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34 results for “reassessment u/s 147”+ Section 50Cclear

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Key Topics

Section 14738Section 14832Addition to Income32Section 14431Section 143(3)21Section 153C16Section 50C16Natural Justice13Section 142(1)

INCOME TAX OFFICER, WARD-1(2), JAIPUR, JAIPUR vs. MUKESH KUMAR SONI, JAIPUR

In the result appeal of the revenue is dismissed and the cross

ITA 656/JPR/2023[2018-19]Status: DisposedITAT Jaipur04 Mar 2024AY 2018-19

Bench: Moving Towards The Facts Of The Case We Would Like To Mention

For Appellant: Sh. S. B. Natani (FCA)For Respondent: Sh. Arvind Kumar (CIT)
Section 143(1)Section 143(3)Section 144BSection 147Section 148A

u/s 148 he accepts the contention of the assessee and holds that the income for which he had initially formed a reason to believe that income has escaped assessment has as a matter of fact not escaped assessment, it is not open to him to independently assess some other income. And if he intends to do so a fresh notice

Showing 1–20 of 34 · Page 1 of 2

12
Section 16310
Limitation/Time-bar7
Deduction7

SUVA LAL PAHARIA,JAIPUR vs. ITO WARD 6(3), JAIPUR

ITA 157/JPR/2024[2008-09]Status: DisposedITAT Jaipur24 Jun 2024AY 2008-09
For Appellant: Sh. Shrawan Kumar Gupta (Adv.) &For Respondent: Smt. Monisha Chaudhary (Addl.CIT)
Section 144Section 147Section 5

147 was unsustainable because it was not approved by the\ncompetent authority in accordance with Section 151—CIT(A) sanctioned re-assessment\nproceedings through issuance of notice u/s 148—ITAT's allowed assessee's appeal by holding\nthat the CIT lacked the authority to sanction re-assessment proceedings through issuance of\nnotice u/s 148—Held, Privy Council in Nazir Ahmad

SHRI BANWARI LAL SHARMA,JAIPUR vs. INCOME TAX OFFICER, WARD-1-5, JAIPUR

In the result, both the appeals filed by the assessee and Revenue are disposed off in light of aforesaid directions

ITA 475/JPR/2019[2008-09]Status: DisposedITAT Jaipur14 Jun 2021AY 2008-09
For Appellant: Shri Manish Agarwal (CA)For Respondent: Smt Monisha Choudhary (Jt.CIT)
Section 144Section 147Section 160Section 163

reassessment.] 21. It was submitted that section 292BB is an exclusive definition and specifically provides that a notice shall be deemed to be served in a situation that assessee has cooperated/ attended / participated in assessment/ re assessment proceedings and no objection regarding non receipt of notice was filed during assessment stage. In other words, section 292BB cures only procedural infirmities

INCOME TAX OFFICER, WARD-1-5, JAIPUR vs. SHRI BANWARI LAL SHARMA, JAIPUR

In the result, both the appeals filed by the assessee and Revenue are disposed off in light of aforesaid directions

ITA 558/JPR/2019[2008-09]Status: DisposedITAT Jaipur14 Jun 2021AY 2008-09
For Appellant: Shri Manish Agarwal (CA)For Respondent: Smt Monisha Choudhary (Jt.CIT)
Section 144Section 147Section 160Section 163

reassessment.] 21. It was submitted that section 292BB is an exclusive definition and specifically provides that a notice shall be deemed to be served in a situation that assessee has cooperated/ attended / participated in assessment/ re assessment proceedings and no objection regarding non receipt of notice was filed during assessment stage. In other words, section 292BB cures only procedural infirmities

SIYARAM EXPORTS INDIA PVT. LTD.,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR

ITA 440/JPR/2018[2013-14]Status: DisposedITAT Jaipur30 Dec 2024AY 2013-14
For Appellant: Shri Rohan Sogani (C.A.)For Respondent: Shri Arvind Kumar (CIT-DR)
Section 142(1)Section 143(3)Section 144Section 153ASection 50C

50C(2) - Whether it was incumbent upon Assessing\nOfficer to refer matter for valuation to a Valuation\nOfficer as provided in section\n50C(2) - Held, yes..\"\n\n22. As per explanation (iia) to section 153B of the Income Tax Act, 1961, in computing the\nperiod of limitation of assessment u/s 153A the following period shall be excluded

