DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S ORIENTAL POWER CABLES LTD., KOTA

reassessment resulting into the demand or proceedings of penalty." (Emphasis supplied) The said judgment which essentially deals with second proviso to Section 153A of the Act also supports the conclusion, which we have reached hereinbefore. 28. It has been observed by the Hon'ble Supreme Court in K.P. Varghese v. ITO [1981] 131 ITR 597/7 Taxman 13 that

M/S ORIENTAL POWER CABLES LTD.,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

reassessment resulting into the demand or proceedings of penalty." (Emphasis supplied) The said judgment which essentially deals with second proviso to Section 153A of the Act also supports the conclusion, which we have reached hereinbefore. 28. It has been observed by the Hon'ble Supreme Court in K.P. Varghese v. ITO [1981] 131 ITR 597/7 Taxman 13 that

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S ORIENTAL POWER CABLES LTD., KOTA

reassessment resulting into the demand or proceedings of penalty." (Emphasis supplied) The said judgment which essentially deals with second proviso to Section 153A of the Act also supports the conclusion, which we have reached hereinbefore. 28. It has been observed by the Hon'ble Supreme Court in K.P. Varghese v. ITO [1981] 131 ITR 597/7 Taxman 13 that

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S ORIENTAL POWER CABLES LTD., KOTA

reassessment resulting into the demand or proceedings of penalty." (Emphasis supplied) The said judgment which essentially deals with second proviso to Section 153A of the Act also supports the conclusion, which we have reached hereinbefore. 28. It has been observed by the Hon'ble Supreme Court in K.P. Varghese v. ITO [1981] 131 ITR 597/7 Taxman 13 that

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S ORIENTAL POWER CABLES LTD., KOTA

reassessment resulting into the demand or proceedings of penalty." (Emphasis supplied) The said judgment which essentially deals with second proviso to Section 153A of the Act also supports the conclusion, which we have reached hereinbefore. 28. It has been observed by the Hon'ble Supreme Court in K.P. Varghese v. ITO [1981] 131 ITR 597/7 Taxman 13 that

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 proceedings - validity of approval granted u/s 151(i) - HELD THAT:- Admittedly the assessment was reopened after elapsing of three years from the end of the relevant assessment year and therefore the approval of either of specified authorities as specified in sub clause (ii) of section 151 was required to be taken, which admittedly has not been taken

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S BARAN ROLLER FLOUR MILLS PVT. LTD., KOTA

264 CTR 86 (RAJASTHAN-HC), CIT v. Orissa Corpn. (P.) Ltd. [1986) 159 ITR 78/25 Taxman 80F (SC), Commissioner of Income-tax 21 ITA No. 1206(4)/JP/2018 M/s. Baran Roller Flour Mills Pvt. Ltd., Kota. v/s Mark Hospitals (P.) Ltd. [2015] 373 ITR 115 (Madras)(MAG.), Commissioner of Income-tax, Ajmer v. Jai Kumar Bakliwal

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S BARAN ROLLER FLOUR MILLS PVT. LTD., KOTA

264 CTR 86 (RAJASTHAN-HC), CIT v. Orissa Corpn. (P.) Ltd. [1986) 159 ITR 78/25 Taxman 80F (SC), Commissioner of Income-tax 21 ITA No. 1206(4)/JP/2018 M/s. Baran Roller Flour Mills Pvt. Ltd., Kota. v/s Mark Hospitals (P.) Ltd. [2015] 373 ITR 115 (Madras)(MAG.), Commissioner of Income-tax, Ajmer v. Jai Kumar Bakliwal

ARYA SAMAJ MANDIR ,BHILWARA vs. CIT(E), JAIPUR

Bench: The Date Of Hearing.”

section 264 is to be given by the Assessing Officer [or the Transfer Pricing Officer, as the case may be,] wholly or partly, otherwise than by making a fresh assessment or reassessment

ARYA SAMAJ MANDIR ,BHILWARA vs. CIT(E) , JAIPUR

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

section 264 is to be given by the Assessing Officer [or the Transfer\nPricing Officer, as the case may be,] wholly or partly, otherwise than by making a fresh\nassessment or reassessment

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)

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

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)

264 is passed: Provided further that the provisions of sub-section (2) of section 274 shall apply in respect of the order imposing or enhancing or reducing penalty under this sub- section. (2) The provisions of this section as they stood immediately before their amendment by the Direct Tax Laws (Amendment) Act, 1987 (4 of 1988), shall apply

SONU AGARWAL ,JAIPUR vs. INCOME TAX OFFICER WARD 1(3), JAIPUR

In the result, the appeal of the assessee is allowed

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

reassessment notice. In the present case the period of three years from the end of the Assessment Year 2016-17 fell for completion on 31st March 2020. Since the expiry date fell during the time period of 20th March 2020 and 31st March 2021 contemplated under Section 3(1) of Taxation and Other Laws (Relaxation and Amendment of Certain Provisions

URMILA RAJENDRA MUNDRA,AJMER vs. INCOME TAX OFFICER, WARD-2(2), AJMER, AJMER

In the result grounds raised by the assessee is allowed

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

section 264 shall be admissible against the order of assessment or reassessment, referred to in clause (a) of sub-section

OM PRAKASH AGARWAL,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX,JAIPUR-1, JAIPUR

In the result, the appeal is allowed

Bench: Us. In This Appeal The Assessee Has Raised The Following Grounds Of Appeal:-

264, the Commissioner may, either of his own motion or on an application by the assessee for revision, call for the records of any proceeding under this Act. However, in section 263 the expression "on his own motion" is absent. It is nowhere provided as to under what circumstances and on the basis of what type of information and source

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

In the result, appeal of the assessee is allowed

264 Taxman 287 (SC)(31-08-2018).\nRelevant extract from Shri Ram Singh's case is reproduced hereunder- (copy annexed as\nAnnexure-22)\n\nIt is only when in proceedings under section 147 the Assessing Officer assesses or reassesses

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. M/S CHOKHI DHANI DEVELOPERS PVT. LTD., JAIPUR

In the result, the appeals of the revenue stands dismissed

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

Section 153 A(1) will have to be mandatorily issued to the person 24 ITA No. 264 to 267/JP/2022 & CO No.13 to 16/JP/2022 DCIT vs. M/s Rigid Conductors (Raj.) Pvt. Ltd. searched requiring him to file returns for six Avs immediately preceding the previous year relevant to the AY in which the search takes place. ii Assessments and reassessments

DEPUTY COMMISSINER OF INCOME TAX, LIC BUILDING vs. M/S GEE VEE DEVELOPERS PVT. LTD., JAIPUR

In the result, the appeals of the revenue stands dismissed

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

Section 153 A(1) will have to be mandatorily issued to the person 24 ITA No. 264 to 267/JP/2022 & CO No.13 to 16/JP/2022 DCIT vs. M/s Rigid Conductors (Raj.) Pvt. Ltd. searched requiring him to file returns for six Avs immediately preceding the previous year relevant to the AY in which the search takes place. ii Assessments and reassessments