DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SUBHASH CHANDRA BANKA, JAIPUR

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

reassessment under\nSections 147/148 read with Section 150. However, the nature, scope, and\nlegal force of this instruction remain subject to statutory limitations and judicial\nprecedent, as discussed below.\n2. 4. CBDT INSTRUCTION NO. 1/2023 IS ADMINISTRATIVE IN NATURE – NOT BINDING\nON CIT(A).\n2.4.i. It is submitted that Instruction No. 1/2023 (CLC 35

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. VAIBHAV BANKA, SIKAR

In the result, the appeals of the revenue stands dismissed, and the

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

reassessment under Sections 147/148 read with Section 150. However, the nature, scope, and legal force of this instruction remain subject to statutory limitations and judicial precedent, as discussed below. 2.4. CBDT INSTRUCTION NO. 1/2023 IS ADMINISTRATIVE IN NATURE – NOT BINDING ON CIT(A). 2.4.i. It is submitted that Instruction No. 1/2023 (CLC 35

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. VIPUL BANKA, SIKAR

In the result, the appeals of the revenue stands dismissed, and the

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

reassessment under Sections 147/148 read with Section 150. However, the nature, scope, and legal force of this instruction remain subject to statutory limitations and judicial precedent, as discussed below. 2.4. CBDT INSTRUCTION NO. 1/2023 IS ADMINISTRATIVE IN NATURE – NOT BINDING ON CIT(A). 2.4.i. It is submitted that Instruction No. 1/2023 (CLC 35

INCOME TAX OFFICER , SIKAR vs. BHASKAR CHAUHAN, JAIPUR

In the result the appeal of the revenue in ITA no

Bench: Him.

reassess total income for entire six years block assessment period even in case of completed/unabated assessment. In respect of completed assessments/unabated assessments no addition can be made by Assessing Officer in absence of any incriminating material found during course of search under section 132 or requisition under section 132A. Completed/unabated assessments can be reopened by Assessing Officer in exercise

DCIT, CC-2, JAIPUR vs. SHRI VIMAL CHAND SURANA(HUF), JAIPUR

In the result, the appeal of the revenue stands dismissed

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

reassessment provisions. Prior to, the introduction of these three Sections, there was Chapter XIV- B of the Act which took care of the assessment to be made in cases of search and seizure. Such an assessment was popularly known as block assessment because the Chapter provided for a single assessment to be made in respect of a period

DCIT, CC-2, JAIPUR vs. M/S. ROYAL JEWELLERS, JAIPUR

In the result, appeals of the revenue stands dismissed

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

reassessments contemplated under section 153A. There is also no requirement under section 153A and other provisions requiring the Department to collect information and evidence for each and every year for six previous years under section 153A. Therefore, the argument of assessee that the information gathered either during pre-search enquiry or during the course of search cannot be made

DCIT, CC-2, JAIPUR vs. M/S. ROYAL JEWELLERS, JAIPUR

In the result, appeals of the revenue stands dismissed

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

reassessments contemplated under section 153A. There is also no requirement under section 153A and other provisions requiring the Department to collect information and evidence for each and every year for six previous years under section 153A. Therefore, the argument of assessee that the information gathered either during pre-search enquiry or during the course of search cannot be made

DCIT, CC-2, JAIPUR vs. M/S. ROYAL JEWELLERS, JAIPUR

In the result, appeals of the revenue stands dismissed

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

reassessments contemplated under section 153A. There is also no requirement under section 153A and other provisions requiring the Department to collect information and evidence for each and every year for six previous years under section 153A. Therefore, the argument of assessee that the information gathered either during pre-search enquiry or during the course of search cannot be made

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. TRILOK DEWAN, SIKAR

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

reassessment under\nSections 147/148 read with Section 150. However, the nature, scope, and\nlegal force of this instruction remain subject to statutory limitations and judicial\nprecedent, as discussed below.\n\n2. 4. CBDT INSTRUCTION NO. 1/2023 IS ADMINISTRATIVE IN NATURE – NOT BINDING\nON CIT(A).\n\n2.4.i.\nIt is submitted that Instruction No. 1/2023 (CLC 35

RSD CONTAINERS PRIVATE LIMITED,JAIPUR vs. ITO, WARD 7(1), JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

35 RSD Containers Pvt Ltd. vs ITO 11/07/2022, the said notice issued under Section 148 of the Act is time barred and therefore, bad in law. Therefore, notice, dated 28/07/2022, issued under Section 148 of the Act (new regime), the consequential reassessment

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.”

35 Late Shri Jitendra Nagar through L/R Smt. Deepika Nagar, Baran. time may be extended by the Assessing Officer as provided in clause (b) of new section 148A of the Act.  After receiving the reply, the Assessing Officer shall decide on the basis of material available on record including reply of the assessee, whether

DCIT, CENTRAL CIRCLE-1, JAIPUR , JAIPUR vs. USHA BANKA, SIKAR

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

35-40), and the provisions of Section 150 of the Act.\nThe assessee, while supporting the ultimate relief granted, is aggrieved\nby the directions given by the Id. CIT(A) in his order suggesting the AO\ninitiate proceedings under Section 147/148 of the Act. The assessee\ntherefore before us by preferring the present Cross-Objection to challenge\nthe directions

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. PRIYA DEWAN, SIKAR

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

35-40), and the provisions of Section 150 of the Act.\nThe assessee, while supporting the ultimate relief granted, is aggrieved\nby the directions given by the Id. CIT(A) in his order suggesting the AO\ninitiate proceedings under Section 147/148 of the Act. The assessee\ntherefore before us by preferring the present Cross-Objection to challenge\nthe directions

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. VIPUL BANKA, SIKAR

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

35-40), and the provisions of Section 150 of the Act.\nThe assessee, while supporting the ultimate relief granted, is aggrieved\nby the directions given by the Id. CIT(A) in his order suggesting the AO\ninitiate proceedings under Section 147/148 of the Act. The assessee\ntherefore before us by preferring the present Cross-Objection to challenge\nthe directions

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SARITA DEWAN, SIKAR

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

35-40), and the provisions of Section 150 of the Act.\nThe assessee, while supporting the ultimate relief granted, is aggrieved\nby the directions given by the Id. CIT(A) in his order suggesting the AO\ninitiate proceedings under Section 147/148 of the Act. The assessee\ntherefore before us by preferring the present Cross-Objection to challenge\nthe directions

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. USHA BANKA, SIKAR

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

35-40), and the provisions of Section 150 of the Act.\nThe assessee, while supporting the ultimate relief granted, is aggrieved\nby the directions given by the Id. CIT(A) in his order suggesting the AO\ninitiate proceedings under Section 147/148 of the Act. The assessee\ntherefore before us by preferring the present Cross-Objection to challenge\nthe directions

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SNEHLATA AGARWAL, SIKAR

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

35-40), and the provisions of Section 150 of the Act.\nThe assessee, while supporting the ultimate relief granted, is aggrieved\nby the directions given by the Id. CIT(A) in his order suggesting the AO\ninitiate proceedings under Section 147/148 of the Act. The assessee\ntherefore before us by preferring the present Cross-Objection to challenge\nthe directions

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SUBHASH CHANDRA BANKA, SIKAR

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

35-40), and the provisions of Section 150 of the Act.\nThe assessee, while supporting the ultimate relief granted, is aggrieved\nby the directions given by the Id. CIT(A) in his order suggesting the AO\ninitiate proceedings under Section 147/148 of the Act. The assessee\ntherefore before us by preferring the present Cross-Objection to challenge\nthe directions