTR 168/ 210 ITR 486. 8. In view of the facts mentioned above and circumstance of the case, provisions of section 145(3) are invoked and books of account are rejected. The Net Profit rate of 5.75% is applied on total contract receipts of Rs. 58,80,71,121/-, which gives net profit

ACIT, CENTRAL CIRCLE-3, JAIPUR vs. LAXMI NARAIN AGARWAL, JAIPUR

In the result, for the assessment years 2009-10 and 2010-11

191 CTR 168/ 210 ITR 486. 8. In view of the facts mentioned above and circumstance of the case, provisions of section 145(3) are invoked and books of account are rejected. The Net Profit rate of 5.75% is applied on total contract receipts of Rs. 58,80,71,121/-, which gives net profit

LAXMI NARAIN AGARWAL,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR

In the result, for the assessment years 2009-10 and 2010-11

191 CTR 168/ 210 ITR 486. 8. In view of the facts mentioned above and circumstance of the case, provisions of section 145(3) are invoked and books of account are rejected. The Net Profit rate of 5.75% is applied on total contract receipts of Rs. 58,80,71,121/-, which gives net profit

LAXMI NARAIN AGARWAL,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR

In the result, for the assessment years 2009-10 and 2010-11

191 CTR 168/ 210 ITR 486. 8. In view of the facts mentioned above and circumstance of the case, provisions of section 145(3) are invoked and books of account are rejected. The Net Profit rate of 5.75% is applied on total contract receipts of Rs. 58,80,71,121/-, which gives net profit