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)

1) shall not apply in any case where any such assessment, reassessment or recomputation as is referred to in that sub-section relates to an assessment year in respect of which an assessment, reassessment or re-computation could not have been made at the time the order which was the subject matter of the appeal, reference or revision

RAJ KUMAR JAIN,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE – 2, JAIPUR, JAIPUR

In the result, appeal of the assessee is allowed

reassessment cannot be declared invalid in the penalty proceedings’’. View taken by the Hon’ble Karnataka High Court in the above judgment was indirectly affirmed by the Hon’ble Apex Court, when it dismissed an SLP filed by the Revenue against the judgment in the case of SSA’s Emerald Meadows (supra), specifically observing that there was no merits

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.”

Section 148-A(d) in respect of each of the assesses concerned.” Further, it directed the assessing officers to issue a notice under section 148 of the new regime “after following the procedure as required under Section 148-A.” Although this Court waived off the requirement of obtaining prior approval under Section 148A(a) and Section 148A

GHANSHYAM TAK,NAYA GHAR AJMER vs. DCIT CENTRAL CIRCLE AJMER, JAIPUR ROAD AJMER

In the result, appeal of the assessee is allowed

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

39,309/- as additional income during assessment proceedings and offered the same for taxation and, therefore, the penalty cannot be levied under section 271AAB of the Act. It is pertinent to note that the disclosure of additional income in the statement recorded under section 132(4) itself is not sufficient to levy the penalty under section 271AAB

INCOME TAX OFFICER , SIKAR vs. BHASKAR CHAUHAN, JAIPUR

In the result the appeal of the revenue in ITA no

Bench: Him.

39,881/-) are not disclosed in the audited balance sheet as well as in the ITR, the bank transactions remains unexplained. As per Bank account obtained u/s 133(6) from the Axis Bank, it is noticed that the bank account was opened on 30.08.2016. The total of credit entries is worked

BHASKAR CHOUHAN,JAIPUR vs. INCOME TAX OFFICER, SIKAR

39,881/-) are not disclosed in the audited balance sheet as\nwell as in the ITR, the bank transactions remains unexplained. As\nper Bank account obtained u/s 133(6) from the Axis Bank, it is\nnoticed that the bank account was opened on 30.08.2016. The\ntotal of credit entries is worked out at Rs.13,33,68,090/- for the\nyear

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

In the result, the appeal of the assessee is allowed

reassessment notice. Section 151 of the new regime does not prescribe a time limit within which a specified authority has to grant sanction. Rather, it links up the time limits with the jurisdiction of the authority to grant sanction. Section 151(ii) of the new regime prescribes a higher level of authority if more than three years have elapsed from

VINITA BAJORIA,JAIPUR vs. INCOME-TAX OFFICER, JAIPUR

In the result, the appeal of the assessee is allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकर अपील सं./ITA No. 370/JP/2025 निर्धारण वर्ष / Assessment Year : 2016-17 Vinita Bajoria 1, Ganesh Colony Moti Doongri Road, Jaipur बनाम Income Tax Officer, Ward 5(2), Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AEBPB4873M अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by: Sh. Manoj Choudhary, CA राजस्व की ओर से / Revenue by : Sh. Gorav Avasthi, JCIT सुनवाई की तारीख / Date of Hear

reassessment notice. Section 151 of the new regime does not prescribe a time limit within which a specified authority has to grant sanction. Rather, it links up the time limits with the jurisdiction of the authority to grant sanction. Section 151(ii) of the new regime prescribes a higher level of authority if more than three years have elapsed from

ANSHU SAHAI (HUF), JAIPUR,JAIPUR vs. ACIT, CENTRAL CIRCLE 2, JAIPUR, JAIPUR

39,64,509 26,79,94,750 5,11,79,000 56,31,38,249 \n\nBased on this calculation again the assessee was asked to show cause as \nto why the aforementioned addition should not be made in his hand. The \nassessee submitted his reply which was considered by the ld. AO but was \nnot found tenable

