OM PRAKASH AGARWAL,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX,JAIPUR-1, JAIPUR

In the result, the appeal is allowed

Bench: Us. In This Appeal The Assessee Has Raised The Following Grounds Of Appeal:-

u/s. 263 & 264. In section 264 the application can be moved by the assessee or own its own motion the proceeding can be initiated. This own motion is missing in the 263 section and thus, the proceeding validly initiated. The ld. DR also read the meaning of record given in the 263 section which include the records of the review

SHIV VEGPRO PRIVATE LIMITED ,KOTA vs. PCIT-UDAIPUR , UDAIPUR

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

reassessment was completed vide order dated\n26.03.2015 by making a further disallowance of Rs.1,38,95,995/- u/s\n40(a)(ia) of the Act (and the total reassessed income of Rs.\n5,97,80,77,790/-). However, this was followed by a notice u/s 263 with\nreference to the reassessment order passed u/s 143(3) r.w. 147 of the\nAct

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

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 131 on the address of above companies requesting furnishing of books of accounts, details of bank accounts, copies of Kedia Builders and Colonizers Pvt. Ltd., Jaipur ITR and other documents, but the same could not be served due to non-existence of the companies on their respective given addresses. From the Database of the department, it is gathered that

VIPUL KUMAR MODI ,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAIPUR -I

In the result, appeal of the assessee is allowed

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

147 read with sections 144B of the Act dated 23.03.2022. 2 Vipul Kumar Modi vs. PCIT 2. The assessee has marched this appeal on the following grounds:- “1 Ground1. That on the facts and in the circumstances of the case, the Id. Principal Commissioner of Income-tax grossly erred in passing an order u/s. 263

PALSANA GRAM SEWA SAHKARI SAMITI LTD.,JAIPUR vs. PCIT-2, JAIPUR

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

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 35 To 37/Jp/2021 Assessment Years: 2010-11 To 2012-13 Palsana Gram Sewa Sahkari Samiti Cuke Pr.Cit-2, Vs. Limited, Jaipur. Village- Palsana Main Market, Palsana, Dist.- Sikar- 332402 (Raj) Pan No.: Aabap 8390 A Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri Shrawan Kr. Gupta (Adv) Jktlo Dh Vksj Ls@ Revenue By : Shri B.K. Gupta (Pr.Cit-Dr) Lquokbz Dh Rkjh[K@ Date Of Hearing : 04/08/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 02/11/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. These Are The Appeals Filed By The Assessee Against The Separate Order Of The Ld. Pr.Cit-2, Jaipur All Dated 31/03/2021 Passed U/S 263 Of The Income Tax Act, 1961 (In Short, The Act) For The A.Y. 2010-11 To 2012-13. 2. The Hearing Of The Appeal Was Concluded Through Video Conference In View Of The Prevailing Situation Of Covid-19 Pandemic.

147 rws143(3) dt. 30.06.2017 by taking a reasonable and possible view. Here we want to say that if the ld. AO has not examined the issues and claim of deduction u/s 80P he could have not made the assessment. When the assessee has filed reply on deduction u/s 80P (PB8-11) with all the bank details and income

PALSANA GRAM SEWA SAHKARI SAMITI LTD.,PALASANA vs. PCIT-2, JAIPUR

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

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 35 To 37/Jp/2021 Assessment Years: 2010-11 To 2012-13 Palsana Gram Sewa Sahkari Samiti Cuke Pr.Cit-2, Vs. Limited, Jaipur. Village- Palsana Main Market, Palsana, Dist.- Sikar- 332402 (Raj) Pan No.: Aabap 8390 A Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri Shrawan Kr. Gupta (Adv) Jktlo Dh Vksj Ls@ Revenue By : Shri B.K. Gupta (Pr.Cit-Dr) Lquokbz Dh Rkjh[K@ Date Of Hearing : 04/08/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 02/11/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. These Are The Appeals Filed By The Assessee Against The Separate Order Of The Ld. Pr.Cit-2, Jaipur All Dated 31/03/2021 Passed U/S 263 Of The Income Tax Act, 1961 (In Short, The Act) For The A.Y. 2010-11 To 2012-13. 2. The Hearing Of The Appeal Was Concluded Through Video Conference In View Of The Prevailing Situation Of Covid-19 Pandemic.

