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

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

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

d)alleged cash deposits of ₹70,92,789/-.\nHowever, in the assessment order ultimately passed, no addition on account of such\nalleged deposits was made. Instead, the AO proceeded to disallow deduction u/s 80P\namounting to ₹14,38,852/-, solely on the ground that no return of income had been filed\nand that deductions under Chapter VI-A, including

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

d)alleged cash deposits of ₹70,92,789/-.\nHowever, in the assessment order ultimately passed, no addition on account of such\nalleged deposits was made. Instead, the AO proceeded to disallow deduction u/s 80P\namounting to ₹14,38,852/-, solely on the ground that no return of income had been filed\nand that deductions under Chapter VI-A, including

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

d)alleged cash deposits of ₹70,92,789/-.\nHowever, in the assessment order ultimately passed, no addition on account of such\nalleged deposits was made. Instead, the AO proceeded to disallow deduction u/s 80P\namounting to ₹14,38,852/-, solely on the ground that no return of income had been filed\nand that deductions under Chapter VI-A, including

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

d)alleged cash deposits of ₹70,92,789/-.\nHowever, in the assessment order ultimately passed, no addition on account of such\nalleged deposits was made. Instead, the AO proceeded to disallow deduction u/s 80P\namounting to ₹14,38,852/-, solely on the ground that no return of income had been filed\nand that deductions under Chapter VI-A, including

M/S JAIPUR ZILA DUGDH UTPADAK SAHKARI SANGH LTD.,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6, JAIPUR

In the result, the appeals of the assessee are allowed for A

147 of the Act (only for A.Y 2011-12- & 2012- 13). (ii) Whether the ld. CIT(A) has erred on facts and in law in allowing deduction u/s 80P (2)(d) of the Act on proportionate basis instead of on the entire 3. On the first issue which relates to AY 2011-12 & 2012-13 where assessee has challenged

INCOME TAX OFFICER, RAWATBHATA ROAD vs. BOREKHEDA GRAM SEWA SAHAKARI SAMITI, HEAD OFFICE NEAR DWARKADIS

In the result, the appeal of the Revenue is dismissed

Bench: SHRI SANDEEP GOSAIN (Judicial Member), DR DIPAK P. RIPOTE (Accountant Member)

u/s 80P(2)(d) of the Act. Thus, irregular allowance of deduction resulted in under computation of income of assessee by Rs.1,67,51,945/- involving under charge of tax of Rs.75,73,002/- On the basis of above facts, I have reason to believe that incone amounting Re. 1,67,61,045/- has escaped assessment within the meaning

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

SAJJAD ALI,CHITTORGARH vs. DCIT(INTL)- JAIPUR, JAIPUR

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

147 r.w.s. 144 of the Act, by the DCIT, Circle (Intl. Tax), Jaipur. 2. Assessee challenged the order of the CIT(IT)-Delhi-1 by raising the following grounds of appeal; “1. That the Impugned order u/s 263 of the Act dated 27.03.2024 and notice u/s 263 are bad in law and on facts of the case and hence

SOYALA GRAM SEWA SAHAKARI SAMITI LIMITED,TONK vs. ITO, TONK, TONK

In the result, appeal of the assessee is allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

147 permits the AO to assess or reassess the income in respect of any issue which has escaped assessment and such issues which comes to his notice subsequently in the course of proceedings under this section. The second limb of this proviso i.e. for assessing other issues can only be invoked if first limb is satisfied i.e. when an addition

NIRMAL KUMAR AGRAWAL,JAIPUR vs. DCIT, CIRCLE - 4 , JAIPUR

In the result, the appeal of the assessee is allowed

80P - Assessee against impugned order filed appeal before Commissioner (Appeals) with a delay of 11 days and sought condonation of delay in filing appeal stating that delay was due to non-availability of its legal consultant - Commissioner (Appeals) refused to condone delay and dismissed appeal in limine - Whether since filing an appeal in tax matters 13 Nirmal Kumar Agrawal

BALITHAL GRAM SEVA SAHAKARI SAMITI LIMITED,TONK vs. RJN-W-(107)(5), TONK

In the result, the appeal of the assessee is allowed

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyalbalithal Gram Seva Sahakari Samiti Limited, Balithal Uniara Tonk, 304024 Pan No.: Aabab4614R ...... Appellant Vs.

80P of the Act claimed by the assessee, which is not sustainable in law. No doubt, a separate proceeding u/s. 148 of the Act can be issued against the assessee on this issue, if possible, but in this proceeding, action of the authorities below is not sustainable as per law. Our view is being further fortified by the authority

SH. BADALURAM,FAULADPUR, ALWAR vs. ITO, WARD-BEHROR, BEHROR

In the result, the appeal of the assessee is allowed

d lnL; ,oa Jh jkBksM deys'k t;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. No. 720/JPR/2023 fu/kZkj.k o"kZ@Assessment Years : 2017-18 cuke Sh. Badaluram ITO, S/o Bah Ram, Vs. Ward- Behror. Fauladpur Neemrana, Alwar. LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR