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

In the result appeal of the assessee in the ITA No

275 ITR 113 (All) dissented from.” 9.6 Easy Transcription & Software (P) Ltd. (2017) 185 TTJ 504 (Ahd) “Revision—Jurisdiction of CIT—Jurisdiction to direct AO to initiate penalty proceedings under s. 271(1)(c)—It is not open to CIT to exercise the revisional powers to create a non-existent proceeding under s. 263by holding the assessment as erroneous

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

In the result appeal of the assessee in the ITA No

275 ITR 113 (All) dissented from.” 9.6 Easy Transcription & Software (P) Ltd. (2017) 185 TTJ 504 (Ahd) “Revision—Jurisdiction of CIT—Jurisdiction to direct AO to initiate penalty proceedings under s. 271(1)(c)—It is not open to CIT to exercise the revisional powers to create a non-existent proceeding under s. 263by holding the assessment as erroneous

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

In the result appeal of the assessee in the ITA No

275 ITR 113 (All) dissented from.” 9.6 Easy Transcription & Software (P) Ltd. (2017) 185 TTJ 504 (Ahd) “Revision—Jurisdiction of CIT—Jurisdiction to direct AO to initiate penalty proceedings under s. 271(1)(c)—It is not open to CIT to exercise the revisional powers to create a non-existent proceeding under s. 263by holding the assessment as erroneous

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

In the result appeal of the assessee in the ITA No

275 ITR 113 (All) dissented from.” 9.6 Easy Transcription & Software (P) Ltd. (2017) 185 TTJ 504 (Ahd) “Revision—Jurisdiction of CIT—Jurisdiction to direct AO to initiate penalty proceedings under s. 271(1)(c)—It is not open to CIT to exercise the revisional powers to create a non-existent proceeding under s. 263by holding the assessment as erroneous

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

In the result appeal of the assessee in the ITA No

275 ITR 113 (All) dissented from.” 9.6 Easy Transcription & Software (P) Ltd. (2017) 185 TTJ 504 (Ahd) “Revision—Jurisdiction of CIT—Jurisdiction to direct AO to initiate penalty proceedings under s. 271(1)(c)—It is not open to CIT to exercise the revisional powers to create a non-existent proceeding under s. 263by holding the assessment as erroneous

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

In the result appeal of the assessee in the ITA No

275 ITR 113 (All) dissented from.” 9.6 Easy Transcription & Software (P) Ltd. (2017) 185 TTJ 504 (Ahd) “Revision—Jurisdiction of CIT—Jurisdiction to direct AO to initiate penalty proceedings under s. 271(1)(c)—It is not open to CIT to exercise the revisional powers to create a non-existent proceeding under s. 263by holding the assessment as erroneous

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

In the result appeal of the assessee in the ITA No

275 ITR 113 (All) dissented from.” 9.6 Easy Transcription & Software (P) Ltd. (2017) 185 TTJ 504 (Ahd) “Revision—Jurisdiction of CIT—Jurisdiction to direct AO to initiate penalty proceedings under s. 271(1)(c)—It is not open to CIT to exercise the revisional powers to create a non-existent proceeding under s. 263by holding the assessment as erroneous

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

In the result appeal of the assessee in the ITA No

275 ITR 113 (All) dissented from.” 9.6 Easy Transcription & Software (P) Ltd. (2017) 185 TTJ 504 (Ahd) “Revision—Jurisdiction of CIT—Jurisdiction to direct AO to initiate penalty proceedings under s. 271(1)(c)—It is not open to CIT to exercise the revisional powers to create a non-existent proceeding under s. 263by holding the assessment as erroneous

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

In the result appeal of the assessee in the ITA No

275 ITR 113 (All) dissented from.” 9.6 Easy Transcription & Software (P) Ltd. (2017) 185 TTJ 504 (Ahd) “Revision—Jurisdiction of CIT—Jurisdiction to direct AO to initiate penalty proceedings under s. 271(1)(c)—It is not open to CIT to exercise the revisional powers to create a non-existent proceeding under s. 263by holding the assessment as erroneous

