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63 results for “reassessment”+ Section 253(2)clear

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Key Topics

Section 14761Addition to Income54Section 143(3)38Section 14838Section 6834Section 14428Condonation of Delay21Reassessment17Reopening of Assessment17

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

ITA 1275/JPR/2024[2012-13]Status: DisposedITAT Jaipur11 Apr 2025AY 2012-13
For Appellant: Sh. Rajendra Sisodia, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 132(1)Section 139Section 142Section 143(2)Section 143(3)Section 148Section 153ASection 2(22)(e)Section 250

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

Showing 1–20 of 63 · Page 1 of 4

Section 25016
Section 153A16
Section 271D16

SHRI SHRAVAN CHOUDHARY,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5, JAIPUR

In the result, appeal of the assessee is allowed

ITA 517/JPR/2019[2010-11]Status: DisposedITAT Jaipur07 Aug 2019AY 2010-11

Bench: The Date Of Hearing.”

For Appellant: Shri Siddharth Ranka &For Respondent: Shri B.K. Gupta (CIT)
Section 143(3)Section 147Section 148Section 2(22)(e)

reassessment order. 9. On the other hand, the ld. D/R has submitted that though the return might have been filed with Circle-2, Jaipur, however the processing under section 143(1) has been done by Circle-5, Jaipur and, therefore, the jurisdiction of AO Circle-5, Jaipur is based on the address shown in the PAN of the assessee

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

ITA 153/JPR/2018[2008-09]Status: DisposedITAT Jaipur28 Jun 2018AY 2008-09
For Appellant: Shri S.R. Sharma and Shri R.K. Batra (C.As.)For Respondent: Shri Varinder Mehta (CIT)
Section 253Section 253(4)

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

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

ITA 152/JPR/2018[2007-08]Status: DisposedITAT Jaipur28 Jun 2018AY 2007-08
For Appellant: Shri S.R. Sharma and Shri R.K. Batra (C.As.)For Respondent: Shri Varinder Mehta (CIT)
Section 253Section 253(4)

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

ACIT, JAIPUR vs. SHRI KALYAN BUILDMART PVT. LTD., JAIPUR

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

ITA 517/JPR/2017[2007-08]Status: DisposedITAT Jaipur28 Jun 2018AY 2007-08
For Appellant: Shri S.R. Sharma and Shri R.K. Batra (C.As.)For Respondent: Shri Varinder Mehta (CIT)
Section 253Section 253(4)

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

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

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

ITA 901/JPR/2024[2014-15]Status: DisposedITAT Jaipur11 Mar 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Sidharth RankaFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 147

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

SHRI DIGAMBER JAIN ATIKSHAYA KESHTRA,PADAMPUA vs. ITO EXEMPTION WARD 1, KAILASH HEIGHTS

In the result appeal of the assessee is partly allowed

ITA 424/JPR/2022[2010-11]Status: DisposedITAT Jaipur22 Aug 2023AY 2010-11

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

For Appellant: Shri Rajeev sogani (C.A)&For Respondent: Ms. Monisha Choudhary (Addl.CIT)
Section 11(2)Section 147Section 148Section 151Section 24Section 253(3)

reassessment proceedings being illegal and without jurisdiction. 4. In the facts and circumstances of the case and in law, Ld CIT(A) has erred in confirming the action of ld. AO of not allowing exemption to the assessee trust in accordance with section 11(2). The action of the ld. CIT(A) is illegal, unjustified, arbitrary and against the facts

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

ITA 480/JPR/2025[2014-15]Status: DisposedITAT Jaipur13 Oct 2025AY 2014-15
For Appellant: Shri Deepak Sharma, CAFor Respondent: MS. Alka Gautam, CIT
Section 132(4)Section 153ASection 68

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

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

In the result, appeal of the assessee is partly allowed

ITA 572/JPR/2023[2010-11]Status: DisposedITAT Jaipur19 Dec 2023AY 2010-11

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

For Appellant: Sh. P. C. Parwal (CA)For Respondent: Smt Monisha Chaudhary (Addl. CIT)
Section 133(6)Section 147Section 269SSection 271D

2). Section 246 covers many cases including orders of assessment, reassessment or recomputation and an order imposing a penalty under section 271 and other provisions. In its turn, section 253

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

ITA 1276/JPR/2024[2014-15]Status: DisposedITAT Jaipur11 Apr 2025AY 2014-15
For Appellant: Shri Rajendra SisodiaFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 132Section 132(1)Section 132(4)Section 139Section 143(3)Section 153ASection 250

2)(vii) of the Income Tax Act, the arguments with regard to non applicability of \nsection 41(1) are not found to be relevant.\nIn the reply the appellant stated during the appellate proceedings dated \n19.07.2024 that the total amount of Rs.16,50,00,000/- was received by M/s Nav \nBharat Nirman Co. (JV) as loan and the same

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

In the result, appeal of the assessee is allowed

ITA 382/JPR/2022[2010-11]Status: DisposedITAT Jaipur28 Mar 2023AY 2010-11

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

For Appellant: Shri C. L. Yadav (C.A.) &For Respondent: Smt Monisha Choudhary (Addl. CIT) a
Section 253Section 253(5)Section 271(1)(b)

