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21 results for “reassessment u/s 147”+ Section 40A(2)(b)clear

Sorted by relevance

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Key Topics

Section 143(3)26Section 14818Addition to Income18Section 153A14Section 14711Section 6810Section 2509Section 10A6Disallowance

ASHOK SHARMA,KOTA vs. DY. COMMISSIONER OF INCOME TAX CIRCLE-2 - KOTA, KOTA

ITA 359/JPR/2024[2014-2015]Status: DisposedITAT Jaipur29 Nov 2024AY 2014-2015
For Appellant: Shri Priyank Kabra (C.A.) (V.C.)For Respondent: Shri Anup Singh (Addl.CIT)
Section 143(3)Section 147Section 40A(3)

section 147\nThe 2nd last para of the 1st page of the Jurisdictional AO's report is a para numbered (i),\nwhich deals with the limitation aspect, does not anywhere contradicts the proviso to\nsection 147 that restricts the ld. AO to take action u/s 147 after a lapse of four years if the\nassessment u/s 143(3) has earlier

SHIVAM READYMIX PRIVATE LIMITED,JAIPUR vs. ACIT, JAIPUR

In the result, the appeal of the assessee is allowed

Showing 1–20 of 21 · Page 1 of 2

5
Search & Seizure5
Reopening of Assessment5
Section 145(3)4
ITA 166/JPR/2025[2012-13]Status: Disposed
ITAT Jaipur
06 Aug 2025
AY 2012-13
For Appellant: Shri Tarun Mittal, CA &For Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR
Section 143(3)Section 147Section 148Section 40A(3)Section 69C

40A(3) and section 69C are\naltogether different and once Id.AO was satisfied that provisions of section\n40A(3) are not applicable (as is evident from show cause notice and assessment\norder), he was duty bound to give opportunity to assessee to furnish explanation\non section 69C before invoking such provisions. It is trite law that assessee\nshould be made

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

ITA 598/JPR/2024[2018-2019]Status: DisposedITAT Jaipur26 Dec 2024AY 2018-2019
For Appellant: Sh. Siddharth Ranka, AdvFor Respondent: \nSh. Saurav Harsh, Adv.&
Section 142(1)Section 143(2)Section 144oSection 14ASection 263Section 69

reassess the earlier\nassessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can't\nusurp the power of the CIT and recommend a revision.\nNo overlapping of powers of the authorities under the Act can be permitted. As the\nrevision proceedings in this case have triggered with the AO sending a proposal

BRIJ BIHARI AGRAWAL,JAIPUR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 1 , JAIPUR

ITA 737/JPR/2023[2013-14]Status: DisposedITAT Jaipur29 Aug 2024AY 2013-14
For Appellant: Shri Tarun Mittal (C.A)For Respondent: Smt. Monisha Choudhary (Addl. CIT)
Section 142(1)Section 147Section 148Section 153ASection 153C

b) a return of income has been furnished by such other person\nbut no notice under sub-section (2) of section 143 has been\nserved and limitation of serving the notice under sub-section\n(2) of section 143 has expired, or\n(c) assessment or reassessment, if any, has been made,\nbefore the date of receiving the books

AMAN EXPORTS INTERNATIONAL,JAIPUR vs. DCIT CIRCLE 1, JAIPUR

In the result, appeal of the assessee is partly allowed

ITA 147/JPR/2023[2012-13]Status: DisposedITAT Jaipur24 Aug 2023AY 2012-13

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

For Appellant: Sh. Manish Tatiwal (CA)For Respondent: Smt. Runi Pal (Addl. CIT) &
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 148Section 40A(3)

B” JAIPUR Jh lanhi xkslkbZ] U;kf;d lnL; ,oa Jh jkBkSM+ deys'k t;arHkkbZ] ys[kk lnL; ds le{k BEFORE: SHRI SANDEEP GOSAIN, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA No. 147/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2012-13 cuke Aman Exports International DCIT, Vs. G-93 Epip Sitapura, Industrial Area Circle

