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)

Sections 147/148 of the Act and those powers are saved”. 32 ITA No. 301 and others /JP/2025 & CO No. 2 and others-JP-2025 DCIT vs. Vaibhav Banka and others 40. It thus becomes apparent that the liberty which the Supreme Court accorded and the limited right inhering in the Revenue to initiate reassessment

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)

Sections 147/148 of the Act and those powers are saved”. 32 ITA No. 301 and others /JP/2025 & CO No. 2 and others-JP-2025 DCIT vs. Vaibhav Banka and others 40. It thus becomes apparent that the liberty which the Supreme Court accorded and the limited right inhering in the Revenue to initiate reassessment

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)

sections 147 and 40 Shri Vimal Chand Surana HUF 148 of the Act. The ITAT held the notice issued under sec. 148 and proceedings under sec. 147 as illegal and void ab initio. It was held that Assessing Officer having not followed procedure under sec. 153C, 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.”

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

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

In the result, the appeal of the assessee is allowed

40,720/- liable to be taxed u/s 115BBE. The appellant further contented that Amendment to section 115BBE(2) made from Assessment Year 2017-18 restricts the set off of loss but there is no restriction on set off unabsorbed depreciation. Set off of Unabsorbed depreciation is on a different footing vis-a-vis Unabsorbed Loss. 10.2 Section 115BBE is inserted

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4, JAIPUR, JAIPUR vs. VIMAL PARWAL, JAIPUR

In the result , the appeal for the Assessment Year 2016-17 filed by the Revenue and the Cross-Objection filed by the assessee for the same assessment year are also dismissed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

reassesses the ‘total income’. It is not obligatory on the AO to make assessment for all the years, the earlier orders passed may be accepted. But once there is incriminating material seized or requisitioned belonging or relatable to the person other than on whom search was conducted, Section 153C is to be resorted to. 40

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4, JAIPUR, JAIPUR vs. VIMAL PARWAL, JAIPUR

In the result , the appeal for the Assessment Year 2016-17 filed by the Revenue and the Cross-Objection filed by the assessee for the same assessment year are also dismissed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

reassesses the ‘total income’. It is not obligatory on the AO to make assessment for all the years, the earlier orders passed may be accepted. But once there is incriminating material seized or requisitioned belonging or relatable to the person other than on whom search was conducted, Section 153C is to be resorted to. 40

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

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, INCOME TAX OFFICE vs. SUPREME POLYMERS PRIVATE LIMITED, JAIPUR

In the results the appeal of the

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं. / ITA No. 189/JP/2025 निर्धारण वर्ष / Assessment Year : 2015-16 DCIT, Central Circle-03, Jaipur बनाम Vs. Supreme Polymers Pvt. Ltd. 137-138, Industrial Area, Jhotwara, Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AACCS 5773 P अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by: Shri Gaurav Nahata, CA राजस्व की ओर से / Revenue by : Mrs. Anita Rinesh, JCIT, Sr. DR सुनवाई की ता

reassessment under Sections 139, 147, 148, 149, 151 8 153. ………………….. 30. The argument that by enactment of Section 153A to 153D has not eclipsed Section 148 does not enhance the case of respondent to initiate the proceedings under Section 148. On fulfillment of two conditions for invoking Section 153C the proceeding in accordance with Section 153A are to be initiated

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)

reassessment u/s 147 of the Act was not valid and the same is quashed. The appeal on Ground No 1 to 1.3 are thus allowed. 1. In view of the above decision on Ground No 1 to 1.3, appeal on Ground No 2 to 2.4, 3, 4 and 5 have become infructuous and no further adjudication is required on merits

M/S HANUMAN TUBE WELL CO.,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3, JAIPUR

In the result, the appeal of the assessee is allowed

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

section 40(b) - He, therefore, made reassessment restricting allowance of deduction under section 40(b) by excluding interest earned on bank

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

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

SHRI SATISH CHANDRA KATTA,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR

reassessment\nproceedings. The assessee is also directed to cooperate fully during the\nproceedings.\nSATISH CHAND KATTA for ITA No. 439/JPR/2018 (AY 2013-14)\nGROUND NO. 1\n48. During the course of the hearing before us, the ld. AR of the assessee stated\nat the bar that he did not wish to press Ground No. 1. Accordingly, Ground

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4, JAIPUR, JAIPUR vs. KAILASH CHAND HIRAWAT , JAIPUR

Appeal is hereby dismissed as having become infructuous

Bench: SHRI GAGAN GOYAL, AM& SHRI NARINDER KUMAR, JM आयकर अपील सं./ITA No. 1175/JPR/2024 निर्धारण वर्ष / Assessment Year: 2011-12 Deputy Commissioner of Income Tax, बनाम Sh. Kailash Chand Hirawat Central Circle-4, VS. 9, Narain Singh Road, Jaipur. Jaipur. अपीलार्थी / Appellant प्रत्यर्थी / Respondent स्थायीलेखा सं./ जीआईआर सं./PAN/GIR No.: AAKPH9224R निर्धारिती की ओरसे / Assesseeby : Shri Rohan Sogani, C.A. राजस्व की ओरसे / Revenue by: Shri Arvind Kumar, CIT-DR, Mrs. Anita Rinesh, JCIT-DR सुनवाई क

reassesses the 'total income'. It is not obligatory on the AO to make assessment for all the years, the earlier orders passed may be accepted. But once there is incriminating material seized or requisitioned belonging or relatable to the person other than on whom search was conducted, Section 153C is to be resorted to. 40

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)

section 151 of the Act. The issue of approval would still be liable to be answered based on whether the reassessment was commenced after or within a period of four years from the end of the relevant assessment year or as per the amended regime dependent upon whether action was being proposed within three years

M/S AMRAPALI EXPORTS,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2, JAIPUR

In the result, the ground No

reassessment order u/s 143(3) read with 147 was passed by the Assessing Officer on 13.12.2017 wherein the assessee was found eligible for deduction u/s 10AA to the extent of Rs. 7,21,35,825/- as originally 3 M/s Amrapali Exports, Jaipur Vs. DCIT, Jaipur assessed u/s 143(3) of the Act. However, books of accounts were rejected

JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-4, JAIPUR, JAIPUR vs. ASHOK PARWAL, JAIPUR

In the result, the appeal of the revenue is dismissed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं./ITA No. 53/JP/2025 निर्धारण वर्ष / Assessment Year : 2015-16 Joint Commissioner of Income Tax (OSD), Circle-04, Jaipur बनाम Vs. Ashok Parwal M-57, Mahesh Colony, Tonk Phatak, Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: ACJPO7256L अपीलार्थी / Appellant प्रत्यर्थी / Respondent निधारिती की ओर से / Assessee by: Sh. Vedant Agarwal, Adv. राजस्व की ओर से / Revenue by : Sh. Ajey Malik, CIT (th. V.C.) सुनवाई क

reassesses the total income. It is not obligatory on the AO to make assessment for all the years, the earlier orders passed may be accepted. But once there is incriminating material seized or requisitioned belonging or relatable to the person other than on whom search was conducted, Section 153C is to be resorted to ………………. 40

SIYARAM EXPORTS INDIA PVT. LTD.,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR

reassessment proceedings being illegal,\nwithout any basis and contrary to principles of natural justice.\n\n6. In the facts and circumstances of the case and in law, ld. CIT(A) has erred in, confirming the\naction of the ld. AO, in rejecting the books of accounts by invoking the provisions of section\n145(3). The action