SHRI KALYAN BUILDMART PVT. LTD.,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result, appeals of the assessee are allowed and appeals of the revenue are dismissed

253 of the IT Act. Therefore, the assessee could have very well file the cross objection after receiving the notice of appeals filed by the revenue against the impugned orders of the ld. CIT (A). The ld. CIT (A) has not adjudicated the grounds raised by the assessee regarding validity of reopening on the reason that the issue of quantum

AJAY BAKLIWAL,KOTA vs. ACIT, CENTRAL CIRCLE, KOTA, KOTA

253 CTR 306\n(Gujarat)(01-03-2011) held that If upon further inquiry by the Assessing Officer,\nsuch details could be gathered and the nature of payment received by the\nassessee from SBL could be ascertained, to find out whether the same should be\ntreated as 'deemed dividend' under section 2(22)(e) or not, the same, would

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)

1,30,00,385/-which is chargeable to tax has escaped from assessment within the meaning of 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

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

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

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

Section 275 was substituted by the Taxation Laws (Amendment) Act, 1970, which came into effect from 1-4-1971. The change was explained by the Board vide Circular No. 56, dated 19-3-1971. Significantly, it postulated that section 275 of the Income-tax Act which specified the time-limit for completion of penalty proceedings has been substituted

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

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

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

Section 275 was substituted by the Taxation Laws (Amendment) Act, 1970, which came into effect from 1-4-1971. The change was explained by the Board vide Circular No. 56, dated 19-3-1971. Significantly, it postulated that section 275 of the Income-tax Act which specified the time-limit for completion of penalty proceedings has been substituted

DAYARAM YADAV,JAIPUR vs. CIT(A), NFAC

In the result, appeal of the assessee is allowed

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

253(5) of the Act, we hereby condone the delay of 153 days in filing the present appeal as we are satisfied that there was sufficient cause for not presenting the appeal within the prescribed time and the appeal is hereby admitted for adjudication on merits. 4. Now, coming to the merits of the case, as there were three orders

SYLVAN GREENS PRIVATE LIMITED,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 6, JAIPUR

In the result, the appeal of the assessee is allowed

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

reassess the income. 4. The assessee's contentions are not found acceptable. The assessee received subsidy from public funds to assist in carrying on its business. The VAT amount constitutes public funds of the State. Where such subsidy is granted to assist the acquisition of new plant and machinery for expansion of business or for setting up of new industries

ARUN BHARDWAJ,DELHI vs. ACIT CIRCLE 1 , JAIPUR

In the result, appeal of the assessee is allowed

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

253 ITR 798 (SC) submitted that the Apex Court have again reiterated that the expression “sufficient cause” should receive a liberal construction and held that advancing of substantial justice should be of prime importance. The ld. A/R, therefore, prayed that looking to the above facts and circumstances and settled legal position, the delay of 21 days caused may kindly

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

In the result, both appeals of the assessee are allowed

reassess\nall the six AYs' years immediately preceding the assessment correlatable\nto the search year or the “relevant assessment year” as defined in terms of\nExplanation 1 of Section 153A. The said approach is clearly unsustainable\nand contrary to the consistent line struck by the precedents noticed above.\nHon'ble Supreme Court in DCIT v. Sunil Kumar Sharma

M/S VIJAYETA BUILDCON PVT. LTD.,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JAIPUR

In the result, the ground of the assessee’s appeal is allowed

253(5) of the Act, we hereby condone the delay in filing the present appeal as we are satisfied that there was sufficient cause for not presenting the appeal within the prescribed time and the appeal is hereby admitted for adjudication on merits. 5. The assessee company has submitted an application praying for raising the following additional ground of appeal

PARIS ELYSEES INDIA PVT. LTD.,JAIPUR vs. DCIT, CIRCLE-7, JAIPUR

Bench: Him Against The Order Dated 05.12.2019 Passed Under Section 147/143(3) Of The Income Tax Act, [ For Short “Act” ] By Acit, Circle-07, Jaipur.

