SHRI SHRAVAN CHOUDHARY,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5, JAIPUR

In the result, appeal of the assessee is allowed

Bench: The Date Of Hearing.”

deemed dividend u/s 2(22)(e) of the Act. 3. The appellant craves leave to add, alter, modify or amend any ground on or before the date of hearing.” Ground No. 1 and 1.1 are regarding validity of initiation of reassessment proceedings under section 147/148 of the IT Act. 2. The ld. Counsel for the assessee has challenged the initiation

SHRI VIKRAM SUKHANI,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-7, JAIPUR

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

deemed dividend U/s 2(22)(e) of the Act. The AO completed the reassessment U/s 147 r.w.s. 143(3) of the act by making

DEPUTY COMMISSIONER OF INCOME TAX , JAIPUR vs. BHARAT SPUN PIPE AND CONSTRUCTION COMPANY, JAIPUR

In the result the appeal of the revenue in ITA no

dividend, the liability to pay tax\nthereon could have only been foisted upon the company which had declared,\ndistributed or paid the same. That in the facts of the present case and even if the\nallegation laid by the respondents were to be accepted would have been GIPL.\n\n15. We also note that the issues emanating from the order

SYLVAN GREENS PRIVATE LIMITED,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 6, JAIPUR

In the result, the appeal of the assessee is allowed

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

dividend and interest income were available with Assessing officer during original assessment proceedings which was concluded under section 143(3) and, further, department did not bring any material facts which was not disclosed in original return of income, impugned reopening notice after four years was unjustified. 5. The Hon'ble Commissioner of Income tax appeals has further not justified

ASSISTANT COMMISSIONER OF INCOME TAX , CIRCLE-2, JAIPUR vs. M/S. ANGEL INFRASTRUCTURE PRIVATE LIMITED, JAIPUR

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

147. 11 Reasons for the belief that the income Reasons as per annexure page has escaped assessment 1 to 11. In view of the reasons it is requested that necessary approval as laid down under sub-section (2) of Section 151 of the IT Act, 1961 may kindly be accorded. Dated 30-03-2016 (G P Awasthi), Income Tax Officer

M/S ANGEL INFRASTRUCTURE (P) LTD.,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR

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

147. 11 Reasons for the belief that the income Reasons as per annexure page has escaped assessment 1 to 11. In view of the reasons it is requested that necessary approval as laid down under sub-section (2) of Section 151 of the IT Act, 1961 may kindly be accorded. Dated 30-03-2016 (G P Awasthi), Income Tax Officer

LOVELY PROMOTERS PRIVATE LIMITED,KOLKATA vs. ACIT, CENTRAL CIRCLE, AJMER, AJMER

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

Bench: him regarding non mentioning of Document Identification Number (DIN) in the body of the order u/s. 127 of the Act dated 08-09-2021 and various other technical pleas raised in grounds of appeal regarding validity of notice u/s. 148 of the Act, thereby appellate order passed by the CIT(A) is non-speaking order and deserves to be quashed. 4. On the facts and in circumstances of the case and in law, the AO erred in issuing notice u/s. 148 of the Act as it was a search related case u/s. 132 r/w

147 r.w.s. 143(3) of the Act without appreciating true and correct facts of the case and documentary evidences brought on record by the assessee Our submissions:- At the outset, your humble appellant would like to bring your kind attention that notice issued u/s. 148 (PB Page 78)of the Act in our case was Time-barred and passed after

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

deemed dividend, the addition made by the AO is not sustainable in law. He has submitted that assessee filed the original return of income on 29.12.2012. The time limit for service of notice u/s 143(2) for the relevant AY was upto 30.09.2013. No notice was issued to the assessee before this date. Thus, the assessment proceedings for the year

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

deemed dividend, the addition made by the AO is not sustainable in law. He has submitted that assessee filed the original return of income on 29.12.2012. The time limit for service of notice u/s 143(2) for the relevant AY was upto 30.09.2013. No notice was issued to the assessee before this date. Thus, the assessment proceedings for the year

