ZUBERI ENGINEERING COMPANY,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2, JAIPUR

In the result, all the three appeals of the assessee are partly allowed and that of revenue’s cross appeal is dismissed

Section 148(2), then the entire assessment is open for the AO to bring to tax any item of escaped income which comes to his notice in such reassessment. 40

ZUBERI ENGINEERING COMPANY,JAIPUR vs. DCIT, JAIPUR

In the result, all the three appeals of the assessee are partly allowed and that of revenue’s cross appeal is dismissed

Section 148(2), then the entire assessment is open for the AO to bring to tax any item of escaped income which comes to his notice in such reassessment. 40

ZUBERI ENGINEERING COMPANY,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2, JAIPUR

In the result, all the three appeals of the assessee are partly allowed and that of revenue’s cross appeal is dismissed

Section 148(2), then the entire assessment is open for the AO to bring to tax any item of escaped income which comes to his notice in such reassessment. 40

DCIT, JAIPUR vs. VIMAL CHAND SURANA HUF, JAIPUR

In the result, the appeal of the revenue stands dismissed

reassessment cannot be faulted as the same was based on information derived from the tax audit report. The tax audit report had already been submitted by the assessee. It is one thing to say that the Assessing Officer had received information from an audit report which was not before the Income- tax Officer, but it is another thing

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

40,000/- made by the AO u/s 68 of the IT Act on account of unexplained unsecured loans allegedly obtained by the assessee from M/s. Birla Arts Pvt. Ltd., M/s. Teac Consultant Pvt. Ltd. and M/s. Sangam Distributors Pvt. Ltd. 2. Whether on the facts and circumstances of the case and in law, the CIT (A) was justified in deleting

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

40,000/- made by the AO u/s 68 of the IT Act on account of unexplained unsecured loans allegedly obtained by the assessee from M/s. Birla Arts Pvt. Ltd., M/s. Teac Consultant Pvt. Ltd. and M/s. Sangam Distributors Pvt. Ltd. 2. Whether on the facts and circumstances of the case and in law, the CIT (A) was justified in deleting

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

40,000/- made by the AO u/s 68 of the IT Act on account of unexplained unsecured loans allegedly obtained by the assessee from M/s. Birla Arts Pvt. Ltd., M/s. Teac Consultant Pvt. Ltd. and M/s. Sangam Distributors Pvt. Ltd. 2. Whether on the facts and circumstances of the case and in law, the CIT (A) was justified in deleting

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

40,000/- made by the AO u/s 68 of the IT Act on account of unexplained unsecured loans allegedly obtained by the assessee from M/s. Birla Arts Pvt. Ltd., M/s. Teac Consultant Pvt. Ltd. and M/s. Sangam Distributors Pvt. Ltd. 2. Whether on the facts and circumstances of the case and in law, the CIT (A) was justified in deleting

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

section 153A of the Act. Thus the said judgment is inapplicable under the facts of the present case. Another judgment cited by ld. D/R is in the case of Harshvardhan Johari vs. DCIT (2020) 118 taxmann.com 449 (Jaipur-Trib) wherein it was held that the notice under section 143(2) of the Act was not issued though the time

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 148 & 147/148 - Held, yes - Whether therefore, where basis for initiation of section 148 proceedings in case of assessee was material seized relating to or belonging to assessee during search conducted on ‘M’ Group, notices issued under section 148 and impugned orders rejecting objections filed to issuance of notice were to be quashed and set aside - Held

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

reassess' to completed assessment proceedings. vi. Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under Section 153A merges into one. Only one assessment shall be made separately for each AY on the basis of the findings of the search and any other material existing or brought on the record

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

reassess' to completed assessment proceedings. vi. Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under Section 153A merges into one. Only one assessment shall be made separately for each AY on the basis of the findings of the search and any other material existing or brought on the record

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

reassess' to completed assessment proceedings. vi. Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under Section 153A merges into one. Only one assessment shall be made separately for each AY on the basis of the findings of the search and any other material existing or brought on the record

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

reassess' to completed assessment proceedings. vi. Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under Section 153A merges into one. Only one assessment shall be made separately for each AY on the basis of the findings of the search and any other material existing or brought on the record

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

reassess' to completed assessment proceedings. vi. Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under Section 153A merges into one. Only one assessment shall be made separately for each AY on the basis of the findings of the search and any other material existing or brought on the record

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, 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

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

In the result, appeal of the assessee is allowed

reassessment is essentially the incriminating material disclosing undisclosed income which was not disclosed by the assessee. In the case in hand, the AO himself has not claimed any incriminating material found during the search and seizure in the case of the assessee. Accordingly, in the facts and circumstances of the case and in view of the binding precedents on this