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20 results for “reassessment u/s 147”+ Section 234Dclear

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Mumbai142Delhi78Bangalore46Ahmedabad38Hyderabad29Jaipur20Raipur17Kolkata10Rajkot7Surat4Chennai3Guwahati3Chandigarh2Patna2Dehradun2Varanasi1Lucknow1Nagpur1Pune1Ranchi1

Key Topics

Section 143(3)30Section 14728Addition to Income20Section 25012Section 14811Section 234B8Section 153D7Unexplained Investment7Deduction

SHRI VIJAY KUMAR AGARWAL,JAIPUR vs. INCOME TAX OFFICER, WARD-4-2, JAIPUR

In the result, this appeal of the assessee is allowed

ITA 59/JPR/2019[2011-12]Status: DisposedITAT Jaipur24 May 2021AY 2011-12

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 59/Jp/2019 Fu/Kzkj.K O"Kz@Assessment Year :2011-12 Vijay Kumar Agarwal, Cuke I.T.O., Vs. 7/58, Vidhyadhar Nagar, Ward 4(2), Jaipur. Jaipur. Lfkk;H Ys[Kk La-@Thvkbzvkj La-@Pan/Gir No.: Advpa 6150 F Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri Pravin Kr. Saraswat (Ca) Jktlo Dh Vksj Ls@ Revenue By : Smt. Rooni Paul (Addl.Cit) Lquokbz Dh Rkjh[K@ Date Of Hearing : 15/03/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 24/05/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. This Is An Appeal Filed By The Assessee Against The Order Of Ld.Cit(A), Ajmer Dated 27/12/2018 For The A.Y. 2011-12 In The Matter Of Order Passed U/S 143(3) Read With Section 147 Of The Income Tax Act, 1961 (In Short, The Act), Wherein Following Grounds Have Been Taken. “1. The Learned C.I.T. (A) Has Erred For Not Considering The Issue For Validity Of Issue Notice U/S 148 Of I.T. Act, 1961, While There Was No Escapement Of Income On Part Of Assessee. The Initiation Of Proceedings Was Only On Behest Of I.T.O. Ward 3(2), Who Has Intimated To A.O. For Advancement Of Loan Rs.53,95,000/- Given By Assessee To Pooja Agarwal, While Concern A.O. Has Accepted Said Loan In Her Hands After Detailed Examination. Hence Initiation Of 2

For Appellant: Shri Pravin Kr. Saraswat (CA)For Respondent: Smt. Rooni Paul (Addl.CIT)
Section 143(3)Section 147
6
Section 234D5
Section 234A5
Disallowance5
Section 148
Section 148(2)
Section 151

u/s 147 read with section 143(3) of the Income Tax Act deserves to be quashed. Ld.Assessing Officer had no jurisdiction to travel beyond the reasons for reopening the assessment. This contention of assessee is based on well settled law and a few judgements in support, including binding judgments of Hon’ble Jurisdictional Rajasthan High Court, are as under

SHRI BHAGWATI PRASAD SHARMA,DAUSA vs. INCOME TAX OFFICER, WARD, DAUSA

ITA 27/JPR/2019[2009-10]Status: DisposedITAT Jaipur06 Mar 2023AY 2009-10

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

Section 143(3)Section 147Section 234BSection 250

234D as consequential in nature. The appellant totally denies it liability of charging of any such interest. Hence the interest so charged, being contrary to the provisions of law and facts, may kindly be deleted in full. 5. The appellant prays your honors indulgence to add, amend or alter all or any of the grounds of the appeal

SMT. SAROJ DHAKA,JAIPUR vs. ITO, WARD-6(3), JAIPUR

ITA 1345/JPR/2019[2009-10]Status: DisposedITAT Jaipur06 Mar 2023AY 2009-10

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

Section 143(3)Section 147Section 234BSection 250

234D as consequential in nature. The appellant totally denies it liability of charging of any such interest. Hence the interest so charged, being contrary to the provisions of law and facts, may kindly be deleted in full. 5. The appellant prays your honors indulgence to add, amend or alter all or any of the grounds of the appeal