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

In the result appeal of the assessee in the ITA No

275 ITR 113 (All) dissented from.” 9.6 Easy Transcription & Software (P) Ltd. (2017) 185 TTJ 504 (Ahd) “Revision—Jurisdiction of CIT—Jurisdiction to direct AO to initiate penalty proceedings under s. 271(1)(c)—It is not open to CIT to exercise the revisional powers to create a non-existent proceeding under s. 263by holding the assessment as erroneous

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

In the result appeal of the assessee in the ITA No

275 ITR 113 (All) dissented from.” 9.6 Easy Transcription & Software (P) Ltd. (2017) 185 TTJ 504 (Ahd) “Revision—Jurisdiction of CIT—Jurisdiction to direct AO to initiate penalty proceedings under s. 271(1)(c)—It is not open to CIT to exercise the revisional powers to create a non-existent proceeding under s. 263by holding the assessment as erroneous

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

In the result appeal of the assessee in the ITA No

275 ITR 113 (All) dissented from.” 9.6 Easy Transcription & Software (P) Ltd. (2017) 185 TTJ 504 (Ahd) “Revision—Jurisdiction of CIT—Jurisdiction to direct AO to initiate penalty proceedings under s. 271(1)(c)—It is not open to CIT to exercise the revisional powers to create a non-existent proceeding under s. 263by holding the assessment as erroneous

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

In the result appeal of the assessee in the ITA No

275 ITR 113 (All) dissented from.” 9.6 Easy Transcription & Software (P) Ltd. (2017) 185 TTJ 504 (Ahd) “Revision—Jurisdiction of CIT—Jurisdiction to direct AO to initiate penalty proceedings under s. 271(1)(c)—It is not open to CIT to exercise the revisional powers to create a non-existent proceeding under s. 263by holding the assessment as erroneous

ISYS SOFTECH PRIVATE LIMITED,JAIPUR vs. CIT (A), JAIPUR, JAIPUR

In the result, appeal of the assessee is allowed

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

275(1)(c) of the Act. Therefore, this ground of appeal is dismissed. 7. In the result, the appeal of the appellant is dismissed. ” 5. As the assessee did not find any favor from the appeal so filed before the ld. CIT(A) the assessee has preferred the present appeal. The ld. AR of the assessee in support

RMS KARAMCHARI BACHAT AND SAKH SAHAKARI SAMITI LIMITED JAIPUR,JAIPUR vs. ITO WARD-1(2), JAIPUR, JAIPUR

In the result, the appeals of the assessee are allowed

C\nAgarwal, so called mediator in these transactions. Given that search proceedings\nin respect of these two persons have formed the basis for the present reassessment\nproceedings in the hands of the assessee, it was essential to at least examine the\nstatements of these three persons and seized material if any found during the\ncourse of search which

RMS KARAMCHARI BACHAT AND SAKH SAHAKARI SAMITI LIMITED JAIPUR,JAIPUR vs. ITO WARD-1(2), JAIPUR, JAIPUR

In the result, the appeals of the assessee are allowed

C\nAgarwal, so called mediator in these transactions. Given that search proceedings\nin respect of these two persons have formed the basis for the present reassessment\nproceedings in the hands of the assessee, it was essential to at least examine the\nstatements of these three persons and seized material if any found during the\n\n12\nITA No. 243 Το

RMS KARAMCHARI BACHAT AND SAKH SAHAKARI SAMITI LIMITED JAIPUR,JAIPUR vs. ITO WARD-1(2), JAIPUR, JAIPUR

In the result, the appeals of the assessee are allowed

C\nAgarwal, so called mediator in these transactions. Given that search proceedings\nin respect of these two persons have formed the basis for the present reassessment\nproceedings in the hands of the assessee, it was essential to at least examine the\nstatements of these three persons and seized material if any found during the\ncourse of search which

RMS KARAMCHARI BACHAT AND SAKH SAHAKARI SAMITI LIMITED JAIPUR,JAIPUR vs. ITO, WARD-1(2), JAIPUR, JAIPUR

In the result, the appeals of the assessee are allowed

C\nAgarwal, so called mediator in these transactions. Given that search proceedings\nin respect of these two persons have formed the basis for the present reassessment\nproceedings in the hands of the assessee, it was essential to at least examine the\nstatements of these three persons and seized material if any found during the\n12\nITA No. 243 Το 246/JPR/2025