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19 results for “reassessment”+ Section 546clear

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Key Topics

Section 26328Section 143(3)26Section 14723Section 14818Addition to Income10Section 80I6Section 153C6Reopening of Assessment5Section 13(3)4

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

In the result, the appeal of the assessee is allowed

ITA 578/JPR/2025[2017-18]Status: DisposedITAT Jaipur11 Aug 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Tarun Mittal, CAFor Respondent: Sh. Gorav Avasthi, JCIT
Section 144BSection 147Section 148Section 148ASection 151ASection 69A

reassessment proceedings were initiated by jurisdictional Assessing Officer and not by Faceless Assessing Officer as required under section 151A, such proceedings were to be quashed. Paras Mahendra Shah v. Union of India [2024] 165 taxmann.com 546

Section 69A4
Reassessment4
Revision u/s 2634

SH. MUKUT BEHARI AGARWAL,JAIPUR vs. THE DCIT, CIRCLE 1, JAIPUR

In the result, the appeals of the assessee is allowed as indicated hereinabove

ITA 1067/JPR/2024[2015-2016]Status: DisposedITAT Jaipur28 Nov 2024AY 2015-2016

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

For Appellant: Shri Tarun Mittal, CAFor Respondent: Ms. Alka Gautam CIT-DR
Section 143(3)Section 144BSection 147Section 148Section 149Section 69A

reassessment proceedings were initiated by jurisdictional Assessing Officer and not by Faceless Assessing Officer as required under section 151A, such proceedings were to be quashed. 6. Paras Mahendra Shah v. Union of India [2024] 165 taxmann.com 546

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 820/JPR/2025[2019-20]Status: DisposedITAT Jaipur25 Jul 2025AY 2019-20
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 143(3)Section 147

reassessment proceedings were initiated by jurisdictional Assessing\nOfficer and not by Faceless Assessing Officer as required under section 151A,\nsuch proceedings were to be quashed.\nParas Mahendra Shah v. Union of India [2024] 165 taxmann.com 546

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMSSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 817/JPR/2025[2016-17]Status: DisposedITAT Jaipur25 Jul 2025AY 2016-17
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 143(3)Section 147

reassessment proceedings were initiated by jurisdictional Assessing\nOfficer and not by Faceless Assessing Officer as required under section 151A,\nsuch proceedings were to be quashed.\nParas Mahendra Shah v. Union of India [2024] 165 taxmann.com 546

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 819/JPR/2025[2018-19]Status: DisposedITAT Jaipur25 Jul 2025AY 2018-19
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 143(3)Section 147

reassessment proceedings were initiated by jurisdictional Assessing\nOfficer and not by Faceless Assessing Officer as required under section 151A,\nsuch proceedings were to be quashed.\nParas Mahendra Shah v. Union of India [2024] 165 taxmann.com 546

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 818/JPR/2025[2017-18]Status: DisposedITAT Jaipur25 Jul 2025AY 2017-18
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 143(3)Section 147

reassessment proceedings were initiated by jurisdictional Assessing\nOfficer and not by Faceless Assessing Officer as required under section 151A,\nsuch proceedings were to be quashed.\nParas Mahendra Shah v. Union of India [2024] 165 taxmann.com 546

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 816/JPR/2025[2015-16]Status: DisposedITAT Jaipur25 Jul 2025AY 2015-16
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 143(3)Section 147

reassessment proceedings were initiated by jurisdictional Assessing\nOfficer and not by Faceless Assessing Officer as required under section 151A,\nsuch proceedings were to be quashed.\nParas Mahendra Shah v. Union of India [2024] 165 taxmann.com 546

SHIV VEGPRO PRIVATE LIMITED ,KOTA vs. PCIT-UDAIPUR , UDAIPUR

In the result, the appeal filed by the assessee is allowed

ITA 1014/JPR/2024[2017-18]Status: DisposedITAT Jaipur28 Jan 2025AY 2017-18
For Appellant: Shri Mahendra Gargieya, (Adv.) &For Respondent: Mrs. Alka Gautam, (CIT-DR)
Section 147Section 263Section 36(1)(va)Section 43B

section 263(2),\nthe notice issued on 30-4-2009 was barred by limitation.”\n3.4 Chhabra Syncotex (P) Ltd. Vs. Assistant Commissioner Of Income\nTax ITA No. 239/Jp/2018 (DC)\n“If the exercise of revision jurisdiction under s.263 in respect of issues\nwhich formed subject-matter of reassessment after the original\nassessment was reopened, the commencement of the limitation would

