M/S. MULTI METAL PRIVATE LTD.,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

section 254(2) of the Income-tax Act, 1961 had been filed by the revenue before the said Tribunal. In that also, in paragraph (g) of the Miscellaneous Application, the revenue had submitted as under:— "(g )Because, although findings of the Tribunal are factually correct but the decision of the Tribunal is not acceptable because violation of the canons

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S. MULTI METAL PRIVATE LTD., KOTA

section 254(2) of the Income-tax Act, 1961 had been filed by the revenue before the said Tribunal. In that also, in paragraph (g) of the Miscellaneous Application, the revenue had submitted as under:— "(g )Because, although findings of the Tribunal are factually correct but the decision of the Tribunal is not acceptable because violation of the canons

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S. MULTI METAL PRIVATE LTD., KOTA

section 254(2) of the Income-tax Act, 1961 had been filed by the revenue before the said Tribunal. In that also, in paragraph (g) of the Miscellaneous Application, the revenue had submitted as under:— "(g )Because, although findings of the Tribunal are factually correct but the decision of the Tribunal is not acceptable because violation of the canons

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S. MULTI METAL PRIVATE LTD., KOTA

section 254(2) of the Income-tax Act, 1961 had been filed by the revenue before the said Tribunal. In that also, in paragraph (g) of the Miscellaneous Application, the revenue had submitted as under:— "(g )Because, although findings of the Tribunal are factually correct but the decision of the Tribunal is not acceptable because violation of the canons

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S. MULTI METAL PRIVATE LTD., KOTA

section 254(2) of the Income-tax Act, 1961 had been filed by the revenue before the said Tribunal. In that also, in paragraph (g) of the Miscellaneous Application, the revenue had submitted as under:— "(g )Because, although findings of the Tribunal are factually correct but the decision of the Tribunal is not acceptable because violation of the canons

M/S. MULTI METAL PRIVATE LTD.,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

section 254(2) of the Income-tax Act, 1961 had been filed by the revenue before the said Tribunal. In that also, in paragraph (g) of the Miscellaneous Application, the revenue had submitted as under:— "(g )Because, although findings of the Tribunal are factually correct but the decision of the Tribunal is not acceptable because violation of the canons

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S. MULTI METAL PRIVATE LTD., KOTA

section 254(2) of the Income-tax Act, 1961 had been filed by the revenue before the said Tribunal. In that also, in paragraph (g) of the Miscellaneous Application, the revenue had submitted as under:— "(g )Because, although findings of the Tribunal are factually correct but the decision of the Tribunal is not acceptable because violation of the canons

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S. MULTI METAL PRIVATE LTD., KOTA

section 254(2) of the Income-tax Act, 1961 had been filed by the revenue before the said Tribunal. In that also, in paragraph (g) of the Miscellaneous Application, the revenue had submitted as under:— "(g )Because, although findings of the Tribunal are factually correct but the decision of the Tribunal is not acceptable because violation of the canons

M/S. MULTI METAL PRIVATE LTD.,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

section 254(2) of the Income-tax Act, 1961 had been filed by the revenue before the said Tribunal. In that also, in paragraph (g) of the Miscellaneous Application, the revenue had submitted as under:— "(g )Because, although findings of the Tribunal are factually correct but the decision of the Tribunal is not acceptable because violation of the canons

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

In the result, the appeal of the assessee is allowed

1) of section 153A]\n\nFrom perusal of above, it is evident that legislation has clearly provided that if any\ndocuments found during search, pertain to a person other than the person searched,\nsuch documents shall be handed over to the Assessing officer having jurisdiction over\nsuch third person, who shall complete assessment in accordance with section 153C of\nthe

RAMESH CHAND SONI HUF,JAIPUR vs. ITO, BEAWAR

In the result, the appeals of the assessee are allowed

147 on 01.12.2011. The assessee challenged the action of the AO including the validity of reopening before the ld. CIT(A) but could not succeed. 3. Before us, the ld. AR of the assessee has submitted that the notice issued u/s 148 on 30.07.2010 is barred by limitation as provided U/s 149 r.w.s. 150. He has further contented that

M/S RAJASTHAN RAJYA VIDYUT PRASARAN NIGAM LTD.,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result, appeal of the assessee is allowed

u/s 44AB was accompanied with the return. Hence, reopening of assessment proceeding is nothing but change of opinion which is outside the scope of provision of section 147. In support of his contention, he has relied upon the following decisions :- 5 Rajasthan Rajya Vidyut Prasaran Nigam Ltd., Jaipur. DCIT vs. Aristocrat Luggage Ltd. 46 CCH 254 (Mumbai Trib.) PCIT

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S. EDILA BUSINESS WORLD PVT. LTD., KOTA

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

M/S. EDILA BUSINESS WORLD PVT. LTD.,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

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

M/S. EDILA BUSINESS WORLD PVT. LTD.,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

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

M/S. JAMMU METALLIC OXIDES PRIVATE LIMITED,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

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 ITA Nos. 1055, 1208, 1191/JP/2018 & CO 49/JP/2018 23 M/s Jammu Metallic Oxides Pvt. Ltd. Vs DCIT each assessment year falling within

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S. JAMMU METALLIC OXIDES PRIVATE LIMITED, KOTA

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 ITA Nos. 1055, 1208, 1191/JP/2018 & CO 49/JP/2018 23 M/s Jammu Metallic Oxides Pvt. Ltd. Vs DCIT each assessment year falling within

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S. JAMMU METALLIC OXIDES PRIVATE LIMITED, KOTA

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 ITA Nos. 1055, 1208, 1191/JP/2018 & CO 49/JP/2018 23 M/s Jammu Metallic Oxides Pvt. Ltd. Vs DCIT each assessment year falling within

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S. TIRUPATI BALAJI ESTATE PRIVATE LIMITED., KOTA

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 ITA Nos. 1054, 1190 & 1209/JP/2018 & CO 47/JP/2018 23 M/s Tirupati Balaji Estate Pvt. Ltd. Vs DCIT each assessment year falling within