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)

Section 147/148 of the Act, relying on the same judgment of Abhisar Buildwell (supra), CBDT Instruction No. 1/2023 (CLC 35-40), and the provisions of Section 150 of the Act. The assessee, while supporting the ultimate relief granted, is aggrieved by the directions given by the ld. CIT(A) in his order suggesting the AO initiate proceedings under Section 147/148

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)

Section 147/148 of the Act, relying on the same judgment of Abhisar Buildwell (supra), CBDT Instruction No. 1/2023 (CLC 35-40), and the provisions of Section 150 of the Act. The assessee, while supporting the ultimate relief granted, is aggrieved by the directions given by the ld. CIT(A) in his order suggesting the AO initiate proceedings under Section 147/148

DCIT, CC-2, JAIPUR vs. M/S. ROYAL JEWELLERS, JAIPUR

In the result, appeals of the revenue stands dismissed

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

reassessments contemplated under section 153A. There is also no requirement under section 153A and other provisions requiring the Department to collect information and evidence for each and every year for six previous years under section 153A. Therefore, the argument of assessee that the information gathered either during pre-search enquiry or during the course of search cannot be made

DCIT, CC-2, JAIPUR vs. M/S. ROYAL JEWELLERS, JAIPUR

In the result, appeals of the revenue stands dismissed

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

reassessments contemplated under section 153A. There is also no requirement under section 153A and other provisions requiring the Department to collect information and evidence for each and every year for six previous years under section 153A. Therefore, the argument of assessee that the information gathered either during pre-search enquiry or during the course of search cannot be made

DCIT, CC-2, JAIPUR vs. M/S. ROYAL JEWELLERS, JAIPUR

In the result, appeals of the revenue stands dismissed

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

reassessments contemplated under section 153A. There is also no requirement under section 153A and other provisions requiring the Department to collect information and evidence for each and every year for six previous years under section 153A. Therefore, the argument of assessee that the information gathered either during pre-search enquiry or during the course of search cannot be made

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SUBHASH CHANDRA BANKA, JAIPUR

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

Section 147/148 of the Act. The assessee\ntherefore before us by preferring the present Cross-Objection to challenge\nthe directions and to raise other legal and factual grounds in support of the\ndeletion of the addition. Record reveals that Id. CIT(A) vide page 36 while\ndealing with the appeal of the assessee has issued direction

DCIT, CENTRAL CIRCLE-1, JAIPUR , JAIPUR vs. USHA BANKA, SIKAR

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

reassessment matters nor vests any such power in the Id.\nCIT(A). Even other wise the Instruction cannot substitute the independent\nstatutory preconditions under Sections 147/148 read with Section 149,\nwhich provides the timelines for issuance of notice of reopening. Provision\nof such section must be satisfied by the Id. AO at any given point of time,\nwhen the jurisdiction

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. PRIYA DEWAN, SIKAR

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

reassessment matters nor vests any such power in the Id.\nCIT(A). Even other wise the Instruction cannot substitute the independent\nstatutory preconditions under Sections 147/148 read with Section 149,\nwhich provides the timelines for issuance of notice of reopening. Provision\nof such section must be satisfied by the Id. AO at any given point of time,\nwhen the jurisdiction

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. VIPUL BANKA, SIKAR

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

reassessment matters nor vests any such power in the Id.\nCIT(A). Even other wise the Instruction cannot substitute the independent\nstatutory preconditions under Sections 147/148 read with Section 149,\nwhich provides the timelines for issuance of notice of reopening. Provision\nof such section must be satisfied by the Id. AO at any given point of time,\nwhen the jurisdiction

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. PRIYA DEWAN, SIKAR

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

reassessment matters nor vests any such power in the Id.\nCIT(A). Even other wise the Instruction cannot substitute the independent\nstatutory preconditions under Sections 147/148 read with Section 149,\nwhich provides the timelines for issuance of notice of reopening. Provision\nof such section must be satisfied by the Id. AO at any given point of time,\nwhen the jurisdiction

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. USHA BANKA, SIKAR

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

reassessment matters nor vests any such power in the Id.\nCIT(A). Even other wise the Instruction cannot substitute the independent\nstatutory preconditions under Sections 147/148 read with Section 149,\nwhich provides the timelines for issuance of notice of reopening. Provision\nof such section must be satisfied by the Id. AO at any given point of time,\nwhen the jurisdiction

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SUBHASH CHANDRA BANKA, SIKAR

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

reassessment matters nor vests any such power in the Id.\nCIT(A). Even other wise the Instruction cannot substitute the independent\nstatutory preconditions under Sections 147/148 read with Section 149,\nwhich provides the timelines for issuance of notice of reopening. Provision\nof such section must be satisfied by the Id. AO at any given point of time,\nwhen the jurisdiction

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. TRILOK DEWAN, SIKAR

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

reassessment matters nor vests any such power in the Id.\nCIT(A). Even other wise the Instruction cannot substitute the independent\nstatutory preconditions under Sections 147/148 read with Section 149,\nwhich provides the timelines for issuance of notice of reopening. Provision\nof such section must be satisfied by the Id. AO at any given point of time,\nwhen the jurisdiction

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SNEHLATA AGARWAL, SIKAR

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

reassessment matters nor vests any such power in the Id.\nCIT(A). Even other wise the Instruction cannot substitute the independent\nstatutory preconditions under Sections 147/148 read with Section 149,\nwhich provides the timelines for issuance of notice of reopening. Provision\nof such section must be satisfied by the Id. AO at any given point of time,\nwhen the jurisdiction

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SARITA DEWAN, SIKAR

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

reassessment matters nor vests any such power in the Id.\nCIT(A). Even other wise the Instruction cannot substitute the independent\nstatutory preconditions under Sections 147/148 read with Section 149,\nwhich provides the timelines for issuance of notice of reopening. Provision\nof such section must be satisfied by the Id. AO at any given point of time,\nwhen the jurisdiction

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SARITA DEWAN, SIKAR

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

reassessment matters nor vests any such power in the Id.\nCIT(A). Even other wise the Instruction cannot substitute the independent\nstatutory preconditions under Sections 147/148 read with Section 149,\nwhich provides the timelines for issuance of notice of reopening. Provision\nof such section must be satisfied by the Id. AO at any given point of time,\nwhen the jurisdiction

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. ANIMESH AGARWAL, SIKAR

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

reassessment matters nor vests any such power in the Id.\nCIT(A). Even other wise the Instruction cannot substitute the independent\nstatutory preconditions under Sections 147/148 read with Section 149,\nwhich provides the timelines for issuance of notice of reopening. Provision\nof such section must be satisfied by the Id. AO at any given point of time,\nwhen the jurisdiction

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