DCIT, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. KAMLAPRABHA L/H OF LATE SHRI GOPAL LAL JI GOSWAMI, KOTA

In the result, the appeal of the revenue is dismissed and the Cross objection of the assessee is disposed off in terms of the observation made herein above

ITA 94/JPR/2025[2014]Status: DisposedITAT Jaipur21 Aug 2025

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

For Appellant: Shri Mahendra Gargieya, AdvFor Respondent: Mrs. Alka Gautam, CIT-Sr.DR a
Section 144Section 153C

546, 54GA, therefore, the other issues containing in the incriminating material/seized material are not open for the AO for assessment due to the limited scrutiny. Para 3: Regarding satisfaction note, since the satisfaction note was based on the finding as declared by the assessee on its own in the ITR filed for AY 2012-13. Further, AO only compare

INCOME TAX OFFICER (EXEMPTION), JAIPUR vs. M/S APOLLO ANIMAL MEDICAL GROUP TRUST, JAIPUR

In the result, the grounds of appeal taken by the Revenue are dismissed

ITA 960/JPR/2018[2008-09]Status: DisposedITAT Jaipur22 Jan 2021AY 2008-09
For Appellant: Shri Rajeev Sogani (C.A.) &For Respondent: Smt Runi Pal (Add.CIT) fu/kZkfjrh dh vksj ls@
Section 11Section 12ASection 13(1)(c)Section 13(3)Section 143(3)Section 147Section 148Section 151

Section 151 of the Income Tax Act, 1961. The action of the ld. CIT(A) is illegal, justified, arbitrary and against the fact of the case. Relief may please be granted by quashing the reassessment proceedings being illegal and without jurisdiction.” 4. Briefly the facts of the case are that the assessee appellant is a charitable trust running a veterinary

DCIT, JAIPUR vs. SUMS EXIM PVT. LTD., JAIPUR

In the result , ground no. 2 raised by the revenue is dismissed

ITA 860/JPR/2016[2009-10]Status: DisposedITAT Jaipur24 Apr 2023AY 2009-10

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

For Appellant: Shri B.P. Mundra, CAFor Respondent: Shri Sanjay Dhariwal, CIT
Section 132(4)Section 153C

546/- and of Rs.11,75,84,639/- /- made by AO on account of undisclosed sales and undisclosed investment/ expenditure.’’ M/S. S.M. DEVELOPERS ITA NO. 864/JP/2016 - A.Y. 2009-10 ‘’1. Whether on the facts and in the circumstances of the case the ld. CIT(A) was right in deleting the addition of Rs.5,61,44,663/- made

PROFESSIONAL AUTOMOTIVES PRIVATE LIMITED,JAMMU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 812/JPR/2025[2016-17]Status: DisposedITAT Jaipur23 Jul 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील /ITA Nos.809 to 815/JP/2025 निर्धारण वर्ष /Assessment Years :2013-14 to 2019-20 Professional Automotives Pvt. बनाम ACIT, Ltd. Bahu Plaza, Bahu Plaza, Jammu Vs. Central Circle- 1, and Kashmir Jaipur स्थायी लेखा सं./जी.आई.आर. सं./PAN/GIR No.:AAACP9608E अपीलार्थी/Appellant प्र]त्यर्थी/Respondent निर्धारिती की ओर से / Assessee by :Shri Tarun Mittal, CA राजस्व की ओर से /Revenue by: Shri Ajey Malik, CIT (Th. V.C)

For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)
Section 143(3)Section 37(1)

Section 194 and 200 were challenged. It was noted in P. RatnakarRao and others V. Govt. Of A.P. and others (1996 (5) SCC 359) that the discretion given under Section 200(1) to the State Government to prescribe maximum rates for compounding the offence is not unguided, uncanalised and arbitrary. It was, inter alia, held as follows: ……………….. ………………. It is indisputable

NARESH KUMAR ARORA,JAIPUR vs. DCIT, CIRCLE-6, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 259/JPR/2022[2013-14]Status: DisposedITAT Jaipur21 Sept 2022AY 2013-14
For Appellant: Shri C.L. Yadav, CA shri Rajendra Sisodia,AdvFor Respondent: Shri Sanajy Dhariwal, CIT-DR
Section 10(38)Section 143(3)Section 147Section 148Section 68Section 69C

reassessment for the verification and particularly when the issue has already been examined in the original assessment u/s 143(3) of the Act. Hence, it appears that impugned reopening proceedings were on the borrowed satisfaction and assumption of the jurisdiction 16 NARESH KUMAR ARORA VS DCIT , CIRCLE-6, JAIPUR to reopen the assessment

