RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

260A - Whether since question of applicability\nof section 143(2) was specifically raised throughout but, prima facie, no finding\nbased on law had been recorded matter was to be remitted to High Court for\nfresh decision in accordance with law - Held, yes\n[2025] 171 taxmann.com 572 (Raipur - Trib.) Balbir Singh v. Assistant\nCommissioner of Income-tax\nSection

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

260A - Whether since question of applicability\nof section 143(2) was specifically raised throughout but, prima facie, no finding\nbased on law had been recorded matter was to be remitted to High Court for\nfresh decision in accordance with law - Held, yes\n[2025] 171 taxmann.com 572 (Raipur - Trib.) Balbir Singh v. Assistant\nCommissioner of Income-tax\nSection

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

260A - Whether since question of applicability\nof section 143(2) was specifically raised throughout but, prima facie, no finding\nbased on law had been recorded matter was to be remitted to High Court for\nfresh decision in accordance with law - Held, yes\n[2025] 171 taxmann.com 572 (Raipur - Trib.) Balbir Singh v. Assistant\nCommissioner of Income-tax\nSection

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

260A - Whether since question of applicability\nof section 143(2) was specifically raised throughout but, prima facie, no finding\nbased on law had been recorded matter was to be remitted to High Court for\nfresh decision in accordance with law - Held, yes\n[2025] 171 taxmann.com 572 (Raipur - Trib.) Balbir Singh v. Assistant\nCommissioner of Income-tax\nSection

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

reassess the total income of six assessment years immediately preceding\nthe assessment year relevant to the previous years in which such search is conducted or\nrequisition is made [and for the relevant assessment year or years):\n\n24\nITA Nos.480/JP/2025\nDCIT vs. Karnani Solvex Private Ltd.\n\n25. In the case of Rangroopchand Chordia, a Division Bench of this Court

RADHAKISHNA BENIWAL,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1, JAIPUR, JAIPUR

In the result, the appeal filed by the assessee in ITA no

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

reassessment into two stages and when viewed in that light allocation. The distribution of functions between the JAO and NFAC is complimentary and concurrent as contemplated under the various schemes and the statutory provisions. This balanced distribution underscores the legislative intent to create a seamless integration of traditional and faceless assessment mechanisms within a unified statutory framework This

RADHAKISHAN BENIWAL,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1, JAIPUR, JAIPUR

In the result, the appeal filed by the assessee in ITA no

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

reassessment into two stages and when viewed in that light allocation. The distribution of functions between the JAO and NFAC is complimentary and concurrent as contemplated under the various schemes and the statutory provisions. This balanced distribution underscores the legislative intent to create a seamless integration of traditional and faceless assessment mechanisms within a unified statutory framework This

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)

260A or an appeal to the Supreme Court under section 261 or revision under section 263 or section 264 and an order imposing or enhancing or reducing or cancelling penalty or dropping the proceedings for the imposition of penalty is passed before the order of60[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the Appellate Tribunal or the High

WHOLE SALE CLOTH MERCHANT ASSOCIATION ,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE KOTA , KOTA

In the result, the appeals of the assessee in ITA no

section\n11 (2) and 11(1)(a) of the\nAct\n33,50,772/-\n33,50,772/-\n5.\nUnverifiable Creditors\n16,75,286/-\n16,75,286/-\n6.\n15% of Construction\nExpenses\n1,20,00,440/-\n1,20,00,440/-\n7.\nDisallowance of Rs\n3,69,567 out of total\nexpenses

WHOLE SALE CLOTH MERCHANT ASSOCIATION ,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE KOTA , KOTA

section\n11 (2) and 11(1)(a) of the\nAct\n33,50,772/-\n33,50,772/-\n\n5.\nUnverifiable Creditors\n16,75,286/-\n16,75,286/-\n\n6.\n15% of Construction\nExpenses\n1,20,00,440/-\n1,20,00,440/-\n\n7.\nDisallowance of Rs\n3,69,567 out of total\nexpenses

GOVINDAM EXPORT,JAIPUR, RAJASTHAN vs. DCIT, CIRCLE-1, JPR, JAIPUR, RAJASTHAN

In the results all the appeals filed by the assessee ITA Nos

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

reassessment is passed pursuant to a search operation is a mandatory requirement of Section 153D of the Act and that such approval is not meant to be given mechanically. The Court also concurs with the finding of the ITAT that in the present cases such approval was granted mechanically without application of mind by the Additional CIT resulting in vitiating

DINESH KUMAR CHAURASIA,TONK vs. ACIT CEN CIR 3, JAIPUR, JPR

In the result, Ground No. 3 raised by the assessee is also allowed and order declared to be bad in law, as the same violated the Principle of Natural Justice

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyaldinesh Kumar Chaurasia, M/S. Mahendra Gargieya & Associates, 537-539, Gargieya’S 5Th Floor, Mahima Trinity, Near Jyoti Rao Phule College, New Sanganer Road, Jaipur – 302 019. Pan No.: Abapc 0810D ..... Appellant Vs. Acit, Central Circle - 3, Jaipur – 302 005. ..... Respondent

reassessment notice and upheld the order of the CIT (A). It is argued that ITAT did not deal with the grounds of appeal or the reasoning of the CIT (A) on the issue of deletion of protective assessment made by the AO. 4. This court has considered the grounds of appeal urged by the revenue in support of present appeal

GOVINDAM EXPORT,JAIPUR, RAJASTHAN vs. DCIT, CIRCLE-1, JAIPUR, RAJASTHAN

reassessment is\npassed pursuant to a search operation is a mandatory requirement of Section\n153D of the Act and that such approval is not meant to be given mechanically.\nThe Court also concurs with the finding of the ITAT that in the present cases such\napproval was granted mechanically without application of mind by the Additional\nCIT resulting in vitiating

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

GOVINDAM EXPORT,JAIPUR, RAJASTHAN vs. DCIT, CIRCLE-1, JAIPUR, RAJASTHAN

reassessment is\npassed pursuant to a search operation is a mandatory requirement of Section\n153D of the Act and that such approval is not meant to be given mechanically.\nThe Court also concurs with the finding of the ITAT that in the present cases such\napproval was granted mechanically without application of mind by the Additional\nCIT resulting in vitiating

GOVINDAM EXPORT,JAIPUR, RAJASTHAN vs. DCIT, CIRCLE-1, JAIPUR, RAJASTHAN

reassessment is\npassed pursuant to a search operation is a mandatory requirement of Section\n153D of the Act and that such approval is not meant to be given mechanically.\nThe Court also concurs with the finding of the ITAT that in the present cases such\napproval was granted mechanically without application of mind by the Additional\nCIT resulting in vitiating

SMT. SAROJ DHAKA,JAIPUR vs. ITO, WARD-6(3), JAIPUR

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

reassessment notice. The Hon’ble court thereafter, in para 4 considered the grounds of appeal urged by the revenue in support of the present appeal u/s 260A and finally in para 5 & 6 the Hon’ble Court was of the opinion that no substantial question of law arose and hence the appeal of the revenue was dismissed on both

SHRI KAILASH CHAND GEHLOT,JAIPUR vs. ITO, WARD-5(3) JAIPUR

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

reassessment notice. The Hon’ble court thereafter, in para 4 considered the grounds of appeal urged by the revenue in support of the present appeal u/s 260A and finally in para 5 & 6 the Hon’ble Court was of the opinion that no substantial question of law arose and hence the appeal of the revenue was dismissed on both