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

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

reassessment order subjected to revision passed on 15.04.2021\nwhereas the Checkmate (Supra) decision came one and a half year later\nthereto i.e. 12.10.2022. Therefore, the CIT could not have found any\nfault in the assessment order or could neither held as the subject\nreassessment as erroneous nor prejudicial to the revenue interest. On\nthis is aspect the law is well

MRS. RENU SEHGAL,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, JAIPUR

In the result, the appeals of the assessee is allowed and that of the

Bench: : Shri Vijay Pal Rao, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 837/Jp/2018 Fu/Kzkj.K O"Kz@Assessment Year : 2012-13 Cuke The Acit Smt. Renu Sehgal Vs. Central Circle-3 27, Onkar Nagar, Civil Lines Jaipur Jaipur Lfkk;H Ys[Kk La-@Thvkbzvkj La-@Pan/Gir No.: Aepps 3048 M Vihykfkhz@Appellant Izr;Fkhz@Respondent Vk;Dj Vihy La-@Ita No. 708 & 709 Jp/2018 Fu/Kzkj.K O"Kz@Assessment Year : 2012-13 & 2015-16 Cuke Mrs. Renu Sehgal The Dcit Vs. 227-278, Nemisagar Colony Central Circle-3, Vaishali Nagar, Jaipur Jaipur Lfkk;H Ys[Kk La-@Thvkbzvkj La-@Pan/Gir No.: Aepps 3048 M Vihykfkhz@Appellant Izr;Fkhz@Respondent Jktlo Dh Vksj Ls@ Revenue By : Shri Varinder Mehta, Cit-Dr Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri P.C. Parwal, Ca Lquokbz Dh Rkjh[K@ Date Of Hearing : 06/08/2019 ?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 19/08/2019 Vkns'K@ Order Per Vijay Pal Rao, Jm There Are Cross Appeals For The Assessment Year 2012-13 Directed Against The Order Dated 09-04-2013 Of The Ld. Cit(A)-4, Jaipur. The 2 Smt. Renu Sehgal Vs Dcit, Central Circle-3, Jaipur

reassessment proceedings. The Supreme Court held that the circular by itself without any other material and investigation, could not afford any basis to the ITO for forming a reasonable belief that the appellant had not made a full and true disclosure of the relevant facts on which account the income of the appellant chargeable to tax had escaped assessment

S.K. THERMOFORMERS,ALWAR vs. ITO, ALWAR

In the result, the appeal of the assessee is dismissed

69B of the Act. It would only amount to fishing inquiry and not investigation under section 142A of the Act. It was opined that, the scheme of the provisions when read 4 M/s. S.K. Thermoformers vs ITO, Ward- 1(5), Jaipur harmoniously would lead to a situation where in case the Assessing Officer, during the pendency of assessment or reassessment

PRABHATI DEVI,DAUSA vs. ITO WARD DAUSA , DAUSA

In the result, appeal of the assessee is allowed

69B, Section 69C or any other provisions of\nthe Act. It is not the case of the Revenue that the Petitioner has paid any cash to the\nso-called accommodation entry provider to obtain the accommodation entry to plough\nback own funds, hence, there is no ground/material to form reasonable belief of any\naccommodation entry. (Refer PCIT Vs. Meenakshi Overseas

PREM LATA PANDYA,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4, , JAIPUR

In the result, the appeal of the assessee is partly allowed

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR, JM आयकर अपील सं. / ITA No. 1471/JPR/2024 निर्धारण वर्ष / Assessment Year :2019-20 Prem Lata Pandya बनाम Deputy Commissioner of 302, Raj Mension, D-299, Vs. Income Tax, Tulsi Marg Bani Park, Central Circle-4, Jaipur. Jaipur अपीलार्थी / Appellant प्रत्यर्थी / Respondent स्थायीलेखा सं./ जीआईआर सं./ PAN/GIR No.:ACXPJ9951A निधर्धारिती की ओरसे / Assessee by : Sh. S.L.Poddar, Adv. राजस्व की ओरसे / Revenue by: Sh. Gautam Singh

69B, section 69C or section 69D, if such income is not covered under clause (a), The income-tax payable shall be the aggregate of- (i)the amount of income-tax calculated on the income referred to in clause (a) and clause (b), at the rate of sixty per cent, and (ii) the amount of income-tax with which the assessee

SUNIL KUMAR GATTANI,JAIPUR vs. THE ASSTT. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 2, JAIPUR

In the result ground no. 7

reassessment is passed\npursuant to a search operation is a mandatory requirement of section 153D and\nthat such approval is not meant to be given mechanically and while elaborate\nreasons need not be given, but there has to be some indication that approving\nauthority has examined draft orders and finds that it meets requirement of law\nHigh Court further held

SANJAY KUMAR KARNANI,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

reassessment cannot be verified. Subject to these observations Shri Ambika Garments vs. ACIT the peak credit as worked out by the assessee at Rs. 36,89,310/- is held as undisclosed income for this year. (iii)………… In the above case the assessment for the AY 2001-02 was done however which was quashed by the honourable Tribunal. Even then

