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)

u/s 147 r.w.s 148? Ground No. 1 Whether on the facts and circumstances of the case, the Ld. CIT(A) is justified in quashing the reopening and reassessment under Section 147 of the Act ignoring that the case was reopened as per clause (c) of Explanation 2 to Section 147 and with the Kedia Builders and Colonizers Pvt. Ltd., Jaipur

ASHOK SHARMA,KOTA vs. DY. COMMISSIONER OF INCOME TAX CIRCLE-2 - KOTA, KOTA

section 40A(3). The payments were made at different dates as was replied by the\nassessee alongwith complete details in the reply to notice u/s 154 and also to notice u/s 148 in\nthe proceedings of reassessment. The reply by the assessee was made part of the order u/s 147\nby the ld. AO but was neither touched-upon

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

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

u/s 147\nr.w.s 148?\nGround No. 1\nWhether on the facts and circumstances of the case, the Ld. CIT(A) is justified in\nquashing the reopening and reassessment under Section 147 of the Act ignoring that\nthe case was reopened as per clause (c) of Explanation 2 to Section 147 and with the\n27\nITA No. 872 & others/JP/2024\nKedia Builders

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

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

u/s 147\nr.w.s 148?\n\nGround No. 1\n\nWhether on the facts and circumstances of the case, the Ld. CIT(A) is justified in\nquashing the reopening and reassessment under Section 147 of the Act ignoring that\nthe case was reopened as per clause (c) of Explanation 2 to Section 147 and with the\n\n27\nITA

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

u/s 147\nr.w.s 148?\nGround No. 1\nWhether on the facts and circumstances of the case, the Ld. CIT(A) is justified in\nquashing the reopening and reassessment under Section 147 of the Act ignoring that\nthe case was reopened as per clause (c) of Explanation 2 to Section 147 and with the\napproval of the Principal Commissioner of Income

SAVITA GUPTA,KOTA vs. ITO, DELHI

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

133(6) of the Act was issued which was duly complied by the appellant. 3. The appellant had purchased a residential plot bearing No. E-13, Landmark City, Kota, from Bhatia Colonisers for a total consideration of Rs. 16,20,000/-, as duly recorded in the books of the seller. 4. However, the assessment was subsequently reopened u/s 147

INCOME TAX OFFICER , SIKAR vs. BHASKAR CHAUHAN, JAIPUR

In the result the appeal of the revenue in ITA no

Bench: Him.

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,- (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, A person other than

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

reassessment process invalid in law. The AO's\naction in initiating proceedings u/s 147 is based on conjecture and suspicion, and falls\nfoul of the binding legal principles laid down by the Hon'ble Supreme Court and various\nHigh Courts.\nIn light of the above legal and factual position, it is respectfully submitted that the\nreassessment proceedings-initiated u/s 147

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

reassessment process invalid in law. The AO's\naction in initiating proceedings u/s 147 is based on conjecture and suspicion, and falls\nfoul of the binding legal principles laid down by the Hon'ble Supreme Court and various\nHigh Courts.\n\nIn light of the above legal and factual position, it is respectfully submitted that the\nreassessment proceedings-initiated u/s

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

reassessment process invalid in law. The AO's\naction in initiating proceedings u/s 147 is based on conjecture and suspicion, and falls\nfoul of the binding legal principles laid down by the Hon'ble Supreme Court and various\nHigh Courts.\nIn light of the above legal and factual position, it is respectfully submitted that the\nreassessment proceedings-initiated u/s 147

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

reassessment process invalid in law. The AO's\naction in initiating proceedings u/s 147 is based on conjecture and suspicion, and falls\nfoul of the binding legal principles laid down by the Hon'ble Supreme Court and various\nHigh Courts.\nIn light of the above legal and factual position, it is respectfully submitted that the\nreassessment proceedings-initiated u/s 147

LATE SHRI JITENDRA NAGAR THROUGH HIS L/R SMT. DEEPIKA NAGAR,BARAN vs. INCOME TAX OFFICER WARD BARAN, BARAN

In the result, appeal of the assessee is allowed

Bench: The Date Of Hearing.”

