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

SH. KAPIL TANEJA,JAIPUR vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, JAIPUR

In the result, the appeal of the assessee is allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

70 wherein the apex court has held that ; b. Interplay of Ashish Agarwal with TOLA 31 Sh. Kapil Taneja vs. DCIT 108. The Income-tax Act read with TOLA extended the time limit for issuing reassessment notices under section 148, which fell for completion from 20 March 2020 to 31 March 2021, till 30 June 2021. All the reassessment notices

DCIT, CENTRAL CIRCLE-2, JAIPUR vs. SHRI PRAKASH CHAND KOTHARI, JAIPUR

In the result, appeal of the assessee is allowed

70. The ld A/R in his submissions has however stated that the addition has been made by the Assessing officer by way of undisclosed investment in form of cash loans invoking the provisions of Section 69 and therefore, the burden lies on the Assessing officer to prove that the investment by way of cash loans has infact taken place

SHRI PRAKASH CHAND KOTHARI,JAIPUR vs. DCIT, CENTRAL CIRCLE-2, JAIPUR

In the result, appeal of the assessee is allowed

70. The ld A/R in his submissions has however stated that the addition has been made by the Assessing officer by way of undisclosed investment in form of cash loans invoking the provisions of Section 69 and therefore, the burden lies on the Assessing officer to prove that the investment by way of cash loans has infact taken place

INCOME TAX OFFICER , SIKAR vs. BHASKAR CHAUHAN, JAIPUR

In the result the appeal of the revenue in ITA no

Bench: Him.

reassessment under Sections 139,147,148,149,151 & 153. " In view of the above discussion, the assessment completed u/s 144 deserves to be quashed. The order of the Learned CIT(A) also deserved to be quashed on this ground. Additional Ground No.2 On the facts and in the circumstances of the case and in law, the Learned

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

section 147 r.w.s.144 vide his order dated 28.03.2022 for the\nyear under consideration. Aggrieved by the order of the AO, the assessee preferred\nappeal before the ld. CIT (A), who after considering the contentions of the assessee\nas well as the material available on record, dismissed the appeal of the assessee.\nBeing aggrieved with the order

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

section 147 r.w.s.144 vide his order dated 28.03.2022 for the\nyear under consideration. Aggrieved by the order of the AO, the assessee preferred\nappeal before the ld. CIT (A), who after considering the contentions of the assessee\nas well as the material available on record, dismissed the appeal of the assessee.\n\nBeing aggrieved with the order

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

section 147 r.w.s.144 vide his order dated 28.03.2022 for the\nyear under consideration. Aggrieved by the order of the AO, the assessee preferred\nappeal before the ld. CIT (A), who after considering the contentions of the assessee\nas well as the material available on record, dismissed the appeal of the assessee.\nBeing aggrieved with the order

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

section 147 r.w.s.144 vide his order dated 28.03.2022 for the\nyear under consideration. Aggrieved by the order of the AO, the assessee preferred\nappeal before the ld. CIT (A), who after considering the contentions of the assessee\nas well as the material available on record, dismissed the appeal of the assessee.\nBeing aggrieved with the order

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

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

reassessment under Section 147, 148 & 148A of the Act in a faceless manner. Proceedings under Section 147 and Section 148 of the Act would now have to be taken as per the 34 ITA No. 656/JP/2023 & CO No. 06/JP/2023 ITO vs. Mukesh Kumar Soni procedure legislated by the Parliament in respect of reopening/ re-assessment i.e., proceedings under Section 148A

LATE SHRI JITENDRA NAGAR THROUGH HIS L/R SMT. DEEPIKA NAGAR,BARAN vs. INCOME TAX OFFICER WARD BARAN, BARAN

In the result, appeal of the assessee is allowed

Bench: The Date Of Hearing.”

147 read with section 144B and (ii) notice issued 36 Late Shri Jitendra Nagar through L/R Smt. Deepika Nagar, Baran. u/s 148 by the ld. Assessing officer is without proper approval and satisfaction of higher authority u/s 151 of the Act and entire proceeding is void-ab-initio. Both these grounds are inter-related, inter-connected, therefore, these grounds

INCOME TAX OFFICER (EXEMPTION), JAIPUR vs. M/S APOLLO ANIMAL MEDICAL GROUP TRUST, JAIPUR

In the result, the grounds of appeal taken by the Revenue are dismissed

70 (Guj) 8. It was further submitted that the details on the basis of which reasons were framed were duly placed on record during the original assessment proceedings u/s 143(3) and only after duly considering the same, ld. AO in the assessment proceedings u/s 143(3), allowed the assessee trust benefit of section 11 and 12. Therefore, while framing