SIYARAM EXPORTS INDIA PRIVATE LIMITED,JAIPUR vs. ITO WARD 6(4), JAIPUR, JAIPUR

ITA 151/JPR/2024[2013-14]Status: DisposedITAT Jaipur30 Dec 2024AY 2013-14
For Appellant: Shri Rohan Sogani (C.A.)For Respondent: Shri Arvind Kumar (CIT-DR)
Section 142(1)Section 143(3)Section 144Section 153ASection 50C

reassessment\nproceedings. The assessee is also directed to cooperate fully during the\nproceedings.\nIn view of the above, appeals of the assessee is allowed for statistical purpose.\nSHANTINATH BUILDCON PRIVATE LIMITED: ITA NO. 467/JPR/2018\n(AY 2012-13)\n68. The appeal has been preferred by assessee company against the order passed\nby the CIT(A)-4, Jaipur

SHRI SATISH CHANDRA KATTA,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR

ITA 438/JPR/2018[2012-13]Status: DisposedITAT Jaipur31 Dec 2024AY 2012-13
For Appellant: Shri Rohan Sogani (C.A.)For Respondent: Shri Arvind Kumar (CIT-DR)
Section 142(1)Section 143(3)Section 144Section 153ASection 50C

reassessment\nproceedings. The assessee is also directed to cooperate fully during the\nproceedings.\nIn view of the above, appeals of the assessee is allowed for statistical purpose.\nSHANTINATH BUILDCON PRIVATE LIMITED: ITA NO. 467/JPR/2018\n(AY 2012-13)\n68. The appeal has been preferred by assessee company against the order passed\nby the CIT(A)-4, Jaipur

RAM SHRAN KATTA, 257, KATTA STREET, JAIN MANDIR WALI GALI, DURGAPURA, JAIPUR,JAIPUR vs. ITO WARD-6(4), JAIPUR

In the result, the appeals of the assessee are allowed

ITA 623/JPR/2019[2010-11]Status: DisposedITAT Jaipur30 Dec 2024AY 2010-11
For Appellant: Shri Rohan Sogani (C.A.)For Respondent: Shri Arvind Kumar (CIT-DR)
Section 132Section 153ASection 153CSection 50C

147, section 148, section\n149, section 151 and section 153, where the Assessing Officer is satisfied thatany money,\nbullion, jewellery or other valuable article or thing or books of account or documents,\nseized or requisitioned, belongs or belong to a person other than the person referred to in\nsection 153A, then, the books of account or documents or assets, seized

RAM SHARAN KATTA, 257, KATTA STREET, JAIN MANDIR WALI GALI, DURGAPURA, JAIPUR,JAIPUR vs. ITO WARD-6(4), JAIPUR, WARD-6(4), JAIPUR

In the result, the appeals of the assessee are allowed

ITA 622/JPR/2019[2009-10]Status: DisposedITAT Jaipur30 Dec 2024AY 2009-10
For Appellant: Shri Rohan Sogani (C.A.)For Respondent: Shri Arvind Kumar (CIT-DR)
Section 132Section 153ASection 153CSection 50C

147, section 148, section\n149, section 151 and section 153, where the Assessing Officer is satisfied thatany money,\nbullion, jewellery or other valuable article or thing or books of account or documents,\nseized or requisitioned, belongs or belong to a person other than the person referred to in\nsection 153A, then, the books of account or documents or assets, seized

BRIGHT SECURITIES PRIVATE LIMITED,JAIPUR vs. INCOME TAX OFFICER, JAIPUR

In the result, the appeals of the assessee are allowed with no order as to\ncosts

ITA 465/JPR/2024[2013-14]Status: DisposedITAT Jaipur15 Jul 2024AY 2013-14
For Appellant: Shri S.L. Poddar, AdvocateFor Respondent: Shri Rajesh Kumar Meena, Addl. CIT-DR
Section 144BSection 147Section 148

sections 147, 148 of\nthe Income-tax Act, 1961, no fault can be found,\n7.7 Similarly, Hon'ble Bombay High Court in the case of Hede\nFerrominas Pvt. Lt reported in 147 taxmann.com 215 (Bombay) had\noccasion to examine whether there was sufficient material to form a\nreasonable belief that appellant's income had escaped assessment. The\nrelevant para

RAMA SHANKER PAREEK,JAIPUR vs. INCOME TAX OFFICER, WARD NO. 7(2), JAIPUR

In the result, appeal of the assessee is allowed

ITA 253/JPR/2025[2010-11]Status: DisposedITAT Jaipur24 Jun 2025AY 2010-11
For Appellant: Shri Shrawan Kumar Gupta, AdvocateFor Respondent: Shri Gautam Singh Choudhary, Addl.CIT
Section 142(1)Section 147Section 148Section 234ASection 250Section 69CSection 80C

section 50C of the Act. The reasons recorded nowhere\nmentioned this possibility. Reasons recorded, in fact, ignored the fact that the sale\nconsideration as per the sale deed was Rs.50 lakhs and that the assessee had by\nfiling the return offered his share of such proceeds by way of capital gain.\"\n1.2.2 In the case of Vijay Harish Chandra Patel