M/S. SILVEX & COMPANY INDIA LTD.,JAIPUR vs. ITO WARD-7(4), JAIPUR

In the result, the appeal of the assessee is allowed and cross appeal of the Revenue is dismissed

ITA 834/JPR/2019[2012-13]Status: DisposedITAT Jaipur28 Oct 2022AY 2012-13
For Appellant: Shri Manish Agarwal(C.A.)For Respondent: Shri P.R. Meena (CIT) a
Section 143(3)Section 145(3)Section 147Section 148Section 250

b), 145. ITO vs Nardev Kumar Gupta (2013) 22 ITR (Trib.) 273 Jaipur ITAT wherein after relying upon a number of judicial pronouncements, it has been held by Hon’ble Bench that once book results are rejected and ad hoc addition has been made applying G P rate , no separate addition u/s 40A(3) can be made by making disallowance

ITO WARD-7(2), JAIPUR, WARD-7(2), JAIPUR vs. M/S. SILVEX & COMPANY G-1/35 TO 37, 47, 48 EPIP, JEWELLERY ZONE, SITAPURA INDUSTRIAL AREA, JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed and cross appeal of the Revenue is dismissed

ITA 845/JPR/2019[2012-13]Status: DisposedITAT Jaipur28 Oct 2022AY 2012-13
For Appellant: Shri Manish Agarwal(C.A.)For Respondent: Shri P.R. Meena (CIT) a
Section 143(3)Section 145(3)Section 147Section 148Section 250

b), 145. ITO vs Nardev Kumar Gupta (2013) 22 ITR (Trib.) 273 Jaipur ITAT wherein after relying upon a number of judicial pronouncements, it has been held by Hon’ble Bench that once book results are rejected and ad hoc addition has been made applying G P rate , no separate addition u/s 40A(3) can be made by making disallowance

INCOME TAX OFFICER, WARD-1-1, KOTA vs. SHRI CHANDI RAM, KOTA

In the result, appeal of the revenue is dismissed

ITA 662/JPR/2018[2012-13]Status: DisposedITAT Jaipur14 Jun 2023AY 2012-13

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

For Appellant: Sh. Siddharth Ranka (Adv.) &For Respondent: Smt Runi Pal (Addl. CIT)
Section 143(3)

reassessment proceedings filed a revised computation offering an additional 0.5% above the originally returned income (accepted by the department with income of Rs 4,67,737/-) and on the interest portion@ 8.5% amounting to Rs. 11,85,314/- thus revising his total income to Rs. 16,82,284)-& passing the additional tax & interest thereon voluntarily. The fact involved was that

WHEATONS DESIGN PRIVATE LIMITED,JAIPUR vs. ACIT / DCIT, CIRCLE -6, JAIPUR, JAIPUR

In the result, appeal of the assessee is allowed

ITA 781/JPR/2025[2014-15]Status: DisposedITAT Jaipur12 Nov 2025AY 2014-15

Bench: The Due Date Of Hearing.”

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Mrs. Anita rinesh, JCIT-DR a
Section 143(3)Section 144BSection 147Section 148Section 250Section 37(1)

reassessment proceedings could not be sustained. Chowgule& Company (P) Ltd. Vs. JCIT &Anr. (2023) 224 DTR 295 (Bombay) (HC) The reasons furnished do not even allege that there was a failure to disclose fully and truly all material facts necessary for the assessees assessment for AY 2012-13. Such failure is an essential jurisdictional parameter that must be fulfilled before

RASHLEELA ENTERPRISES PRIVATE LIMITED, JAIPUR,JAIPUR vs. ACIT CEN CIR 3, JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 1/JPR/2025[2012-13]Status: DisposedITAT Jaipur25 Mar 2025AY 2012-13

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyalrashleela Enterprises Pvt. Ltd., C-5, Krishna Balram, Calgiri Road, Malviya Nagar, Jaipur 302017. Pan No.: Aadcr2594J ...... Appellant Vs.