SHRI KAILASH CHAND GEHLOT,JAIPUR vs. ITO, WARD-5(3) JAIPUR

ITA 1279/JPR/2019[2009-10]Status: DisposedITAT Jaipur06 Mar 2023AY 2009-10

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

Section 143(3)Section 147Section 234BSection 250

234D as consequential in nature. The appellant totally denies it liability of charging of any such interest. Hence the interest so charged, being contrary to the provisions of law and facts, may kindly be deleted in full. 5. The appellant prays your honors indulgence to add, amend or alter all or any of the grounds of the appeal

SHRI SURESH KUMAR CHAWLA,JAIPUR vs. ITO, WARD -6(3), JAIPUR

ITA 8/JPR/2020[2009-10]Status: DisposedITAT Jaipur06 Mar 2023AY 2009-10

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

Section 143(3)Section 147Section 234BSection 250

234D as consequential in nature. The appellant totally denies it liability of charging of any such interest. Hence the interest so charged, being contrary to the provisions of law and facts, may kindly be deleted in full. 5. The appellant prays your honors indulgence to add, amend or alter all or any of the grounds of the appeal

ASHA SHARMA,JAIPUR vs. ITO, WARD-2(3), JAIPUR

ITA 22/JPR/2021[2009-10]Status: DisposedITAT Jaipur06 Mar 2023AY 2009-10

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

Section 143(3)Section 147Section 234BSection 250

234D as consequential in nature. The appellant totally denies it liability of charging of any such interest. Hence the interest so charged, being contrary to the provisions of law and facts, may kindly be deleted in full. 5. The appellant prays your honors indulgence to add, amend or alter all or any of the grounds of the appeal

SHRI SHRINIVAS TRIPATHI,AJMER vs. INCOME TAX OFFICER, AJMER

ITA 471/JPR/2018[2009-10]Status: DisposedITAT Jaipur06 Mar 2023AY 2009-10

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

Section 143(3)Section 147Section 234BSection 250

234D as consequential in nature. The appellant totally denies it liability of charging of any such interest. Hence the interest so charged, being contrary to the provisions of law and facts, may kindly be deleted in full. 5. The appellant prays your honors indulgence to add, amend or alter all or any of the grounds of the appeal

SHRI ARVIND KUMAR SENGWA,AJMER vs. INCOME TAX OFFICER, WARD-2-1, AJMER

ITA 1123/JPR/2018[2009-10]Status: DisposedITAT Jaipur06 Mar 2023AY 2009-10

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

Section 143(3)Section 147Section 234BSection 250

234D as consequential in nature. The appellant totally denies it liability of charging of any such interest. Hence the interest so charged, being contrary to the provisions of law and facts, may kindly be deleted in full. 5. The appellant prays your honors indulgence to add, amend or alter all or any of the grounds of the appeal

BALVEER SINGH,JAIPUR vs. ITO WARD 3(3) JAIPUR, INCOME TAX DEPARTMENT

ITA 183/JPR/2024[2012-13]Status: DisposedITAT Jaipur30 Oct 2024AY 2012-13
For Appellant: Shri Naresh Gupta (Adv.)For Respondent: Shri Sanjay Nargas (JCIT)
Section 133(6)Section 143(2)Section 144Section 147

147 and 148, of the Income-tax Act, 1961-\nBusiness income Chargeable as (Reassessment) Assessment year 2013-14\nAssessing Officer issued on assessee a notice under section 148 seeking to\nreopen assessment for reasons that as per Form No. 26AS assessee's total\nreceipt under sections 1944, 194C and 194J was of Rs. 5.23 crores, whereas in\nprofit and loss

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

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

ITA 1294/JPR/2024[2013-14]Status: DisposedITAT Jaipur13 Feb 2025AY 2013-14

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

For Appellant: Shri Mahendra Gargieya, Advocate &For Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 144Section 147Section 148Section 2(47)Section 234ASection 48Section 50C

