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)

sections of 153C of the Act and therefore consequential order passed u/s 147 of the Act is bad in law and deserves to be quashed. 1.4. That, the Ld. CIT(A) has further erred in confirming the action of ld. AO in reopening the assessment, beyond the specified time line. Thus, the reassessment proceedings initiated is time barred and entire

SAVITA GUPTA,KOTA vs. ITO, DELHI

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

reassessment order passed u/s 147 r.w.s. 143(3) is also illegal and void ab- initio and is liable to be quashed.” " ITAT, Jaipur bench in the case of Shri Kalyan Buildmart Pvt. Ltd., ... vs Assistant Commissioner of Income Tax, ITA 152 & 153/JP/2018 dated 28.06.2018, held that: “Following the earlier decision of this Tribunal, we hold that the reopening under section

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)

152 are substantially different from the provisions as they stood prior to such substitution. Under the old provisions of section 147, separate clauses (a) and (b) laid down the circumstances under which income escaping assessment for the past assessment years could be assessed or reassessed. To confer jurisdiction under section 147(a) two conditions were required to be satisfied firstly

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

In the result, the appeal of the assessee is allowed

147, of the Income-tax Act, 1961 - Income escaping\nassessment Issue of notice for (Reassessment) Assessment year 2013-14\nAssessing Officer issued notice under section 148 on basis of information received\nfrom Investigation Wing relating to certain share transactions alleging that sell trades\nexceeded buy trades and assessee was beneficiary of bogus LTCG - Objections raised\nby assessee to initiation

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

147 of the Act as well as during the entire assessment proceeding. He never mentioned anywhere that he was thinking about the different property at the time of recording the reasons of his satisfaction to reopen the assessment. This is completely a post think story of the Ld. DR. b) With regard to non-submission of assessee’s reply dated

SUSHILA DEVI JANGID,JAIPUR vs. ITO, WD 7(2), JAIPUR

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं. / ITA. No. 374/JP/2025 निर्धारणवर्ष / AssessmentYears : 2010-11 Smt. Sushila Devi Jangid 65, Koshaliya Vihar Hajyawala,Muhana Mandi Ke Pass, Sanganer, Jaipur 302 029 बनाम Vs. The ITO Ward 7(2) Jaipur अपीलार्थी / Appellant प्रत्यर्थी / Respondent स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: AFMPJ 2091 P निर्धारिती की ओरसे / Assesseeby : Shri Utkarsh Mishra, Advocate राजस्व की ओरसे / Revenue by :Shri Gautam Sing

Reassessment proceedings u/s 147 of the Act for relevant A.Y still reflect as on-going proceedings under ‘For your action’ list on ‘e-proceedings’ tab on the Income Tax profile of the assessee. Also, there is no Order u/s 144 r.w.s 147 dated 24.12.2017 available under ‘For your information’ list on ‘e- proceedings’ tab on the income tax profile

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

152 taxmann.com 347 (Kerala). (IT APPEAL\r\nNOS. 120 OF 2019/11 OF 2022, MARCH 14, 2023) wherein it is held as under :-\r\n\"On a reading of section 80A(5) and section 80AC as they stood prior to 1-4-2018,\r\nit is found that when the latter provision was amended by Finance Act 2018, it\r\nwould

SHRI DIGAMBER JAIN ATIKSHAYA KESHTRA,PADAMPUA vs. ITO EXEMPTION WARD 1, KAILASH HEIGHTS

In the result appeal of the assessee is partly allowed

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

152 3.7. It may please be noted that none of the additions based on the above reasons have been made in the reassessment proceedings. The additions made are on the following reasons: 10 Shri Digamber Jain Atikshaya Keshtra I. Accumulation of Income under section 11(2) Rs.1,11,000 II. Income from House Property under section 24(a) Rs.1

SMT. LAKSHMI AGARWAL ,JAIPUR vs. ITO, WARD-4(5), JAIPUR, JAIPUR

In the result, the appeal of the assessee is dismissed with no orders as to costs

Bench: recording satisfaction for issuance of notice since the information is specific. Thus the reasons recorded for re-opening is on borrowed satisfaction and not on any satisfaction by the AO. The

u/s 147 by the AO during the course of reassessment proceedings. AO has applied his mind independently after verification of the records of the appellant in the database that the appellant did not file original return of income and that no original scrutiny proceedings was carried out as well as there is cogent material in the form of information received

SHRI BANNA LAL JAT,BHILWARA vs. ASSISTANT COMMISSIONER OF INCOME TAX, AJMER

In the result, theses appeals filed by the assessee are allowed

147 (income escaping assessment) and 263 (revision of orders) of the Act. 26. The plea raised on behalf of the assessee that as the first proviso provides for assessment or reassessment of the total income in respect of each assessment year falling within the six assessment years, is merely reading the said provision in isolation and not in the context

SHRI BANNA LAL JAT,BHILWARA vs. ASSISTANT COMMISSIONER OF INCOME TAX, AJMER

In the result, theses appeals filed by the assessee are allowed

147 (income escaping assessment) and 263 (revision of orders) of the Act. 26. The plea raised on behalf of the assessee that as the first proviso provides for assessment or reassessment of the total income in respect of each assessment year falling within the six assessment years, is merely reading the said provision in isolation and not in the context

SHRI BANNA LAL JAT,BHILWARA vs. ASSISTANT COMMISSIONER OF INCOME TAX, AJMER

In the result, theses appeals filed by the assessee are allowed

147 (income escaping assessment) and 263 (revision of orders) of the Act. 26. The plea raised on behalf of the assessee that as the first proviso provides for assessment or reassessment of the total income in respect of each assessment year falling within the six assessment years, is merely reading the said provision in isolation and not in the context

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

147 (income escaping assessment) and 263 (revision of orders) of the Act. 29 ITA Nos. 1284(4)/JP/2018 Smt. Reema Harish Bhatia, Kota. 26. The plea raised on behalf of the assessee that as the first proviso provides for assessment or reassessment of the total income in respect of each assessment year falling within the six assessment years, is merely

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

147 (income escaping assessment) and 263 (revision of orders) of the Act. 29 ITA Nos. 1284(4)/JP/2018 Smt. Reema Harish Bhatia, Kota. 26. The plea raised on behalf of the assessee that as the first proviso provides for assessment or reassessment of the total income in respect of each assessment year falling within the six assessment years, is merely

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

147 (income escaping assessment) and 263 (revision of orders) of the Act. 29 ITA Nos. 1284(4)/JP/2018 Smt. Reema Harish Bhatia, Kota. 26. The plea raised on behalf of the assessee that as the first proviso provides for assessment or reassessment of the total income in respect of each assessment year falling within the six assessment years, is merely

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

147 (income escaping assessment) and 263 (revision of orders) of the Act. 29 ITA Nos. 1284(4)/JP/2018 Smt. Reema Harish Bhatia, Kota. 26. The plea raised on behalf of the assessee that as the first proviso provides for assessment or reassessment of the total income in respect of each assessment year falling within the six assessment years, is merely

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

147 (income escaping assessment) and 263 (revision of orders) of the Act. 29 ITA Nos. 1284(4)/JP/2018 Smt. Reema Harish Bhatia, Kota. 26. The plea raised on behalf of the assessee that as the first proviso provides for assessment or reassessment of the total income in respect of each assessment year falling within the six assessment years, is merely

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

In the result, the appeal of the assessee for A

147 (income escaping assessment) and 263 (revision of orders) of the Act. 26. The plea raised on behalf of the assessee that as the first proviso provides for assessment or reassessment of the total income in respect of each assessment year falling within the six assessment years, is merely reading the said provision in isolation and not in the context