ANSHU SAHAI (HUF),JAIPUR vs. ACIT, CENTRAL CIRCLE, CENTRAL CIRCLE

39,64,509 \n26,79,94,750 \n5,11,79,000 \n56,31,38,249 \nBased on this calculation again the assessee was asked to show cause as \nto why the aforementioned addition should not be made in his hand. The \nassessee submitted his reply which was considered by the ld. AO but was \nnot found tenable. Ld. AO also

ANSHU SAHAI (HUF), JAIPUR,JAIPUR vs. ACIT, CENTRAL CIRCLE 2, JAIPUR, JAIPUR

39,64,509\n26,79,94,750\n5,11,79,000\n56,31,38,249\nBased on this calculation again the assessee was asked to show cause as\nto why the aforementioned addition should not be made in his hand. The\nassessee submitted his reply which was considered by the ld. AO but was\nnot found tenable. Ld. AO also

SHRI MADHO LAL SAINI,JAIPUR vs. ITO, WARD-2(3), JAIPUR

In the result, the appeals of the assessees are allowed

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

Reassessment pursuant to material found in search can be done through recourse to section 153C only and not by invoking the provisions of section 147/148. 1.12. The provisions of section 153C are over-riding in nature and contain non obstante clause for sections 139,147,148,149,151 and 153. 1.13. Section 147 and 153C are not interchangeable

AJAY BAKLIWAL,KOTA vs. ACIT, CENTRAL CIRCLE, KOTA, KOTA

reassessment proceedings initiated under Section 148 be upheld as valid\nand in accordance with the law.\n2. The addition of ₹44,62,938/- under Section 2(22)(e) be upheld, as the\nAppellant has failed to disprove the findings of the AO.\n3.\nThe appeal of the Appellant be dismissed, and the order of the Ld. CIT(A)\nbe upheld

OM KOTHARI FOUNDATION,JAIPUR, RAJASTHAN vs. ITO, (EXEMPTION) WARD-1, JAIPUR, JAIPUR, RAJASTHAN

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

Bench: SHRI SANDEEP GOSAIN (Judicial Member), DR MITHA LAL MEENA (Accountant Member)

reassessment is to be done in two different stages challenging the reasons of reopening and (i) challenging the assessment order. Assessee's challenge to the order of the assessing officer rejecting the objection against the reasons of reopening and assessce's challenge to the assessment order are two separate proceedings. Assessee cannot challenge order of the assessing officer disposing objections

R P WOOD PRODUCTS PRIVATE LIMITED,AJMER vs. DCIT CENTRAL CIRCLE AJMER, JAIPUR ROAD AJMER

In the result, appeal of the assessee is allowed

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

1)(c), i.e., whether it is for concealment of income or for furnishing of incorrect particulars of income. Sending printed form where all the grounds mentioned in section 271 are mentioned would not satisfy the requirement of law ; The assessee should know the grounds which he has to meet specifically. Otherwise, the principles of natural justice are offended

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)

1,30,00,385/-which is chargeable to tax has escaped from assessment within the meaning of 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

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)

reassessing the unabated assessment on the basis of material received from the other sources and can proceed under section 148. The decision does not 39 Sh. Kapil Taneja vs. DCIT support the contentions raised that section 148 is rendered redundant if section 153C is to be resorted to in the facts of the present case. 36. The Single Bench

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, JAIPUR vs. M/S N. M. AGROFOOD PRODUCTS PVT. LTD., SRIGANGANAGAR

In the result the appeal of the revenue is dismissed

Section 143(3) read with Section 153A(1)(b) in determining the total income of the Assessee of Rs. 14.5 crores against declared income of Rs. 3.44 crores. The ITAT deleted the additions on the ground that it was not based on any incriminating material found during the course of the search in respect of AYS under consideration

INCOME TAX OFFICER, WARD-1(2), JAIPUR, JAIPUR vs. MUKESH KUMAR SONI, JAIPUR

In the result appeal of the revenue is dismissed and the cross

Bench: Moving Towards The Facts Of The Case We Would Like To Mention

reassessment under Section 147, 148 & 148A of the Act in a faceless manner. Proceedings under Section 147 and Section 148 of the Act would now have to be taken as per the 34 ITA No. 656/JP/2023 & CO No. 06/JP/2023 ITO vs. Mukesh Kumar Soni procedure legislated by the Parliament in respect of reopening/ re-assessment i.e., proceedings under Section 148A