147 rws143(3) dt. 30.06.2017 by taking a reasonable and possible view. Here we want to say that if the ld. AO has not examined the issues and claim of deduction u/s 80P he could have not made the assessment. When the assessee has filed reply on deduction u/s 80P (PB8-11) with all the bank details and income

PALSANA GRAM SEWA SAHKARI SAMITI LTD.,PALSANA vs. PCIT-2, JAIPUR

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

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 35 To 37/Jp/2021 Assessment Years: 2010-11 To 2012-13 Palsana Gram Sewa Sahkari Samiti Cuke Pr.Cit-2, Vs. Limited, Jaipur. Village- Palsana Main Market, Palsana, Dist.- Sikar- 332402 (Raj) Pan No.: Aabap 8390 A Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri Shrawan Kr. Gupta (Adv) Jktlo Dh Vksj Ls@ Revenue By : Shri B.K. Gupta (Pr.Cit-Dr) Lquokbz Dh Rkjh[K@ Date Of Hearing : 04/08/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 02/11/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. These Are The Appeals Filed By The Assessee Against The Separate Order Of The Ld. Pr.Cit-2, Jaipur All Dated 31/03/2021 Passed U/S 263 Of The Income Tax Act, 1961 (In Short, The Act) For The A.Y. 2010-11 To 2012-13. 2. The Hearing Of The Appeal Was Concluded Through Video Conference In View Of The Prevailing Situation Of Covid-19 Pandemic.

147 rws143(3) dt. 30.06.2017 by taking a reasonable and possible view. Here we want to say that if the ld. AO has not examined the issues and claim of deduction u/s 80P he could have not made the assessment. When the assessee has filed reply on deduction u/s 80P (PB8-11) with all the bank details and income

SHRI HARI RAM YADAV,ALWAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, ALWAR

reassessment or recomputation under section 147, the Assessing Officer shall serve on the assessee a notice requiring him to furnish within such period, as may be specified in the notice, a return of his income ...”. Thus it is evident that whereas section 148 specifically requires serving a notice on the assessee, section 263 simply talks of giving an opportunity

ANIL KUMAR BATAR,SIKAR vs. PCIT-JAIPUR-2, JAIPUR

In the result, the appeal of the assessee is allowed

147 read with section 144B of the\nIncome Tax Act, 1961 on 18.03.2023 at returned income of Rs.\n19,89,250/-. Subsequently, the ld. PCIT on examination of the\nassessment record noted that during the course of survey proceedings, it\nwas found that the firm M/s. Matrix JEE Academy, Sikar runs its\nbusiness from a rented building which was owned

PINK CITY JEWEL HOUSE PRIVATE LIMITED ,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), JAIPUR

u/s 263 by CIT - HELD THAT:- Section 263 of the Act confers power on the CIT to revise an assessment order, subject to certain conditions. Instantly, we are confronted with a situation in which the revision was initiated on the basis of the AO sending a proposal to the CIT and not on the CIT suo motu calling

INCOME TAX OFFICER, JAIPUR vs. KEDIA BUILDERS AND COLONIZERS PRIVATE LIMITED, JAIPUR

In the result, all appeals of the revenue are stands dismissed

u/s 148 of the Act on\n28/03/2019 merely as a process of review, the reassessment is not legally invalid. The\nappellant relied on various judicial decisions that the AO cannot reopen concluded\nassessment merely to re-examine any transaction for non-application of his mind on the\nmaterials already with him.\n\n5.13 The Hon’ble Supreme Court

HARISH JAIN,JAIPUR vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

147 and/or to revise the assessment order under s. 263 of the Act. The scope of the power/jurisdiction under the different provisions of the Act would naturally be different. The power and jurisdiction of the Revenue to deal with a concluded assessment, therefore, must be understood in the context of the provisions of the relevant sections noticed above. While doing

RAM KISHAN VERMA,KOTA vs. PCIT (CIRCLE), JAIPUR

In the result appeal of the assessee in the ITA No

147 and/or to revise the assessment order under s. 263 of the Act. The scope of the power/jurisdiction under the different provisions of the Act would naturally be different. The power and jurisdiction of the Revenue to deal with a concluded assessment, therefore, must be understood in the context of the provisions of the relevant sections noticed above. While doing

HARISH JAIN,KOTA vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

147 and/or to revise the assessment order under s. 263 of the Act. The scope of the power/jurisdiction under the different provisions of the Act would naturally be different. The power and jurisdiction of the Revenue to deal with a concluded assessment, therefore, must be understood in the context of the provisions of the relevant sections noticed above. While doing

MANOJ KUMAR SHARMA,JAIPUR vs. PCIT(CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

147 and/or to revise the assessment order under s. 263 of the Act. The scope of the power/jurisdiction under the different provisions of the Act would naturally be different. The power and jurisdiction of the Revenue to deal with a concluded assessment, therefore, must be understood in the context of the provisions of the relevant sections noticed above. While doing

RAM KISHAN VERMA,KOTA vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

147 and/or to revise the assessment order under s. 263 of the Act. The scope of the power/jurisdiction under the different provisions of the Act would naturally be different. The power and jurisdiction of the Revenue to deal with a concluded assessment, therefore, must be understood in the context of the provisions of the relevant sections noticed above. While doing

RAM KISHAN VERMA,KOTA vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

147 and/or to revise the assessment order under s. 263 of the Act. The scope of the power/jurisdiction under the different provisions of the Act would naturally be different. The power and jurisdiction of the Revenue to deal with a concluded assessment, therefore, must be understood in the context of the provisions of the relevant sections noticed above. While doing