133(6) was called for from the bank. On perusal of the bank account statements, it was found that the assessee deposited cash of Rs. 16,90,000/- in his bank account on 24.11.2015 relevant to A.Y. 2016-17. Therefore, the AO had reason to believe that income amounting to Rs. 16,90,000/- escaped assessment in the hands

J.K.V. STONEX,KISHANGARH vs. INCOME TAX OFFICER, KISHANGARH

In the result, the appeal of the assessee is allowed

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

133(6) on assessee relevant extract of the said reasons is set and lenders as he had out below: ample time to conduct enquiry after completion "In this case Company was of assessment and due incorporated 09.07.2011 and has date initiating proceeding authorized capital Rs. 1,00,000/-. It u/s 148 for the year has not shown any sales/receipts

PRAMILA AGARWAL,JAIPUR vs. THE INCOME TAX OFFICER WARD-2(5), JAIPUR

In the result, the appeal of the assessee is allowed

reassessment\norder so passed deserves to be held bad in law.”\n\n2.2 As regards admission of additional ground so taken by assessee is\nconcerned, the ld. AR of the assessee has submitted that though legal\nground against order passed u/s 147 has been taken requesting it to\nconsider as bad in law, however, for the sake of clarity, additional

VINITA BAJORIA,JAIPUR vs. INCOME-TAX OFFICER, JAIPUR

In the result, the appeal of the assessee is allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकर अपील सं./ITA No. 370/JP/2025 निर्धारण वर्ष / Assessment Year : 2016-17 Vinita Bajoria 1, Ganesh Colony Moti Doongri Road, Jaipur बनाम Income Tax Officer, Ward 5(2), Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AEBPB4873M अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by: Sh. Manoj Choudhary, CA राजस्व की ओर से / Revenue by : Sh. Gorav Avasthi, JCIT सुनवाई की तारीख / Date of Hear

section 147, and • The reassessment order passed u/s 147 r.w.s. 144 be kindly held to be without jurisdiction, bad in law and liable to be quashed. 6. To support the contention so raised in the written submission reliance was placed on the following evidence / records / decisions: S. No. Particulars Page Nos. 1. Synopsis of the Case

KOSHAL KISHOR SHARMA,JAIPUR vs. DCIT(INTL. TAX), JAIPUR, JAIPUR

In the result, appeals of the assessee are allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

133-A was conducted at business premises of Assessee and notice u/s. 148 was issued by ITO at Suratgarh—CIT(A) held that pecuniary or territorial jurisdiction as contemplated u/s. 124 was not applicable as Assessee was filling his return of income with ITO at Chennai—ITAT held that Assessee was regularly filing his returns of income at Chennai

KOSHAL KISHOR SHARMA,JAIPUR vs. DCIT(INTL. TAX.) JAIPUR, JAIPUR

In the result, appeals of the assessee are allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

133-A was conducted at business premises of Assessee and notice u/s. 148 was issued by ITO at Suratgarh—CIT(A) held that pecuniary or territorial jurisdiction as contemplated u/s. 124 was not applicable as Assessee was filling his return of income with ITO at Chennai—ITAT held that Assessee was regularly filing his returns of income at Chennai

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

SHRI SATYA NARAYAN BAIRWA,JAIPUR vs. INCOME TAX OFFICER, WARD-2(4), JAIPUR

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

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 867 & 869/Jp/2018 Fu/Kzkj.K O"Kz@Assessment Years :2008-09 & 2009-10 Cuke Shri Satya Narayan Bairwa, I.T.O., Vs. 97/77, Shipra Path, Ward-2(4), Mansarovar, Jaipur (Raj). Jaipur. Lfkk;H Ys[Kk La-@Thvkbzvkj La-@Pan/Gir No.: Ahppb 0077 J Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri Shravan Kumar Gupta (Adv.) Jktlo Dh Vksj Ls@ Revenue By : Smt. Runi Pal (Addl.Cit) Lquokbz Dh Rkjh[K@ Date Of Hearing : 20/07/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 15/09/2021 Vkns'K@ Order

147 of the Acdt is barred by limitation. The ld AR appearing on behalf of the assessee has reiterated the same arguments as were raised before the ld. CIT(A) and also relied on the written submissions filed before the Bench and the submissions qua the issue under consideration are as under: 6 ITA 867 & 869/JP/2018_ Sh. Satya Narayan Bairwa