234D of the Act. The appellant totally denies it liability of charging of any such interest. The interest, so charged, being contrary to the provisions of law and facts, kindly be deleted in full. 2.1 Apropos Ground of appeals (supra), it is noted that the ld. CIT(A) has partly allowed the appeal of the assessee for statistical purposes

RAJNI VINOD MALHOTRA,MUMBAI vs. DCIT, INTERNATIONAL TAXATION, JAIPUR

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

ITA 324/JPR/2021[2012-13]Status: DisposedITAT Jaipur31 Mar 2022AY 2012-13
For Appellant: Shri Rohan Sogani (C.A.)For Respondent: Shri A.S. Nehra (Addl. CIT) a
Section 139(1)Section 143(3)Section 234ASection 234BSection 234CSection 234DSection 271(1)(c)Section 271FSection 54Section 69A

147 of the Act at Rs. 3,46,08,520/-. Issued demand notice and challan. Charge interest u/s 234A, u/s 234B, u/s 234C & u/s 234D of the Act. Issued penalty notice u/s 271(1)(c) of the Act in respect of Income determined u/s 69A of the Act. Penalty notice u/s 271F r.w.s. 274 issued for non-compliance

AKSH OPTIFIBRE LIMITED,NEW DELHI vs. ACIT, CIRCLE - 2, ALWAR

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

ITA 170/JPR/2024[2010-11]Status: DisposedITAT Jaipur20 May 2025AY 2010-11
For Appellant: Shri Akul Agarwal, C.A. (thr. V.C.)For Respondent: Shri Arvind Kumar, CIT-DR
Section 143(3)Section 147Section 148Section 156Section 234ASection 250

section 250 of the I.T. Act,\n1961, for the assessment year 2010-11.\n2.\nThe assessee has raised the following grounds of appeal :-\n\"1. On the facts and in the circumstances of the case and in law the Ld. A.O. has erred in\nlaw as well as on facts in Issuing notice u/s 148 to an entity which

RAJESH KUMAR KHANDELWAL,JAIPUR vs. INCOME TAX OFFICER, WARD – 2(1), JAIPUR

In the result, the appeal of the assessee is allowed

ITA 14/JPR/2022[2010-11]Status: DisposedITAT Jaipur16 Aug 2022AY 2010-11
For Appellant: None (Written Submission)For Respondent: Shri Manoj Mehar (CIT) a
Section 143(3)Section 147Section 148Section 234ASection 271(1)(c)

section 147 of the Income Tax Act, 1961 showing calculation of tax and interest chargeable, if any, is attached herewith forming part of this order. Charge interest u/s 234A/ 234B/234C and 234D, if any, a peer rules. Penalty proceedings u/s 271(1)(c) are initiated separately. Rajesh Kumar Khandealwal vs. ITO 7. Being aggrieved by the AO the assessee preferred

RESONANCE EDUVENTURES LIMITED,,KOTA vs. ACIT DCIT, CENTRAL CIRCLE, , KOTA

In the result, all the appeals of the assessee are allowed

ITA 671/JPR/2024[2017-18]Status: DisposedITAT Jaipur10 Mar 2025AY 2017-18

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

For Appellant: Shri Mahendra Gargieya, Adv. (Thr. V.C)&For Respondent: Smt. Alka Gautam, CIT-DR
Section 143(3)Section 14ASection 153DSection 234DSection 250

234D of the Act. The appellant totally denies its liability of charging of any such interest. The interest so charged, being contrary to the provisions of law and facts, kindly be deleted in full. 5. The appellant prays your honor indulgences to add, amend or alter of or any of the grounds of the appeal on or before the date

RESONANCE EDUVENTURES LIMITED,KOTA vs. ACIT DCIT, CENTRAL CIRCLE,, KOTA

In the result, all the appeals of the assessee are allowed

ITA 672/JPR/2024[2018-19]Status: DisposedITAT Jaipur10 Mar 2025AY 2018-19

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

For Appellant: Shri Mahendra Gargieya, Adv. (Thr. V.C)&For Respondent: Smt. Alka Gautam, CIT-DR
Section 143(3)Section 14ASection 153DSection 234DSection 250

