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.”

section 151(new regime). Consequently, the assessment u/s 147 r.w.s. 144 r.w.s. 144B of the Act dated 24.03.2023, stands quashed. 3.5 Hon’ble ITAT, Mumbai Bench in the case of ACIT v. Surya Ferrous Alloys Pvt. Ltd. [2025] 1 TMI 326 after considering the aforesaidjudgment of Hon’ble Supreme Court in Rajeev Bansal (supra) has held: Validity of reassessment

RSD CONTAINERS PRIVATE LIMITED,JAIPUR vs. ITO, WARD 7(1), JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

1) of the new regime read with TOLA; and (ii) obtain the previous approval of the authority specified under section 151. A notice issued without complying with the preconditions is invalid as it affects the jurisdiction of the assessing officer. Therefore, the reassessment notices issued under section 148 of the new regime, which are in pursuance of the deemed notices

DCIT, CC-2, JAIPUR vs. SHRI VIMAL CHAND SURANA(HUF), JAIPUR

In the result, the appeal of the revenue stands dismissed

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

u/s 153C of the Act. For ready reference we quote section 153C as under:- “ 153C. 79[(1)] 80[Notwithstanding anything contained in section 139, section 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, 81belongs

SHRI MADHO LAL SAINI,JAIPUR vs. ITO, WARD-2(3), JAIPUR

In the result, the appeals of the assessees are allowed

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

u/s 153C of the Act. For ready reference we quote section 153C as under:- “ 153C. 79[(1)] 80[Notwithstanding anything contained in section 139, section 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, 81belongs

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

Section 292B of the IT Act. 1.8.2 Also refer Ghanshyam K. Khabrani v/s ACIT 346 ITR 443(Bom.) and 1.8.3 In the case of CIT V/s SPL’s Siddhartha Ltd 345 ITR 223(Del). Reassessment—Sanction for issue of notice u/s 151(1)—AO issued notice u/s 147

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

Section 292B of the IT Act. 1.8.2 Also refer Ghanshyam K. Khabrani v/s ACIT 346 ITR 443(Bom.) and 1.8.3 In the case of CIT V/s SPL’s Siddhartha Ltd 345 ITR 223(Del). Reassessment—Sanction for issue of notice u/s 151(1)—AO issued notice u/s 147

SUVA LAL PAHARIA,JAIPUR vs. ITO WARD 6(3), JAIPUR

Section 292B of the IT\nAct.\nFurther we noted from the reliance placed by the Ld AR for the assesee in the case\nof CIT V/s SPL's Siddhartha Ltd 345 ITR 223(Del), which is as under :\n\"Reassessment-Sanction for issue of notice u/s 151(1)—AO issued notice u/s 147

KATRATHAL GRAM SEWA SAHKARI SAMITI LIMITED ,KATRATHAL vs. ITO WARD 1 SIKAR, SIKAR

u/s 80P(2)(d)\r\nof the Act. The assessee's claim of deduction under chapter VIA was not\r\nallowable as per the provision of section 80AC of the Act and thereby the\r\nclaim was not allowed by disallowing the same and thereby it is clear that\r\nno addition was made on the issue upon which

INCOME TAX OFFICER , SIKAR vs. BHASKAR CHAUHAN, JAIPUR

In the result the appeal of the revenue in ITA no

Bench: Him.

u/s 153C. The assessments relating to search material are governed by provisions of section 153A/153C. The relevant provisions of section 153A and 153C are quoted below: - Assessment in case of search or requisition. 153A. (1) Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, in the case of a person where

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

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)

1)— Reassessment proceedings were completed—Assessee claimed that the notice u/s 147 was unsustainable because it was not approved by the competent authority in accordance with Section 151

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)

1)— Reassessment proceedings were completed—Assessee claimed that the notice u/s 147 was unsustainable because it was not approved by the competent authority in accordance with Section 151

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

1) of the new regime read with TOLA; and (ii) obtain the previous approval of the authority specified under section 151. A notice issued without complying with the preconditions is invalid as it affects the jurisdiction of the assessing officer. Therefore, the reassessment notices issued under section 148 of the new regime, which are in pursuance of the deemed notices

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

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

u/s 153A cannot be\nsustained and is hereby deleted as the same is without basis of incriminating\nmaterial unearthed during the search action on the appellant and impugned\naddition could have been done by the learned assessing officer in re-assessment\nproceedings by issuance of notice under section 147/148. The Id. AO is directed\nto take necessary action in this

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

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

u/s 153A cannot be sustained\nand is hereby deleted as the same is without basis of incriminating material\nunearthed during the search action on the appellant and impugned addition could\nhave been done by the learned assessing officer in re-assessment proceedings by\nissuance of notice under section 147/148. The Id. AO is directed to take necessary\naction in this

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

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

u/s 153A cannot be sustained\nand is hereby deleted as the same is without basis of incriminating material\nunearthed during the search action on the appellant and impugned addition could\nhave been done by the learned assessing officer in re-assessment proceedings by\nissuance of notice under section 147/148. The Id. AO is directed to take necessary\naction in this

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

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

u/s 153A cannot be sustained\nand is hereby deleted as the same is without basis of incriminating material\nunearthed during the search action on the appellant and impugned addition could\nhave been done by the learned assessing officer in re-assessment proceedings by\nissuance of notice under section 147/148. The Id. AO is directed to take necessary\naction in this

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

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

u/s 153A cannot be sustained\nand is hereby deleted as the same is without basis of incriminating material\nunearthed during the search action on the appellant and impugned addition could\nhave been done by the learned assessing officer in re-assessment proceedings by\nissuance of notice under section 147/148. The Id. AO is directed to take necessary\naction in this

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

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

u/s 153A cannot be\nsustained and is hereby deleted as the same is without basis of incriminating\nmaterial unearthed during the search action on the appellant and impugned addition could\nhave been done by the learned assessing officer in re-assessment proceedings by\nissuance of notice under section 147/148. The Id. AO is directed to take necessary\naction in this