SMT. MALTI KHANDELWAL,JAIPUR vs. INCOME TAX OFFICER, WARD-4-2, JAIPUR

In the result, the ground is disposed off in light of aforesaid directions

ITA 1046/JPR/2019[2013-14]Status: DisposedITAT Jaipur21 Sept 2020AY 2013-14
For Appellant: Sh. Dileep Shivpuri (Advocate)For Respondent: Ms. Chanchal Meena (Add. CIT)
Section 147Section 148Section 234B

reassessment order was quashed. In the instant case, it is an admitted position that the assessee for the first time applied for the copy of the reasons on 14.11.2019 i.e. after passing of appellate order by ld. CIT(A), Jaipur and the same was provided by the AO to her on 18.12.2019 and therefore, it is crystal clear on facts

LAXMI NARAYAN AGARWAL,JAIPUR vs. PCIT, JAIPUR-2, INCOME TAX DEPARTMENT

In the result, appeal of the assessee is allowed

ITA 296/JPR/2023[2016-17]Status: DisposedITAT Jaipur29 Aug 2023AY 2016-17

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

For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Shri Arvind Kumar (CIT) a
Section 142(1)Section 143(2)Section 143(3)Section 263

section 263 cannot be invoked.’ Hon’ble Bombay High Court in Moil Ltd. Vs. CIT [81 Taxmann.com 420] observed that if a query is raised during the assessment proceedings which was responded to by the assessee, the mere fact that the query was not dealt with in the assessment order then it would not lead to a conclusion that

SHIVAM READYMIX PRIVATE LIMITED,NEEMUCH vs. THE PCIT(CENTRAL), JAIPUR

In the result, the appeal of the assessee is allowed

ITA 412/JPR/2024[2013-14]Status: DisposedITAT Jaipur12 Nov 2024AY 2013-14

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

For Appellant: Shri Tarun Mittal (C.A.)For Respondent: Ms. Alka Gautam (CIT)
Section 143(3)Section 153ASection 153DSection 263Section 69C

section does not visualize a case of substitution of the judgment of the Commissioner for that of the Income-tax Officer, who passed the order unless the decision is held to be erroneous. Cases may be visualized where the Income-tax Officer while making an assessment examines the accounts, makes enquiries, applies his mind to the facts and circumstances

GA INFRA PRIVATE LIMITED ,JAIPUR vs. PCIT, JAIPUR-2

In the result, appeal of the assessee is allowed

ITA 219/JPR/2023[2018-19]Status: DisposedITAT Jaipur14 Jun 2023AY 2018-19

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

For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Shri Shailendra Sharma (CIT) a
Section 142(1)Section 143(2)Section 143(3)Section 263Section 80I

section does not visualize a case of substitution of the judgment of the Commissioner for that of the Income-tax Officer, who passed the order unless the decision is held to be erroneous. Cases may be visualized where the Income-tax Officer while making an assessment examines the accounts, makes enquiries, applies his mind to the facts and circumstances

M/S GVK JAIPUR EXPRESSWAY PRIVATE LIMITED,TELANGANA vs. PCIT 2, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 248/JPR/2023[2018-19]Status: DisposedITAT Jaipur19 Aug 2025AY 2018-19
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Arvind Kumar, CIT-DR
Section 115Section 115JSection 143(3)Section 14ASection 263Section 36(1)(iii)Section 80

section 263 cannot be invoked.'\nHon'ble Bombay High Court in Moil Ltd. Vs. CIT [81 Taxmann.com\n420] observed that if a query is raised during the assessment proceedings\nwhich was responded to by the assessee, the mere fact that the query was\nnot dealt with in the assessment order then it would not lead to a\nconclusion that

DHARMENDRA MEHTA,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-2, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 201/JPR/2022[2012-13]Status: DisposedITAT Jaipur13 Apr 2023AY 2012-13

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

For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Shri Avadhesh Kumar (CIT)
Section 143(3)Section 147Section 148Section 263Section 44A

section does not visualize a case of substitution of the judgment of the Commissioner for that of the Income-tax Officer, who passed the order unless the decision is held to be erroneous. Cases may be visualized where the Income-tax Officer while making an assessment examines the accounts, makes enquiries, applies his mind to the facts and circumstances