234D of the Act. The appellant totally denies its liability of charging of any such interest. The interest so charged, being contrary to the provisions of law and facts, kindly be deleted in full. 5. The appellant prays your honor indulgences to add, amend or alter of or any of the grounds of the appeal on or before the date

RESONANCE EDUVENTURES LIMITED, KOTA,KOTA vs. ACIT DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result, all the appeals of the assessee are allowed

ITA 669/JPR/2024[2015-16]Status: DisposedITAT Jaipur10 Mar 2025AY 2015-16

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

For Appellant: Shri Mahendra Gargieya, Adv. (Thr. V.C)&For Respondent: Smt. Alka Gautam, CIT-DR
Section 143(3)Section 14ASection 153DSection 234DSection 250

234D of the Act. The appellant totally denies its liability of charging of any such interest. The interest so charged, being contrary to the provisions of law and facts, kindly be deleted in full. 5. The appellant prays your honor indulgences to add, amend or alter of or any of the grounds of the appeal on or before the date

RESONANCE EDUVENTURES LIMITED,KOTA,KOTA vs. ACIT DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result, all the appeals of the assessee are allowed

ITA 670/JPR/2024[2016-17]Status: DisposedITAT Jaipur10 Mar 2025AY 2016-17
For Appellant: Shri Mahendra Gargieya, Adv. (Thr. V.C)&For Respondent: Smt. Alka Gautam, CIT-DR
Section 143(3)Section 14ASection 153DSection 234D

234D of the Act. The appellant totally denies its liability of\ncharging of any such interest. The interest so charged, being contrary to the\nprovisions of law and facts, kindly be deleted in full.\n5.\nThe appellant prays your honor indulgences to add, amend or alter of or any of the\ngrounds of the appeal on or before the date

RAKESH KUMAR JAIN,JAIPUR vs. DCIT,CIRCLE-2, JAIPUR, JAIPUR

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

ITA 212/JPR/2025[2014-15]Status: DisposedITAT Jaipur23 Jul 2025AY 2014-15

Bench: Or At The Time Of Hearing Of The Appeal & / Or Modify Any Of The Above Grounds.

For Appellant: Shri C.L. Yadav, CA and Shri Vikas Yadav AdvocateFor Respondent: Shri Gautam Singh Choudhary
Section 250(6)Section 271(1)(c)

Reassessment was quashed. [S. 144, 144B, 147, 282, Rule 127, Art. 226] 1.6 In the instant case also, the Notice for Enablement of Communication window. (notice intimating start of appellate proceedings by NFAC) was issued on 01 11 02022. On the said date, the Primary email id registered in the PAN database was nekiwala71@gmail.com, but the NFAC sent the hearing

MAHESH KUMAR AGRAWAL,JAIPUR vs. ACIT CIRCLE 7 JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 194/JPR/2021[2012-13]Status: DisposedITAT Jaipur29 Aug 2022AY 2012-13
For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Shri A.S. Nehara (Addl.CIT) a
Section 139(1)Section 147Section 148Section 271(1)(c)Section 274

147 of the Act vide notice dated 13.10.2014 u/s 148 of the Income Tax Act. It would not be out of place to mention here that during the year under appeal, assessee was employed with a company at Jaipur till July 2011 and thereafter joined a company at Ahmedabad. In order to attract him, new employer at Ahmedabad (M/s Adani

AKSHAT LOYALKA,JAIPUR vs. RJN-C-(101)(1), JAIPUR

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

ITA 1019/JPR/2024[2016-17]Status: DisposedITAT Jaipur27 May 2025AY 2016-17
For Appellant: Shri Mahendra Gargieya, Advocate &For Respondent: Shri Gautam Singh Choudhary, Addl. CIT-DR
Section 144BSection 147Section 234ASection 250Section 5Section 69A

234D of the Act. The levy interest being\ncharged, is contrary to the provisions of law and facts, kindly be deleted in full.\n6. The appellant prays your honor indulgences to add, amend or alter of or any of\nthe grounds of the appeal on or before the date of hearing.”\nWe find that as per order sheet placed