DCIT, CIRCLE-4, JAIPUR vs. M/S KANDOI METAL POWDERS MANUFACTURING COMPANY PVT. LTD., JAIPUR

In the result, both the appeals are partly allowed

147 TTJ 308 (Del.) (Trib.) The assessee while furnishing necessary information regarding the transactions and the aforesaid parties like purchase bills issued against goods purchased, sales- tax registration numbers of the parties, PANs, their confirmations and Bank statements showing the debit of the amount paid through Account payee Cheques to them in the account of assessee and credited

PINCITY JEWLHOUSE PVT. LTD.,JAIPUR vs. PCIT, CC, JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

Bench: the date of hearing." 3. At the outset of hearing, the Bench observed that there is delay of 58 days in filing of the present appeal by the assessee for which the Id. AR of 3

Bogus Purchase and ESI/PF 2014-2015 Claiming Deduction Deduction allowed SCN: 244-247 [PBII] (Reassessment) U/s 10AA by dividing Reply: 248-251 [PBII] AO: 17.12.18 expenses at Order: 122-139 [PBII] proportionate basis 2015-2016 Claiming Deduction Deduction allowed Notice: 252-255[PBII] (Reassessment) U/s 10AA by dividing Reply: 256-259 [PBII] AO: 17.12.18 expenses at Order

RMS KARAMCHARI BACHAT AND SAKH SAHAKARI SAMITI LIMITED JAIPUR,JAIPUR vs. ITO WARD-1(2), JAIPUR, JAIPUR

In the result, the appeals of the assessee are allowed

purchaser, etc has been stated, therefore, the\nquestion that has been raised before us is about the tangible nature of such\ninformation and material in possession of the AO and the nexus thereof with\nformation of belief that the income has escaped assessment. It has been contended\nby the ld AR that the information so referred in the reasons recorded

RMS KARAMCHARI BACHAT AND SAKH SAHAKARI SAMITI LIMITED JAIPUR,JAIPUR vs. ITO WARD-1(2), JAIPUR, JAIPUR

In the result, the appeals of the assessee are allowed

purchaser, etc has been stated, therefore, the\nquestion that has been raised before us is about the tangible nature of such\ninformation and material in possession of the AO and the nexus thereof with\nformation of belief that the income has escaped assessment. It has been contended\nby the ld AR that the information so referred in the reasons recorded

RMS KARAMCHARI BACHAT AND SAKH SAHAKARI SAMITI LIMITED JAIPUR,JAIPUR vs. ITO, WARD-1(2), JAIPUR, JAIPUR

In the result, the appeals of the assessee are allowed

purchaser, etc has been stated, therefore, the\nquestion that has been raised before us is about the tangible nature of such\ninformation and material in possession of the AO and the nexus thereof with\nformation of belief that the income has escaped assessment. It has been contended\nby the ld AR that the information so referred in the reasons recorded

RMS KARAMCHARI BACHAT AND SAKH SAHAKARI SAMITI LIMITED JAIPUR,JAIPUR vs. ITO WARD-1(2), JAIPUR, JAIPUR

In the result, the appeals of the assessee are allowed

purchaser, etc has been stated, therefore, the\nquestion that has been raised before us is about the tangible nature of such\ninformation and material in possession of the AO and the nexus thereof with\nformation of belief that the income has escaped assessment. It has been contended\nby the ld AR that the information so referred in the reasons recorded

M/S. SILVEX & COMPANY INDIA LTD.,JAIPUR vs. ITO WARD-7(4), JAIPUR

In the result, the appeal of the assessee is allowed and cross appeal of the Revenue is dismissed

u/s 147/148 was legal and valid.” During the course of assessment proceedings also Ld. AO has failed to bring on record any corroborative evidence except the so called information gathered from the Investigation Wing, for supporting the allegation that the assessee had made alleged bogus purchases from the companies i.e. M/s Atharv Business (P) Ltd., M/s Casper Enterprises

ITO WARD-7(2), JAIPUR, WARD-7(2), JAIPUR vs. M/S. SILVEX & COMPANY G-1/35 TO 37, 47, 48 EPIP, JEWELLERY ZONE, SITAPURA INDUSTRIAL AREA, JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed and cross appeal of the Revenue is dismissed

u/s 147/148 was legal and valid.” During the course of assessment proceedings also Ld. AO has failed to bring on record any corroborative evidence except the so called information gathered from the Investigation Wing, for supporting the allegation that the assessee had made alleged bogus purchases from the companies i.e. M/s Atharv Business (P) Ltd., M/s Casper Enterprises

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4, JAIPUR, JAIPUR vs. SUNDER DAS SONKIYA, JAIPUR