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

deemed dividend, the addition made by the AO is not sustainable in law. He has submitted that assessee filed the original return of income on 29.12.2012. The time limit for service of notice u/s 143(2) for the relevant AY was upto 30.09.2013. No notice was issued to the assessee before this date. Thus, the assessment proceedings for the year

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

deemed dividend, the addition made by the AO is not sustainable in law. He has submitted that assessee filed the original return of income on 29.12.2012. The time limit for service of notice u/s 143(2) for the relevant AY was upto 30.09.2013. No notice was issued to the assessee before this date. Thus, the assessment proceedings for the year

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

deemed dividend, the addition made by the AO is not sustainable in law. He has submitted that assessee filed the original return of income on 29.12.2012. The time limit for service of notice u/s 143(2) for the relevant AY was upto 30.09.2013. No notice was issued to the assessee before this date. Thus, the assessment proceedings for the year

SMT. JAYA PREM BHATIA,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

In the result, the appeal of the assessee for A

deemed dividend, the addition made by the AO is not sustainable in law. He has submitted that assessee filed the original return of income on 20.12.2013. The time limit for service of notice u/s 143(2) for the relevant AY was upto 30.09.2014. No notice was issued to the assessee before this date. Thus, the assessment proceedings for the year

SMT. JAYA PREM BHATIA,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

In the result, the appeal of the assessee for A

deemed dividend, the addition made by the AO is not sustainable in law. He has submitted that assessee filed the original return of income on 20.12.2013. The time limit for service of notice u/s 143(2) for the relevant AY was upto 30.09.2014. No notice was issued to the assessee before this date. Thus, the assessment proceedings for the year

ANUSHA FINVEST PVT LTD ,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 1, JAIPUR

In the result, the appeal of the assessee is allowed

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

deemed sufficient. It is crucial that the assessing officer's belief is fair and not based on extraneous or fallacious reasoning. 1.4. Before issuing a notice under Section 148, the assessing officer must apply their reasoning skills to draw conclusions from new or existing information. The term "reason to believe" refers to the belief that prompts the assessing officer

URMILA RAJENDRA MUNDRA,AJMER vs. INCOME TAX OFFICER, WARD-2(2), AJMER, AJMER

In the result grounds raised by the assessee is allowed

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

u/s. 142(1) of the Act dated 20.07.2023 submitted vide point no. 14 that deduction of interest was claimed on borrowing from IDFC first bank and PNB housing and the statement of the loan was submitted. Thus, the claim of the assessee was supported by the evidence. It was the decision of the assessee not to challenge the disallowance even

DCIT, JAIPUR vs. GVK JAIPUR EXPRESSWAY PVT LTD, JAIPUR

In the result, the appeal of the revenue for the years [A

deemed\nincome u/s 115JB by making adjustment as per explanation 1(f) of\nsection 115JB(2), as per the AO.\n\n5.\nThe ld. CIT(A) has considered the issue in detail and after\nexamination of various facts and issues under consideration and by giving\ndetailed reasoning, the ld. CIT(A) has deleted the disallowance made u/s\n14A mainly

DCIT, JAIPUR vs. GVK JAIPUR EXPRESSWAY PVT LTD, JAIPUR

In the result, the appeal of the revenue for the years [A

deemed\nincome u/s 115JB by making adjustment as per explanation 1(f) of\nsection 115JB(2), as per the AO.\n\n5. The ld. CIT(A) has considered the issue in detail and after\nexamination of various facts and issues under consideration and by giving\ndetailed reasoning, the ld. CIT(A) has deleted the disallowance made u/s\n14A mainly

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

reassess the same. Since the assessment under section 153A of the Act is linked with search and requisition under sections 132 and 132A of the Act, it is evident that the object of the section is to bring to tax the undisclosed income which is found during the course of or pursuant to the search or requisition. However, instead