SH. KAPIL TANEJA,JAIPUR vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, JAIPUR

In the result, the appeal of the assessee is allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

reassessment under sections 139, 147, 148, 149, 151 & 153. 28. The language of explanation 2 to new section 148 is akin

M/S KOTA DALL MILL,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

M/S KOTA DALL MILL,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

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S KOTA DALL MILL, 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

M/S KOTA DALL MILL,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

DCIT, CENTRAL CIRCLE, AJMER vs. M/S SILVERTOSS COMMODITIES PVT. LTD., KOLKATA

The appeals of the revenue stand dismissed and the cross objections of the assessee are partly allowed

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

SMT. REEMA HARISH BHATIA,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX. CENTRAL CIRCLE, KOTA

28 ITA Nos. 1284(4)/JP/2018 Smt. Reema Harish Bhatia, Kota. in which the search took place there is only one determination of the total income, it has been provided in the second proviso of sub-Section (1) of Section 153A that any proceedings for assessment or reassessment

DEPUTY COMMISSIONER OF INCOME TAX. CENTRAL CIRCLE, KOTA vs. SMT. REEMA HARISH BHATIA, KOTA

28 ITA Nos. 1284(4)/JP/2018 Smt. Reema Harish Bhatia, Kota. in which the search took place there is only one determination of the total income, it has been provided in the second proviso of sub-Section (1) of Section 153A that any proceedings for assessment or reassessment

SMT. REEMA HARISH BHATIA,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

28 ITA Nos. 1284(4)/JP/2018 Smt. Reema Harish Bhatia, Kota. in which the search took place there is only one determination of the total income, it has been provided in the second proviso of sub-Section (1) of Section 153A that any proceedings for assessment or reassessment

SMT. REEMA HARISH BHATIA,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

28 ITA Nos. 1284(4)/JP/2018 Smt. Reema Harish Bhatia, Kota. in which the search took place there is only one determination of the total income, it has been provided in the second proviso of sub-Section (1) of Section 153A that any proceedings for assessment or reassessment

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. SMT. REEMA HARISH BHATIA, KOTA

28 ITA Nos. 1284(4)/JP/2018 Smt. Reema Harish Bhatia, Kota. in which the search took place there is only one determination of the total income, it has been provided in the second proviso of sub-Section (1) of Section 153A that any proceedings for assessment or reassessment

POOJASHISH INFRASTRUCTURES PVT. LTD.,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, KOTA

In the result, appeal of the assessee is allowed

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

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, AJMER vs. M/S SHRI RAJLAXMI DENIM, BHILWARA

In the result, appeal of the revenue is allowed

section 132A, as the case may be, shall abate25 : 26[Provided also that the Central Government may by rules27 made by it and published in the Official Gazette (except in cases where any assessment or reassessment has abated under the second proviso), specify the class or classes of cases in which the Assessing Officer shall not be required to issue

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S. MULTI METAL PRIVATE 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

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S. MULTI METAL PRIVATE 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

M/S. MULTI METAL PRIVATE 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

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S. MULTI METAL PRIVATE 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

M/S. MULTI METAL PRIVATE 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

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S. MULTI METAL PRIVATE 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