DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. KARNANI SOLVEX PRIVATE LIMITED, JAIPUR

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

2, Madhab\nKisto Sett Lane, Kolkata, 700007. In this regard certificate issued by land lord\nShri Santosh Kumar Soni (CIT(A) PBP-101-102) and bill of Rent (CIT(A)\nPBP-99-100) issued to lender company by land lord is enclosed.\n\n(iv) The existence of said place is further evident from copy of bill issued for\nelectricity

SUNIL CHABLANI,AJMER, RAJASTHAN vs. CIRCLE (INTL TAX), JAIPUR, JAIPUR, RAJASTHAN

220\n19,29,791\n2016-17 (5,96,200) 264\n6,14,267\n2017-18 (2,10,000)\n2,10,000\n39,27,473\nCapital Gain in FY 2018-\n19\n15,39,545\nDeductions/s 54 (Property\nPurchased in 28 May 2018\nRs.38,20,000/-\n15,39,545\nNIL\nDRP\nLong Term Capital Gain\nNe\nD\nDRP.1. Ne\nariat.\n3.4 However

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

LOVELY PROMOTERS PRIVATE LIMITED,KOLKATA vs. ACIT, CENTRAL CIRCLE, AJMER, AJMER

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

Bench: him regarding non mentioning of Document Identification Number (DIN) in the body of the order u/s. 127 of the Act dated 08-09-2021 and various other technical pleas raised in grounds of appeal regarding validity of notice u/s. 148 of the Act, thereby appellate order passed by the CIT(A) is non-speaking order and deserves to be quashed. 4. On the facts and in circumstances of the case and in law, the AO erred in issuing notice u/s. 148 of the Act as it was a search related case u/s. 132 r/w

reassessment proceedings initiated by notice u/s 148 of the Income-tax Act, 1961 were not legally transferred by the Chief Commissioner/Director General, Kolkata after recording and communicating the reasons and providing opportunity to the appellant as prescribed u/s 127(1) of the Income-tax Act, 1961. Our submissions:- Without prejudice to the above ground, it would be seen that

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

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

SHRI SALASAR BALAJI DEVELOPERS PVT. LTD,JAIPUR vs. INCOME TAX OFFICER, WARD 2(2), JAIPUR

In the result, the appeal of the assessee is allowed

2) Act, 2009. However, the Explanation 3 does\nnot and cannot override the necessity of fulfilling the conditions set out in the substantive part\nof section 147. An Explanation to a statutory provision is intended to explain its contents and\ncannot be construed to override it or to render the substance and core nugatory. Section 147\nhas the effect that

VISHNU KUMAR,BHARATPUR vs. ACIT OR JCIT OR DCIT OR ASST. CIT OR ITO, NATIONAL FACELESS ASSESSMENT CENTRE, BHARATPUR

Bench: This Appellate Tribunal, Feeling Aggrieved By The Order Dated 08.12.2023 Passed, U/S 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “ The Act”), By Learned Cit(A), Nfac, Delhi, Whereby His Appeal Relating To Assessment Year 2015-16 Has Been Dismissed. 2. The Assessee Was Before Learned Cit(A), Having Felt Dissatisfied With The Assessment Order Dated 29.03.2022 Passed By The Assessing

220 (Delhi).  CIT v. Rajeev Sharma, (2010) 192 taxman 197 (Allahabad). 13. Learned DR has referred to the findings recorded in para No. 5 of the impugned order by Learned CIT(A), to justify non issuance of any such notice to the assessee, and contended that non issuance of notice under section 143(2) does not adversely affect the case

SHRI SATISH CHANDRA KATTA,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR

reassessment proceedings.\nGROUND NO. 3\n33. In relation to Ground No. 3, an addition of Rs. 98,82,400 has been made to\nthe income of the assessee. As per the factual position emerging from the order of\nthe lower authorities and the material before us, at the time of search being\nconducted a rough paper was found, marked

KATRATHAL GRAM SEWA SAHKARI SAMITI LIMITED ,KATRATHAL vs. ITO WARD 1 SIKAR, SIKAR

section even though said issue did not find mention in the reasons\r\nrecorded and the notice issued under s.148. Since there was confusion\r\nprevailing with regard to the powers of the AO to assess or reassess on the\r\nissues for which no reasons were recorded, Expln. 3 came to be inserted as\r\nclarificatory. Now, after

PRADEEP KUMAR,JHUJHUNU vs. ITO WARD -2, JHUJHUNU

In the result, appeal of the assessee is allowed

Bench: HON’BLE SHRI SANDEEP GOSAIN (Judicial Member)

section even though said issue did not find mention in the reasons recorded and the notice issued under s. 148. Since there was confusion prevailing with regard to the powers of the AO to assess or reassess on the issues for which no reasons were recorded, Expln. 3 came to be inserted as clarificatory. Now, after the insertion of Expln

SIYARAM EXPORTS INDIA PVT. LTD.,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR

reassessment proceedings.\n\nGROUND NO. 3\n\n33. In relation to Ground No. 3, an addition of Rs. 98,82,400 has been made to\nthe income of the assessee. As per the factual position emerging from the order of\nthe lower authorities and the material before us, at the time of search being\nconducted a rough paper was found

JUHI BHANDARI, JAIPUR,JAIPUR vs. DCIT CIRCLE (INTL TAX), JAIPUR, JAIPUR

In the result, both appeals of the assessee are allowed

2) issued to the\nassessee alongwith:\nNA\nYES\nYES\n52-56\nYES\nYES\n57\nYES\nYES\n58\nYES\nYES\n59\nYES\nYES\ncopy of satisfaction note dated\n27.03.2023 recorded by\nAssessing Officer\n60-64\nYES\nYES\n13\n21.12.2023 Reply filed by the assessee\nalongwith:\nPassport copies\nBank Details\nInterest Certificates\nAgreement to sale dated\n07.06.2013 entered by the\nassessee

SHRI SATISH CHANDRA KATTA,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR

reassessment proceedings.\nGROUND NO. 3\n33. In relation to Ground No. 3, an addition of Rs. 98,82,400 has been made to\nthe income of the assessee. As per the factual position emerging from the order of\nthe lower authorities and the material before us, at the time of search being\nconducted a rough paper was found, marked

SHRI SATISH CHANDRA KATTA,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR

reassessment proceedings.\nGROUND NO. 3\n33. In relation to Ground No. 3, an addition of Rs. 98,82,400 has been made to\nthe income of the assessee. As per the factual position emerging from the order of\nthe lower authorities and the material before us, at the time of search being\nconducted a rough paper was found, marked

SIYARAM EXPORTS INDIA PRIVATE LIMITED,JAIPUR vs. ITO WARD 6(4), JAIPUR, JAIPUR

reassessment proceedings.\nGROUND NO. 3\n33. In relation to Ground No. 3, an addition of Rs. 98,82,400 has been made to\nthe income of the assessee. As per the factual position emerging from the order of\nthe lower authorities and the material before us, at the time of search being\nconducted a rough paper was found, marked