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

ARUN BHARDWAJ,DELHI vs. ACIT CIRCLE 1 , JAIPUR

In the result, appeal of the assessee is allowed

ITA 1190/JPR/2024[2010-2011]Status: DisposedITAT Jaipur08 Jan 2025AY 2010-2011

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

For Appellant: Shri S.L. Jain, Advocate &For Respondent: Shri Gautam Singh Choudhary, JCIT
Section 139(1)Section 147Section 148Section 234ASection 250

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

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

In the result, appeal of the assessee is allowed

ITA 1393/JPR/2024[2013-14]Status: DisposedITAT Jaipur24 Jun 2025AY 2013-14
For Appellant: Shri Shivangi Chopra, C.AFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 139(1)Section 143(2)Section 144Section 147Section 148Section 250Section 69A

2) Act of 2009. However, Explanation 3 does not and cannot\noverride the necessity of fulfilling the conditions set out in the substantive part of section 147.\nAn Explanation to a statutory provision is intended to explain to contents and cannot be\nconstrued to override it or render the substance and core nugatory, Section 147 has this effect\nthat

PINCITY JEWLHOUSE PVT. LTD.,JAIPUR vs. PCIT, CC, JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 63/JPR/2021[2015-16]Status: DisposedITAT Jaipur07 Mar 2024AY 2015-16

Bench: the date of hearing." 3. At the outset of hearing, the Bench observed that there is delay of 58 days in filing of the present appeal by the assessee for which the Id. AR of 3

For Appellant: Sh. Siddharth Ranka, Adv. &For Respondent: Sh. Ajey Malik, CIT
Section 10ASection 147Section 253(5)Section 263Section 5

section 147 r.w.s 143(3) of the Income Tax Act, by ACIT, Circle-2, Jaipur. 2. In this appeal, the assessee has raised following grounds: - 2 Pinkcity Jewelhouse Pvt. Ltd. vs. PCIT “1. That on the facts and in the circumstances of the case, the ld. Principal Commissioner of Income-tax grossly erred in passing an order

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

ITA 681/JPR/2023[2012-13]Status: DisposedITAT Jaipur19 Sept 2024AY 2012-13

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.

For Appellant: Sh. Rohan Sogani, CAFor Respondent: Sh. Anup Singh, Addl. CIT
Section 115JSection 147Section 148Section 151Section 250Section 253(5)

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

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

In the result, the appeal of the assessee is allowed

ITA 414/JPR/2025[2015-16]Status: DisposedITAT Jaipur25 Jul 2025AY 2015-16

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

For Appellant: Smt. Neelam Bhala, AdvocateFor Respondent: Shri Gorav Avasthi, JCIT-DR
Section 142(1)Section 143(3)Section 147Section 148Section 250Section 801C

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

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

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

ITA 1277/JPR/2024[2015-16]Status: DisposedITAT Jaipur11 Apr 2025AY 2015-16
For Appellant: Shri Rajendra SisodiaFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 132Section 132(1)Section 132(4)Section 139Section 143(3)Section 153ASection 250

section 132 of the Income Tax act together. The documents related to dissolution of JV of both of them were found from the premises of both the persons. Both of them accepted that the transaction in question was not loan but an accommodation entry against the settlement of dispute. In fact, some of the amounts as per seized paper

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

In the result, both appeals of the assessee are allowed

ITA 234/JPR/2025[2015-16]Status: DisposedITAT Jaipur13 Aug 2025AY 2015-16
For Appellant: Shri Siddharth Ranka, AdvFor Respondent: Smt. Runi Pal, CIT (through VC)
Section 144C(5)Section 153CSection 69

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

ACIT, NCR BUILDING, JAIPUR vs. HANS RAJ AGARWAL, VIDHYADHAR NAGAR JAIPUR

39. In view of the above discussion and findings, memorandum of cross objections No 1/JP/2025 filed by the assessee is allowed

ITA 1253/JPR/2024[2016-17]Status: DisposedITAT Jaipur12 Mar 2025AY 2016-17

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Aditya Vijay, Adv. &For Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 132Section 142(1)Section 143(1)(a)Section 147Section 148Section 250

2. 17.09.2018 20.09.2018 3. 29.09.2018 27.09.2018 4. 03.10.2018 07.10.2018 5. 10.10.2018 12.10.2018 6. 19.10.2018 24.10.2018 7. 05.11.2018 11.11.2018 8. 12.11.2018 13.11.2018 4.6 It is seen that AO during the scrutiny assessment issued the letter dated 12/09/2018 whereby appellant was asked to submit the details through e-filing which also included the demat account for F.Y. 2015-16, details of work

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

ITA 980/JPR/2018[2007-08]Status: DisposedITAT Jaipur27 Oct 2020AY 2007-08
For Appellant: Sh. S. R. Sharma (CA) &For Respondent: Sh. B. K. Gupta (CIT)
Section 153ASection 253(5)Section 40A(3)

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