OM PRAKASH AGRAWAL HUF,JAIPUR vs. ITO WARD 5(1), JAIUPR, JAIPUR

ITA 967/JPR/2024[2012-13]Status: DisposedITAT Jaipur09 Sept 2024AY 2012-13
For Appellant: Sh. Sarwan Kumar Gupta (Adv.)For Respondent: Smt. Monisha Choudhary (Addl.CIT)
Section 143(3)Section 147Section 148Section 234A

section 50C of the Act would\napply, of course, subject to the riders contained therein. However, this is\nnot the cited reason for reopening the assessment. The reasons cited\nare that the assessee filed no return and that 1/3rd share of the\nassessee from the actual sale consideration of Rs. 1,18,95,000/-\ntherefore, was not brought

AVG CONSTRUCTION PVT. LTD,JAIPUR vs. ITO, WARD-6(2), JAIPUR

ITA 90/JPR/2020[2011-12]Status: DisposedITAT Jaipur02 Sept 2021AY 2011-12

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 90/Jp/2020 Assessment Year: 2011-12 Avg Construction Pvt. Ltd., Cuke I.T.O. 1St Floor, Trade Center No. 10, Opp. Vs. Ward-6(2), Jp Underpass, Sahkar Marg, Lal Jaipur. Kothi, Jaipur. Pan No.: Aadca 2264 J Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri Ashok Kr. Gupta (Adv) Jktlo Dh Vksj Ls@ Revenue By : Smt. Monisha Choudhary (Jcit) Lquokbz Dh Rkjh[K@ Date Of Hearing : 04/08/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 02/09/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. The Present Appeal Has Been Filed By The Assessee Against The Order Of The Ld. Cit(A)-2, Jaipur Dated 13/12/2019 For The A.Y. 2011-12. In This Appeal, The Assessee Has Only Challenged Ground No. 4 Before Us, Which Reads As Under: “4. The Addition Made On Other Issues Which Were Different From The Issues On Which Reassessment Proceedings Initiated; The Ld. Cit(A) Has Grossly Erred In Confirming The Action Of Ld. Ao In Making Additions In Respect Of Issues In Respect Of Which Proceedings Were Not Initiated & No Additions Were Made On The Issues On Which Re-Assessment Proceedings Were Initiated.”

For Appellant: Shri Ashok Kr. Gupta (Adv)For Respondent: Smt. Monisha Choudhary (JCIT)
Section 133(6)Section 142(1)Section 143(2)Section 148Section 500Section 50C

50C is 12,00,064/- and sales value of Rs. 19,51,000/- valued u/s 500 is 21,83,258/- which copies of registration deed existed on page no. 62 of PB-I and page no. 110 of PB-II respectively. Thereby by this reply it has been established that questioned transaction of immovable properties have been sufficiently included under

ASHOK KUMAR JAIN,KOTA vs. ITO WD-2(1), KOTA, KOTA

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

ITA 1225/JPR/2024[2015-16]Status: DisposedITAT Jaipur18 Mar 2025AY 2015-16
For Appellant: Sh. Mahendra Gargieya, Adv.& Sh. Devang Gargieya, AdvFor Respondent: Sh. Gautam Singh Choudhary, JCIT
Section 147Section 250Section 253(3)Section 5

50C of\nthe Act.\n6.3 Ld. AO further noted that the assessee claimed expenses of Rs.9,31,742/-\n(after indexation) for the construction, payment made to the various parties. For\nthat vide notice u/s 142(1), assessee was requested to submit the PAN of the\nparties, their address and documentary evidence showing payment made. Assessee\nhas submitted

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

147 r.w.s. 144 r.w.s. 144B of the Act. The appellant has not produced any material to controvert the finding of AO with any document, evidence which he could rely upon. It has been recorded by the AO that the appellant did not file any return in response to notice u/s 148.On the facts and circumstances, the appellant has not made

DINESH AGARWAL,JAIPUR vs. DCIT CIR-6, JAIPUR

ITA 17/JPR/2022[2008-09]Status: DisposedITAT Jaipur30 Jun 2023AY 2008-09

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

For Appellant: Shri Shrawan Kumar Gupta (C.A.)For Respondent: Mrs Monisha Choudhary (Addl.CIT)
Section 147Section 148Section 50C