In the result, both appeals of the revenue are dismissed

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

u/s 143 (3) / 147 was completed 19 DCIT vs. Sunder Das Sonkiya by Ld. A.O. at an income of Rs. 43,57,610/- by taking total income at 24,000/- as per return filed and by disallowing 25% of said purchases of Rs. 1,73,34,424/- amounting to Rs. 43,33,606/- holding them as ingenuine purchases and added

SHRI KHANDELWAL DIAMONDS PRIVATE LIMITED,JAIPUR vs. ACIT, CIRCLE 1, JAIPUR, JAIPUR

In the result, appeal of the assessee is partly allowed

Bench: Him On The Reason Of Issuing Notice U/S 148 On Borrowed Satisfaction Of Another Wing Of The Department.

bogus purchases is wrong and unjustified. The appellant has enclosed copies of its Balance Sheet and Profit & Loss Account for the year under consideration for your kind verification (APB 38-39). Ground No. 2 : That the ld. CIT (A) has erred seriously in law and on facts in sustaining the validity of notice issued by ld. AO u/s

INCOME TAX OFFICER, JAIPUR vs. KEDIA BUILDERS AND COLONIZERS PRIVATE LIMITED, JAIPUR

In the result, all appeals of the revenue are stands dismissed

reassessment u/s 147 of the Act ignoring that the\nreason to belief of the AO is founded on information which has been received by\nthe AO after completion of assessment, which is a sound foundation for\nexercising power u/s 147 r.w.s 148?\n2.3 In ITA No. 874/JP/2024 the revenue has raised the following grounds;\n1 Whether on the facts

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4, JAIPUR, JAIPUR vs. SUNDER DAS SONKIYA, JAIPUR

In the result, both appeals of the revenue are dismissed

Bench: Moving Towards The Facts Of The Case We Would Like To Mention That The Revenue Has Assailed The Appeal In Ita No.453/Jp/2024 On The Following Grounds; “(I) Whether On The Facts & In The Circumstances Of The Case, The Ld. Cit(A) Is Justified In Deleting The Addition Of Rs.43,33,606/- Without Appreciating The Fact That Assessee Has Shown Bogus Purchase Of Rs 1,73,34,424/- During The Year From A Bogus Concern. 3

bogus purchase bills from the above entry providers. In the list supplied by the DCIT, CC-4, Surat name of the assessee Shri Sunder Das Sonkia (Prop. M/s S. Naveen Jewellers) also find place who had obtained purchase bills amounting to Rs. 1,73,34,424/- from M/s Aadi Impex (Prop. Anoop Jain), M/s Arihant Exports (Prop. Shri Sachin Pareek

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 ignoring that the reason to belief of the AO is founded on information which has been received by the AO after completion of assessment, which is a sound foundation for exercising power u/s 147 r.w.s 148? 2.3 In ITA No. 874/JP/2024 the revenue has raised the following grounds; 1 Whether on the facts

INCOME TAX OFFICER, JAIPUR vs. KEDIA BUILDERS AND COLONIZERS PRIVATE LIMITED, JAIPUR

In the result, all appeals of the revenue are stands dismissed

reassessment u/s 147 of the Act ignoring that the\nreason to belief of the AO is founded on information which has been received by\nthe AO after completion of assessment, which is a sound foundation for\nexercising power u/s 147 r.w.s 148?\n\n2.3 In ITA No. 874/JP/2024 the revenue has raised the following grounds;\n\n1 Whether

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)

Bogus purchase) - Certain portion of purchases made by assessee was disallowed - Commissioner (Appeals) found that entire disallowance was based on third party information gathered by Investigation Wing of Department, which had not been independently subjected to further verification by Assessing Officer and he had not provided copy of such statements to appellant, thus, denying opportunity of cross examination to appellant

INCOME TAX OFFICER, JAIPUR vs. KEDIA BUILDERS AND COLONIZERS PRIVATE LIMITED, JAIPUR

reassessment u/s 147 of the Act ignoring that the\nreason to belief of the AO is founded on information which has been received by\nthe AO after completion of assessment, which is a sound foundation for\nexercising power u/s 147 r.w.s 148?\n2.3 In ITA No. 874/JP/2024 the revenue has raised the following grounds;\n1 Whether on the facts

INCOME TAX OFFICER WARD-1(1), JAIPUR vs. KIRAN INFRA ISPAT LIMITED, JAIPUR

reassessment\nproceedings completed on the basis of notice issued u/s 148 is beyond the time\nlimit stipulated u/s 149, is not in accordance with law and consequent order\npassed deserves to be held void ab initio.\n1.2 That, the ld. CIT(A) has further erred in holding the proceedings u/s 148 as\nvalid when the notice issued is itself

M/S G.B. IMPEX ,JAIPUR vs. INCOME TAX OFFICER, WARD-5-3, JAIPUR

In the result, both the appeals of the assessee are allowed

bogus transaction and finally made an addition of 25% of such purchases. Therefore, the Assessing Officer has estimated the income of the assessee in the reassessment order passed U/s 143(3) read with Section 147