For Appellant: Mr. Rajeev Sogani, CA, Ld. AR &For Respondent: Mrs. Anita Rinesh, JCIT- Ld. DR
Section 143(3)Section 147Section 148Section 151Section 250Section 35Section 35(1)Section 35(1)(ii)

147 of Income Tax Act, 1961 ("ITA"). The action of the Ld. CIT (A) is illegal, unjustified, arbitrary and against the facts of the case. Relief may please be granted by quashing the reassessment proceedings being illegal and without any basis. 2. In the facts and circumstances of the case and in law, Ld. CIT (A) has erred in confirming

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

Appeal are disposed off and all the appeals of the

ITA 117/JPR/2021[ 2013-14]Status: DisposedITAT Jaipur29 Mar 2022

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

For Appellant: Shri P.C. Parwal, CAFor Respondent: Shri Sanjay Dhariwal, CIT
Section 132(4)Section 143(3)Section 153A

b) The Ld. CIT(A) has erred in law and on facts and has acted whimsically in relyingupon her discretion having no judicial basis for arriving at a GP of 1%. 6 The Ld. CIT (A) has erred in law and has committed a grave error of law in not giving notice to the Assessing Officer as contemplated within

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

Appeal are disposed off and all the appeals of the

ITA 69/JPR/2021[2012-13]Status: DisposedITAT Jaipur29 Mar 2022AY 2012-13

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

For Appellant: Shri P.C. Parwal, CAFor Respondent: Shri Sanjay Dhariwal, CIT
Section 132(4)Section 143(3)Section 153A

b) The Ld. CIT(A) has erred in law and on facts and has acted whimsically in relyingupon her discretion having no judicial basis for arriving at a GP of 1%. 6 The Ld. CIT (A) has erred in law and has committed a grave error of law in not giving notice to the Assessing Officer as contemplated within

M/S AMRAPALI EXPORTS,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2, JAIPUR

In the result, the ground No

ITA 454/JPR/2019[2013-14]Status: DisposedITAT Jaipur05 Jan 2021AY 2013-14
For Appellant: Sh. P. C. Bafna (CA)For Respondent: Smt. Monisha Choudhary (Addl.CIT)
Section 10ASection 143(3)Section 145(3)Section 147Section 148Section 69C

reassessment order u/s 143(3) read with 147 was passed by the Assessing Officer on 13.12.2017 wherein the assessee was found eligible for deduction u/s 10AA to the extent of Rs. 7,21,35,825/- as originally 3 M/s Amrapali Exports, Jaipur Vs. DCIT, Jaipur assessed u/s 143(3) of the Act. However, books of accounts were rejected u/s

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, INCOME TAX OFFICE vs. SHRI SURESH KUMAR GUPTA, SRIGANGANAGAR

In the result the appeal of the revenue in ITA No

ITA 55/JPR/2022[2013-14]Status: DisposedITAT Jaipur24 Aug 2022AY 2013-14
For Appellant: Sh. P. C. Parwal, C.AFor Respondent: Sh. Sanjay Dhariwal, CIT lquo
Section 132Section 143(3)Section 68

Section 263 of the Act were proper and legal and the Tribunal committed a serious error in reversing such decisions. Mr. Arif Ali, learned Advocate appearing for the appellant in ITAT No. 44 of 2020 (Assessee-Gupta Agarwal) submitted that the facts which have been set out in the memorandum of appeal, is wholly incorrect and does not pertain

DEPUTY COMMISSIONER OF INCOME TAX, INCOME TAX DEPARTMENT, CENTRAL CIRCLE-3 vs. M/S N. M. AGROFOOD PRODUCTS PVT. LTD., SRIGANGANAGAR

In the result the appeal of the revenue in ITA No

ITA 54/JPR/2022[2013-14]Status: DisposedITAT Jaipur24 Aug 2022AY 2013-14
For Appellant: Sh. P. C. Parwal, C.AFor Respondent: Sh. Sanjay Dhariwal, CIT lquo
Section 132Section 143(3)Section 68