reassessment proceedings. 3. In the facts and circumstances of the case and in law, Id. CIT(A)/NFAC has erred in confirming the action of the Id. AO in making addition of Rs. 83,74,399/- under clause (i) of Explanation 1 of section 115JB while computing the book profits u/s 115JB of the Act. The action

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

In the result, appeal of the assessee is allowed

1) Limited (supra) had examined the import of\nExplanation 3 that was introduced to Section 147 of the Act by virtue of Finance (No.2) Act of\n2009. It would also be relevant to refer to the following extracts of the said decision: (copy\nannexed as Annexure-21)\n\n\"22 Explanation 3 lifts the embargo, which was inserted by judicial

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

1) of Sushil Securities P Ltd\nfor AY 2018-19 dated 11.04.2019\n322-\n334\n70. Copy of Director Report and Auditors report of\nAngita Plaza P Ltd along with Financial\nStatements\n335-\n346\n71. Copy of Director Report and Auditors report of\nVidya Laxmi Fabrics P Ltd along with Financial\nStatements\n347-\n358\n\n52\nITA Nos.480/JP/2025\nDCIT vs. Karnani

SH. ASHOK KUMAR PORWAL,JHALAWAR vs. JCIT, RANGE-1, KOTA, KOTA

In the result, appeal of the assessee is partly allowed

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

reassessment or recomputation and an order imposing a penalty under section 271 and other provisions. In its turn, section 253 provides for appeals to the Appellate Tribunal against orders passed by the Appellate Assistant Commissioner in regard to the matters mentioned therein. If there has been an appeal against the assessment or other order, the period of limitation for imposing

RAGHAV COMMODITIES,JAIPUR vs. ITO WARD 6(2), JAIPUR

In the result, the appeal of the assessee is partly allowed as indicated

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

reassessment proceedings as well as during the appellate proceedings in spite of multiple hearing opportunities provided to the appellant. The comprehensive submission made by the appellant is silent on this particular issue. It is needless to mention here that burden of proof lies on the appellant. 8 Raghav Commodities vs. ITO The appellant failed to discharge this primary onus

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, KOTA vs. M/S SHIV VEGPRO PVT. LTD., KOTA

In the result, appeal of the revenue is dismissed

reassessment was completed on 12.12.2018 whereby the AO has made addition under section 68 of the IT Act of Rs. 12,74,04,995/- along with disallowance of commission payment and freight payment total amounting to Rs. 12,83,51,717/-. The assessee challenged the action of the AO before the ld. CIT (A) both on merits of the addition

PROFESSIONAL AUTOMOTIVES PRIVATE LIMITED,JAMMU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JAIPUR

In the result the appeal of the assessee in ITA no

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील /ITA Nos.809 to 815/JP/2025 निर्धारण वर्ष /Assessment Years :2013-14 to 2019-20 Professional Automotives Pvt. बनाम ACIT, Ltd. Bahu Plaza, Bahu Plaza, Jammu Vs. Central Circle- 1, and Kashmir Jaipur स्थायी लेखा सं./जी.आई.आर. सं./PAN/GIR No.:AAACP9608E अपीलार्थी/Appellant प्र]त्यर्थी/Respondent निर्धारिती की ओर से / Assessee by :Shri Tarun Mittal, CA राजस्व की ओर से /Revenue by: Shri Ajey Malik, CIT (Th. V.C)

1), bei Vehicle rating of the gross vehicle weight and axel weight respectively as duly certified by the testing agencies for compliance of the rule 126, or in the maximum vehicle weight and maximum safe axle weight of each vehicle respectively as notified by the Central Government, or ill the maximum total load permitted to be carned by the tyre

UPENDRA KUMAR SONI,KOTA vs. ACIT, CENTRAL CIRCLE-KOTA, CENTRAL CIRCLE, KOTA

In the result, both the appeals of the assesee are allowed for statistical purposes

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

253(5) of the Income Tax Act, 1961 read with section 5 of Limitation Act in filling of appeal SHRI UPENDRAF KUMAR SONI VS ACIT, CENTRAL CIRCLE-KOTA Hon'ble Sir(s), The humble assessee appellant applicant respectfully prays for the condonation of delay in the filling of appeal for the following reason 1. That the Id. CIT (Appeals) passed