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)

Section 147. From the aforesaid notings of the AO in the reasons recorded it is clear that the AO was not sure as to whether income escaped the assessment. Since the word probably has been used, and there was no application of his own mind by the AO who depended only on the information received from the Investigation Wing

KAILASH CHAND YADAV,100, KALU BABA KI DHANI, SHEOSHINGHPUR, AKODA, PHULERA-303338 vs. INCOME TAX OFFICER,, WARD - 1(2), JAIPUR

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

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

Section 292BB is not attracted. 4. Reasons recorded are not correct – On requested by the assessee the Learned Assessing Officer has supplied the copy of reasons recorded. Copy of reasons recorded is available on Paper Book Page No. 179 to 180. The Learned Assessing Officer made the addition of Rs. 25,85,740/- on the basis of reasons recorded which

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. SH. NAVAL KISHORE, KOTA

In the result appeal filed by the assessee stands allowed and that of the revenue stands dismissed

u/s 2(31) of the act. #### 3. Supporting Case laws: - 3.1 Principal CIT vs. Saumya Construction ((2017) 297 CTR (Guj) 387 : (2016) 387 ITR 529 (Guj)) - 3.2 In the case of Dy. CIT vs. Smt. Shivali Mahajan & Ors. (ITA No. 5585/Del/2015), the Tribunal was considering whether books of accounts, money, bullion, jewellery found during the course of search relates

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. KARNANI SOLVEX PRIVATE LIMITED, JAIPUR

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

u/s 143(3) of Prem\nKunj Commosales P Ltd for AY 2014-15 dated\n07.12.2016\n146-\n152\n25. Copy of assessment order u/s 143(3) of\nPanchkoti Wholeseller P Ltd for AY 2014-15 dated\n13.12.2016\n153-\n159\n26. Copy of assessment order u/s 143(3) of Night\nBird Barter P Ltd for AY 2014-15 dated\n21.11.2016\n160-\n165

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

147 is bad in law and deserves to be quashed.\n2. Re Assessment for A.Y. 2015-16 completed without issuing notice_u/s\n143(2) of the Act\nIn this regard, it is submitted that as is evident from table of notices issued as\nfurnished in preceding paras, no notice u/s 143(2) was issued by Id.AO during the\ncourse

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

147 is bad in law and deserves to be quashed.\n2. Re Assessment for A.Y. 2015-16 completed without issuing notice_u/s\n143(2) of the Act\nIn this regard, it is submitted that as is evident from table of notices issued as\nfurnished in preceding paras, no notice u/s 143(2) was issued by Id.AO during the\ncourse

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

147 is bad in law and deserves to be quashed.\n2. Re Assessment for A.Y. 2015-16 completed without issuing notice_u/s\n143(2) of the Act\nIn this regard, it is submitted that as is evident from table of notices issued as\nfurnished in preceding paras, no notice u/s 143(2) was issued by Id.AO during the\ncourse

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMSSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

147 is bad in law and deserves to be quashed.\n2. Re Assessment for A.Y. 2015-16 completed without issuing notice_u/s\n143(2) of the Act\nIn this regard, it is submitted that as is evident from table of notices issued as\nfurnished in preceding paras, no notice u/s 143(2) was issued by Id.AO during the\ncourse

PUNEET SINGHVI,KOTA vs. ITO, WARD-2(1), KOTA

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

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

147 and the notice u/s 148 deserved to be quashed. 2.No adequate opportunity: The ld. CIT(A) erred in law as well as on the facts of the case in passing the impugned order in a haste on dated 26.08.2024 without 8 SHRI PUNEET SINGHVI VS ITO, WARD 2(1), KOTA affording adequate and reasonable opportunity of being heard

M/S BHIVARAM PANNALAL KUMAWAT,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR

Appeal are disposed off and all the appeals of the

Bench: Us By The Department. The Facts As Well As Issues, Are More Or Less Involving The Disallowance Of Labour Expenses & Therefore, These Twelve Appeals Were Head

u/s 132(4) where certain facts are recorded, from the interpretation of which AO could conclude that there was some undisclosed income, then that statement can be 52 M/s. Bhivaram PannalalKumawat vs ACIT , Central Circle-3, Jaipur considered as incriminating material. However, in the present case, the statement stood retracted supported by reasons and subsequent to this decision various High

DCIT, CC-3, JAIPUR vs. M/S BHIVARAM PANNALAL KUMAWAT, JAIPUR

Appeal are disposed off and all the appeals of the

Bench: Us By The Department. The Facts As Well As Issues, Are More Or Less Involving The Disallowance Of Labour Expenses & Therefore, These Twelve Appeals Were Head

u/s 132(4) where certain facts are recorded, from the interpretation of which AO could conclude that there was some undisclosed income, then that statement can be 52 M/s. Bhivaram PannalalKumawat vs ACIT , Central Circle-3, Jaipur considered as incriminating material. However, in the present case, the statement stood retracted supported by reasons and subsequent to this decision various High

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

147 is bad in law and deserves to be quashed.\n2. Re Assessment for A.Y. 2015-16 completed without issuing notice_u/s\n143(2) of the Act\nIn this regard, it is submitted that as is evident from table of notices issued as\nfurnished in preceding paras, no notice u/s 143(2) was issued by Id.AO during the\ncourse

KAILASH CHAND,JAIPUR vs. ITO WARD, BEHROR, BEHROR

In the result, the appeal of the assessee is allowed

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

section 147 would give arbitrary powers to the Assessing Officer to reopen assessments on the basis of "mere change of opinion", which cannot be per se reason to reopen. We must also keep in mind the conceptual difference between power to review and power to reassess. The Assessing Officer has no power to review; he has the power to reassess

CASTAMET WORKS PRIVATE LIMITED,KHARWA vs. PRINCIPLE COMMISSIONER OF INCOME TAX, UDAIPUR

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001. 28. The correctness of the claim of the Assessee for the purpose of Section 14A read with Rule

LATE SH. BHIM SEN BATRA L/H SH. HIMANSHU BATRA,ALWAR vs. ITO, ALWAR

In the result, appeals of the assessee in ITA Nos

reassessment under section 143(3) read with section 147 and made various additions apart from the surrendered income of Rs. 3,14,490/-. The assessee challenged the action of the AO before the ld. CIT (A) and also raised objections against the validity of reopening of the assessment. However, the ld. CIT (A) has upheld the validity of reopening

LATE SH. BHEEM SEN BATRA,JAIPUR vs. ITO, ALWAR

In the result, appeals of the assessee in ITA Nos

reassessment under section 143(3) read with section 147 and made various additions apart from the surrendered income of Rs. 3,14,490/-. The assessee challenged the action of the AO before the ld. CIT (A) and also raised objections against the validity of reopening of the assessment. However, the ld. CIT (A) has upheld the validity of reopening

LATE SH. BHEEM SEN BATRA,JAIPUR vs. ITO, ALWAR

In the result, appeals of the assessee in ITA Nos

reassessment under section 143(3) read with section 147 and made various additions apart from the surrendered income of Rs. 3,14,490/-. The assessee challenged the action of the AO before the ld. CIT (A) and also raised objections against the validity of reopening of the assessment. However, the ld. CIT (A) has upheld the validity of reopening

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. M/S RIGID CONDUCTORS (RAJ.) PVT. LTD., JAIPUR

In the result, the appeals of the revenue stands dismissed

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

147 assessment proceedings. 7 Inspector report for the physical enquiry made during the 148 assessment proceedings. It is certified that the above documents have been supplied by the DCIT, Central Circle-03, Jaipur vide letter no. 710 dated 14.09.2022.” 29 ITA No. 264 to 267/JP/2022 & CO No.13 to 16/JP/2022 DCIT vs. M/s Rigid Conductors (Raj.) Pvt. Ltd. Report