Section 263 of the Act were proper and legal and the Tribunal committed a serious error in reversing such decisions. Mr. Arif Ali, learned Advocate appearing for the appellant in ITAT No. 44 of 2020 (Assessee-Gupta Agarwal) submitted that the facts which have been set out in the memorandum of appeal, is wholly incorrect and does not pertain

DALAS BIOTECH LIMITED,BHIWADI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, ALWAR

In the result, the appeal of the assessee is allowed with no orders as to cost

ITA 147/JPR/2024[2010-11]Status: DisposedITAT Jaipur30 Sept 2024AY 2010-11

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

For Appellant: Shri Rohit Tiwari, Adv (Physical)For Respondent: Shri Anup Singh, Addl. CIT-DR
Section 131Section 143(3)Section 40Section 68

B’ JAIPUR JhlanhixkslkbZ]U;kf;dlnL; ,oaJhjkBksMdeys'kt;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: SHRI SANDEEP GOSAIN, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA No. 147/JP/2024 fu/kZkj.k o"kZ@Assessment Year : 2010-11 cuke M/s. Dalas Biotech Ltd. The ACIT Vs. E-292, RIICO Industrial Area Alwar Bhiwadi LFkk;h ys[kk la-@thvkbZvkj

SHRI AMBICA GARMENTS, JODHPUR,JODHPUR vs. ACIT, CENTAL CIRCLE-3, JAIPUR, JODHPUR

In the result, all appeals of the assessee are disposed off in terms of

ITA 59/JPR/2025[2017-18]Status: DisposedITAT Jaipur15 Oct 2025AY 2017-18
For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

reassessment cannot be verified. Subject to these observations Shri Ambika Garments vs. ACIT the peak credit as worked out by the assessee at Rs. 36,89,310/- is held as undisclosed income for this year. (iii)………… In the above case the assessment for the AY 2001-02 was done however which was quashed by the honourable Tribunal. Even then

SANJAY KUMAR KARNANI,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

ITA 672/JPR/2025[2015-16]Status: DisposedITAT Jaipur15 Oct 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

reassessment cannot be verified. Subject to these observations Shri Ambika Garments vs. ACIT the peak credit as worked out by the assessee at Rs. 36,89,310/- is held as undisclosed income for this year. (iii)………… In the above case the assessment for the AY 2001-02 was done however which was quashed by the honourable Tribunal. Even then

SANJAY KUMAR KARNANI,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

ITA 673/JPR/2025[2016-17]Status: DisposedITAT Jaipur15 Oct 2025AY 2016-17

Bench: AO on 12-04-2021 18. Reply filed before AO on 15-07-2021 19. Additional Written Submissions filed before CIT(A) for AY 2014-15 on 11-11-2024 20. Written Submissions filed before CIT(A) for AY 2014-15 21. Written Submissions filed before CIT(A) for AY 2015-16 on 10-10-2024 22. Written Submissions filed before CIT(A) for AY 2016-17 on 10-10-2024 23. Written Submissions filed before CIT(A) for AY 2017-18 on 15-10-2024 24. Written Submissions filed before CIT(A) for AY 2018-19 on 15-10-2024 25.

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

reassessment cannot be verified. Subject to these observations Shri Ambika Garments vs. ACIT the peak credit as worked out by the assessee at Rs. 36,89,310/- is held as undisclosed income for this year. (iii)………… In the above case the assessment for the AY 2001-02 was done however which was quashed by the honourable Tribunal. Even then

SHRI AMBICA GARMENTS, JODHPUR,JODHPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

ITA 61/JPR/2025[2019-20]Status: DisposedITAT Jaipur15 Oct 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

reassessment cannot be verified. Subject to these observations Shri Ambika Garments vs. ACIT the peak credit as worked out by the assessee at Rs. 36,89,310/- is held as undisclosed income for this year. (iii)………… In the above case the assessment for the AY 2001-02 was done however which was quashed by the honourable Tribunal. Even then