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)

reassessment proceedings and it is only the assessment made under Section 153A of the Act would be the assessment for the said year. 20

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)

reassessment proceedings and it is only the assessment made under Section 153A of the Act would be the assessment for the said year. 20

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)

reassessment proceedings and it is only the assessment made under Section 153A of the Act would be the assessment for the said year. 20

INCOME TAX OFFICER , SIKAR vs. BHASKAR CHAUHAN, JAIPUR

In the result the appeal of the revenue in ITA no

Bench: Him.

reassessment under Sections 139,147,148,149,151 & 153. " In view of the above discussion, the assessment completed u/s 144 deserves to be quashed. The order of the Learned CIT(A) also deserved to be quashed on this ground. Additional Ground No.2 On the facts and in the circumstances of the case and in law, the Learned

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.”

reassessment notices under Section 148, which fell for completion from 20 March 2020 to 31 March 2021, till 30 June

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)

reassessment of income of the person other than search persons based on seized material can only be made u/s 153C r.w.s. 153A and the provisions of section 147/148 of the Act are not applicable in such cases without appreciating the fact that it is nowhere written in any of the section of the Income Tax Act that proceedings

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

In the result, the appeal of the assessee is allowed

reassessment notices under section 148, which fell for completion from 20 March 2020 to 31 March 2021, till 30 June

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 sections 147/48 of the Act. subject to\nfulfilment of the conditions mentioned in sections 147/148, as in such a situation, the\nRevenue cannot be left with no remedy. Therefore, even in case of block assessment\nunder section 153A and in case of unabated/completed assessment and in case no\nincriminating material is found during the search, the power

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

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

reassessment matters nor vests any such power in the Id.\nCIT(A). Even other wise the Instruction cannot substitute the independent\nstatutory preconditions under Sections 147/148 read with Section 149,\nwhich provides the timelines for issuance of notice of reopening. Provision\nof such section must be satisfied by the Id. AO at any given point of time,\nwhen the jurisdiction

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

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

reassessment matters nor vests any such power in the Id.\nCIT(A). Even other wise the Instruction cannot substitute the independent\nstatutory preconditions under Sections 147/148 read with Section 149,\nwhich provides the timelines for issuance of notice of reopening. Provision\nof such section must be satisfied by the Id. AO at any given point of time,\nwhen the jurisdiction

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

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

reassessment matters nor vests any such power in the Id.\nCIT(A). Even other wise the Instruction cannot substitute the independent\nstatutory preconditions under Sections 147/148 read with Section 149,\nwhich provides the timelines for issuance of notice of reopening. Provision\nof such section must be satisfied by the Id. AO at any given point of time,\nwhen the jurisdiction

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

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

reassessment matters nor vests any such power in the Id.\nCIT(A). Even other wise the Instruction cannot substitute the independent\nstatutory preconditions under Sections 147/148 read with Section 149,\nwhich provides the timelines for issuance of notice of reopening. Provision\nof such section must be satisfied by the Id. AO at any given point of time,\nwhen the jurisdiction

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

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

reassessment matters nor vests any such power in the Id.\nCIT(A). Even other wise the Instruction cannot substitute the independent\nstatutory preconditions under Sections 147/148 read with Section 149,\nwhich provides the timelines for issuance of notice of reopening. Provision\nof such section must be satisfied by the Id. AO at any given point of time,\nwhen the jurisdiction

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

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

reassessment matters nor vests any such power in the Id.\nCIT(A). Even other wise the Instruction cannot substitute the independent\nstatutory preconditions under Sections 147/148 read with Section 149,\nwhich provides the timelines for issuance of notice of reopening. Provision\nof such section must be satisfied by the Id. AO at any given point of time,\nwhen the jurisdiction

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

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

reassessment matters nor vests any such power in the Id.\nCIT(A). Even other wise the Instruction cannot substitute the independent\nstatutory preconditions under Sections 147/148 read with Section 149,\nwhich provides the timelines for issuance of notice of reopening. Provision\nof such section must be satisfied by the Id. AO at any given point of time,\nwhen the jurisdiction

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

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

reassessment matters nor vests any such power in the Id.\nCIT(A). Even other wise the Instruction cannot substitute the independent\nstatutory preconditions under Sections 147/148 read with Section 149,\nwhich provides the timelines for issuance of notice of reopening. Provision\nof such section must be satisfied by the Id. AO at any given point of time,\nwhen the jurisdiction