Section 50C as inserted w.e.f. 01.04.2021 (as clarificatory nature), up to 10% excess valuation as made by Stamp Valuation Authority is permitted under the eyes of exchequer, therefore complete additions should be deleted. 5. Under the facts & Circumstances the learned AO was not justified in charging interest u/s 234A & 234B 2.1 Apropos Ground of appeal

JAIPRAKASH YADAV,ALWAR vs. INCOME TAX OFFICER, WD, BEHROR, BEHROR

In the result, the appeal of the assessee is allowed

ITA 18/JPR/2025[2016-17]Status: DisposedITAT Jaipur15 Jul 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Pranav Yadav, Adv. (Thr.VC)For Respondent: Shri Gaurav Awasthi, JCIT, Sr. DR
Section 147Section 148Section 151Section 56(2)(vii)Section 69Section 69A

section 147, of the Income-tax Act, 1961 - Cash credit (Accommodation entry) Assessment vear 2008-09 Information was received from investigation wing that assessee-company was a beneficiary of accommodation entries received from certain established entry operators During investigation, it was found that entry operators were engaged in money laundering business for beneficiaries - According to Assessing Officer, sources of transactions

MACRO PROPRIETIES PRIVATE LIMITED,M 28 INCOME TAX COLONY TONK ROAD JAIPUR vs. DCIT CENTRAL CIRCLE 2, LIC BUILDING JAIPUR

In the result, the appeals of the assessee are allowed

ITA 174/JPR/2023[2013-2014]Status: DisposedITAT Jaipur17 Jul 2023AY 2013-2014

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;djvihy la-@ITA No.174 TO 177/JP/2023 fu/kZkj.ko"kZ@AssessmentYear : 2013-14 TO 2016-17 M/s. Macro Properties Pvt. Ltd.M-28, Income Tax Colony, Tonk Road Jaipur cuke Vs. The DCIT Central Circle-2 LIC Building, Jaipur LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAFCM 3633 D vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksjls@Assesseeby : Shri C.M. Agarwal, CA jktLo dh vksjls@Revenue by: Shri JameshKurian, CI

For Appellant: Shri C.M. Agarwal, CAFor Respondent: Shri JameshKurian, CIT
Section 153CSection 50C(1)Section 69

50C(1) of the LT. Act. 1961, arbitrarily, thus the value so adopted deserves to be hold bad in law. Ground No. 4: On facts and in circumstances of the matter, the Ld. AO erred in making addition of Rs. 3,68,874/- u/s 69 on account of alleged investment in property, arbitrarily. Thus the addition so made deserve

INCOME TAX OFFICE, WARD-6(2), JAIPUR, JAIPUR vs. MEDICAL DESIGNS INDIA PVT. LTD., JAIPUR

ITA 236/JPR/2024[2011-12]Status: DisposedITAT Jaipur27 Sept 2024AY 2011-12
For Appellant: Shri Ratan Lal Goyal (C.A.) &For Respondent: Shri Arvind Kumar (CIT)
Section 127Section 142(1)Section 144Section 147Section 148

147, Subh Infrastructure 398 ITR 198 and Pr. CIT Vs. RMC Polyvinyl (I) Ltd.\n396 ITR 5 wherein the Delhi High Court has held that observations of the\nInvestigation Wing should not be treated as conclusions without the AO\nindependently verifying the same in the absence of which the Hon'ble Court\nheld that the reopening of assessment

MACRO TOWNSHIP PVT LTD,288-289 MAHAVEER NAGAR DURGAPURA JAIPUR vs. DCIT CC -2 JAIPUR, LIC BUILDING JAIPUR

In the result, the appeals of the assessee are allowed

ITA 399/JPR/2023[2015-16]Status: DisposedITAT Jaipur05 Dec 2023AY 2015-16

Bench: HON’BLE SHRI SANDEEP GOSAIN, JM & HON’BLE SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri C.M. Agarwal, CAFor Respondent: Shri Arvind Kumar (CIT)
Section 153CSection 250Section 69

50C(1) of the LT. Act. 1961, arbitrarily, thus the value so adopted deserves to be hold bad in law. Ground No. 4: On facts and in circumstances of the matter, the Ld. AO erred in making addition of Rs. 15,00,000/- u/s 68 by treating the loan taken from M/s. Gemini Commerce Pvt. Ltd. as accommodation entry arbitrarily