SANJAY KUMAR KARNANI,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

Bench: AO on 12-04-2021 18. Reply filed before AO on 15-07-2021 19. Additional Written Submissions filed before CIT(A) for AY 2014-15 on 11-11-2024 20. Written Submissions filed before CIT(A) for AY 2014-15 21. Written Submissions filed before CIT(A) for AY 2015-16 on 10-10-2024 22. Written Submissions filed before CIT(A) for AY 2016-17 on 10-10-2024 23. Written Submissions filed before CIT(A) for AY 2017-18 on 15-10-2024 24. Written Submissions filed before CIT(A) for AY 2018-19 on 15-10-2024 25.

reassessment cannot be verified. Subject to these observations Shri Ambika Garments vs. ACIT the peak credit as worked out by the assessee at Rs. 36,89,310/- is held as undisclosed income for this year. (iii)………… In the above case the assessment for the AY 2001-02 was done however which was quashed by the honourable Tribunal. Even then

SHRI AMBICA GARMENTS, JODHPUR,JODHPUR vs. ACIT, CENTAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

reassessment cannot be verified. Subject to these observations Shri Ambika Garments vs. ACIT the peak credit as worked out by the assessee at Rs. 36,89,310/- is held as undisclosed income for this year. (iii)………… In the above case the assessment for the AY 2001-02 was done however which was quashed by the honourable Tribunal. Even then

SHRI AMBICA GARMENTS, JODHPUR,JODHPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

reassessment cannot be verified. Subject to these observations Shri Ambika Garments vs. ACIT the peak credit as worked out by the assessee at Rs. 36,89,310/- is held as undisclosed income for this year. (iii)………… In the above case the assessment for the AY 2001-02 was done however which was quashed by the honourable Tribunal. Even then

SHRI AMBICA GARMENTS, JODHPUR,JODHPUR vs. ACIT, CENTAL CIRCLE-3, JAIPUR, JODHPUR

In the result, all appeals of the assessee are disposed off in terms of

reassessment cannot be verified. Subject to these observations Shri Ambika Garments vs. ACIT the peak credit as worked out by the assessee at Rs. 36,89,310/- is held as undisclosed income for this year. (iii)………… In the above case the assessment for the AY 2001-02 was done however which was quashed by the honourable Tribunal. Even then

SHRI RAJESH CHACHWANI,JAIPUR vs. INCOME TAX OFFICER, WARD-6-4, JAIPUR

In the result, the appeal of the assessee is dismissed

reassessment proceedings. As regards the claim of opening balance of Rs. 3,13,300/-, except the affidavit filed by the assessee no supporting material was produced, even otherwise assessee was not maintaining any books of account and never filed any return of income during the period the saving is claimed, thus the claim of the assessee cannot be accepted

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

reassessment made pursuant to notice under section 153A is not de novo assessment, therefore, there is no merit in the ground to make a new claim of deduction or allowance during assessment/reassessment under section 153A as such where admittedly the regular assessments are shown as completed assessment on the date of initiation of action under section 132." In the above

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

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

reassessment made pursuant to notice under section 153A is not de novo assessment, therefore, there is no merit in the ground to make a new claim of deduction or allowance during assessment/reassessment under section 153A as such where admittedly the regular assessments are shown as completed assessment on the date of initiation of action under section 132." In the above

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं. / ITA Nos.931 to 936/JP/2024 निर्धारण वर्ष / Assessment Years : 2012-13 & 2014-15 to 2018-19 Dheeraj Singh Sisodiya 005, (Nayagaun) Ram Ganmandi, Kota बनाम DCIT, Vill. Beedmandi Vs. Central Circle, Kota स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: APAPS 6392 E अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by : Sh. P. C. Parwal, CA राजस्व की ओर से / Revenue by : Mrs. Alka Gautam,

reassessment made pursuant to notice under section 153A is not de novo assessment, therefore, there is no merit in the ground to make a new claim of deduction or allowance during assessment/reassessment under section 153A as such where admittedly the regular assessments are shown as completed assessment on the date of initiation of action under section 132." In the above

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं. / ITA Nos.931 to 936/JP/2024 निर्धारण वर्ष / Assessment Years : 2012-13 & 2014-15 to 2018-19 Dheeraj Singh Sisodiya 005, (Nayagaun) Ram Ganmandi, Kota बनाम DCIT, Vill. Beedmandi Vs. Central Circle, Kota स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: APAPS 6392 E अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by : Sh. P. C. Parwal, CA राजस्व की ओर से / Revenue by : Mrs. Alka Gautam,

reassessment made pursuant to notice under section 153A is not de novo assessment, therefore, there is no merit in the ground to make a new claim of deduction or allowance during assessment/reassessment under section 153A as such where admittedly the regular assessments are shown as completed assessment on the date of initiation of action under section 132." In the above

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

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

reassessment made pursuant to notice under section 153A is not de novo assessment, therefore, there is no merit in the ground to make a new claim of deduction or allowance during assessment/reassessment under section 153A as such where admittedly the regular assessments are shown as completed assessment on the date of initiation of action under section 132." In the above

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

reassessment made pursuant to notice under section 153A is not de novo assessment, therefore, there is no merit in the ground to make a new claim of deduction or allowance during assessment/reassessment under section 153A as such where admittedly the regular assessments are shown as completed assessment on the date of initiation of action under section 132." In the above