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

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 VISION ESTATES 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 COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. M/S RIGID CONDUCTORS (RAJ.) 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 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

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं. / ITA Nos.931 to 936/JP/2024 निर्धारण वर्ष / Assessment Years : 2012-13 & 2014-15 to 2018-19 Dheeraj Singh Sisodiya 005, (Nayagaun) Ram Ganmandi, Kota बनाम DCIT, Vill. Beedmandi Vs. Central Circle, Kota स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: APAPS 6392 E अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by : Sh. P. C. Parwal, CA राजस्व की ओर से / Revenue by : Mrs. Alka Gautam,

reassessment proceedings, an assessee can neither claim nor be allowed a deduction that was not claimed in the original return. As such the assessment proceedings initiated on the basis of an action under Section 132 of the Act also cannot be utilised by the assessee to seek relief not claimed earlier. Sh. Dheeraj Singh Sisodiya vs. DCIT The ITAT Chennai

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

reassessment proceedings, an assessee can neither claim nor be allowed a deduction that was not claimed in the original return. As such the assessment proceedings initiated on the basis of an action under Section 132 of the Act also cannot be utilised by the assessee to seek relief not claimed earlier. Sh. Dheeraj Singh Sisodiya vs. DCIT The ITAT Chennai

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं. / ITA Nos.931 to 936/JP/2024 निर्धारण वर्ष / Assessment Years : 2012-13 & 2014-15 to 2018-19 Dheeraj Singh Sisodiya 005, (Nayagaun) Ram Ganmandi, Kota बनाम DCIT, Vill. Beedmandi Vs. Central Circle, Kota स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: APAPS 6392 E अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by : Sh. P. C. Parwal, CA राजस्व की ओर से / Revenue by : Mrs. Alka Gautam,

reassessment proceedings, an assessee can neither claim nor be allowed a deduction that was not claimed in the original return. As such the assessment proceedings initiated on the basis of an action under Section 132 of the Act also cannot be utilised by the assessee to seek relief not claimed earlier. Sh. Dheeraj Singh Sisodiya vs. DCIT The ITAT Chennai

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

reassessment proceedings, an assessee can neither claim nor be allowed a deduction that was not claimed in the original return. As such the assessment proceedings initiated on the basis of an action under Section 132 of the Act also cannot be utilised by the assessee to seek relief not claimed earlier. Sh. Dheeraj Singh Sisodiya vs. DCIT The ITAT Chennai

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

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

reassessment proceedings, an assessee can neither claim nor be allowed a deduction that was not claimed in the original return. As such the assessment proceedings initiated on the basis of an action under Section 132 of the Act also cannot be utilised by the assessee to seek relief not claimed earlier. Sh. Dheeraj Singh Sisodiya vs. DCIT The ITAT Chennai

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

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

reassessment proceedings, an assessee can neither claim nor be allowed a deduction that was not claimed in the original return. As such the assessment proceedings initiated on the basis of an action under Section 132 of the Act also cannot be utilised by the assessee to seek relief not claimed earlier. Sh. Dheeraj Singh Sisodiya vs. DCIT The ITAT Chennai

PINK CITY JEWEL HOUSE PRIVATE LIMITED ,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), JAIPUR

Section 14A of the Act can\nbe made if the assessee had not earned any exempt income? - HELD THAT:- A\nperusal of the Memorandum of the Finance Bill, 2022 reveals that it explicitly stipulates\nthat the amendment made to Section 14A will take effect from 1st April, 2022 and will\napply in relation to the assessment year

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