VINITA BAJORIA,JAIPUR vs. INCOME-TAX OFFICER, JAIPUR

In the result, the appeal of the assessee is allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकर अपील सं./ITA No. 370/JP/2025 निर्धारण वर्ष / Assessment Year : 2016-17 Vinita Bajoria 1, Ganesh Colony Moti Doongri Road, Jaipur बनाम Income Tax Officer, Ward 5(2), Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AEBPB4873M अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by: Sh. Manoj Choudhary, CA राजस्व की ओर से / Revenue by : Sh. Gorav Avasthi, JCIT सुनवाई की तारीख / Date of Hear

section 147, and • The reassessment order passed u/s 147 r.w.s. 144 be kindly held to be without jurisdiction, bad in law and liable to be quashed. 6. To support the contention so raised in the written submission reliance was placed on the following evidence / records / decisions: S. No. Particulars Page Nos. 1. Synopsis of the Case

WHOLE SALE CLOTH MERCHANT ASSOCIATION ,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE KOTA , KOTA

In the result, the appeals of the assessee in ITA no

147\nof the Act. Therefore, the argument of the appellant are not found to be\nacceptable.\nFurther the addition made by the AO are based on return filed in response to\nnotice issued u/s 148. Before the notice, there was no return filed by the\nassessee. Therefore, the notice issued u/s 148 is found to be valid. The\nappellant

SONU AGARWAL ,JAIPUR vs. INCOME TAX OFFICER WARD 1(3), JAIPUR

In the result, the appeal of the assessee is allowed

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

147 r.w.s 144B along with all consequential additions be quashed. 3. Any other relief deemed fit in the interest of justice may please be granted.” The ld. AR further filed the Paper Book in support of his case as under :- PAPER BOOK S.No. Particular Page No. From To 1. Written Submission. 01 12 2. Copy of Notice dated 08.04.2021 issued

AJAY BAKLIWAL,KOTA vs. ACIT, CENTRAL CIRCLE, KOTA, KOTA

reassessment proceedings initiated under Section 148 be upheld as valid\nand in accordance with the law.\n2. The addition of ₹44,62,938/- under Section 2(22)(e) be upheld, as the\nAppellant has failed to disprove the findings of the AO.\n3.\nThe appeal of the Appellant be dismissed, and the order of the Ld. CIT(A)\nbe upheld

SHRI SATYA NARAYAN BAIRWA,JAIPUR vs. INCOME TAX OFFICER, WARD-2(4), JAIPUR

In the result, both these appeals of the assessee are allowed

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 867 & 869/Jp/2018 Fu/Kzkj.K O"Kz@Assessment Years :2008-09 & 2009-10 Cuke Shri Satya Narayan Bairwa, I.T.O., Vs. 97/77, Shipra Path, Ward-2(4), Mansarovar, Jaipur (Raj). Jaipur. Lfkk;H Ys[Kk La-@Thvkbzvkj La-@Pan/Gir No.: Ahppb 0077 J Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri Shravan Kumar Gupta (Adv.) Jktlo Dh Vksj Ls@ Revenue By : Smt. Runi Pal (Addl.Cit) Lquokbz Dh Rkjh[K@ Date Of Hearing : 20/07/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 15/09/2021 Vkns'K@ Order

147 of the Acdt is barred by limitation. The ld AR appearing on behalf of the assessee has reiterated the same arguments as were raised before the ld. CIT(A) and also relied on the written submissions filed before the Bench and the submissions qua the issue under consideration are as under: 6 ITA 867 & 869/JP/2018_ Sh. Satya Narayan Bairwa

SHRI SATYA NARAYAN BAIRWA,JAIPUR vs. INCOME TAX OFFICER, WARD-2(4), JAIPUR

In the result, both these appeals of the assessee are allowed

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 867 & 869/Jp/2018 Fu/Kzkj.K O"Kz@Assessment Years :2008-09 & 2009-10 Cuke Shri Satya Narayan Bairwa, I.T.O., Vs. 97/77, Shipra Path, Ward-2(4), Mansarovar, Jaipur (Raj). Jaipur. Lfkk;H Ys[Kk La-@Thvkbzvkj La-@Pan/Gir No.: Ahppb 0077 J Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri Shravan Kumar Gupta (Adv.) Jktlo Dh Vksj Ls@ Revenue By : Smt. Runi Pal (Addl.Cit) Lquokbz Dh Rkjh[K@ Date Of Hearing : 20/07/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 15/09/2021 Vkns'K@ Order

147 of the Acdt is barred by limitation. The ld AR appearing on behalf of the assessee has reiterated the same arguments as were raised before the ld. CIT(A) and also relied on the written submissions filed before the Bench and the submissions qua the issue under consideration are as under: 6 ITA 867 & 869/JP/2018_ Sh. Satya Narayan Bairwa

RSD CONTAINERS PRIVATE LIMITED,JAIPUR vs. ITO, WARD 7(1), JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

reassessment proceedings and the Assessment Order, dated 11.05.2023, passed under Section 147 read with Section 144B of the Act are quashed. 10 Even if the argument of the revenue is accepted that the since the time limit for issuance of notice was not expired in this case being A. Y. 2017-18 the notice issued u/s. 148 dated