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

reassessment process invalid in law. The AO's\naction in initiating proceedings u/s 147 is based on conjecture and suspicion, and falls\nfoul of the binding legal principles laid down by the Hon'ble Supreme Court and various\nHigh Courts.\nIn light of the above legal and factual position, it is respectfully submitted that the\nreassessment proceedings-initiated u/s 147

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

reassessment process invalid in law. The AO's\naction in initiating proceedings u/s 147 is based on conjecture and suspicion, and falls\nfoul of the binding legal principles laid down by the Hon'ble Supreme Court and various\nHigh Courts.\nIn light of the above legal and factual position, it is respectfully submitted that the\nreassessment proceedings-initiated u/s 147

KOSHAL KISHOR SHARMA,JAIPUR vs. DCIT(INTL. TAX.) JAIPUR, JAIPUR

In the result, appeals of the assessee are allowed

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

unexplained investment under section 69 of the Act. Thus the ld. AO made the entire cash deposit without seeing the withdrawals and nature of transactions. Koshal Kishor Sharma, Jaipur. Hence this appeal SUBMISSIONS: 1. Notice without jurisdiction: 1.1 At the very outsetit is submitted that the applicantassessee was/isan NRI. The assessee was residing at Japan from 24-25 years

KOSHAL KISHOR SHARMA,JAIPUR vs. DCIT(INTL. TAX), JAIPUR, JAIPUR

In the result, appeals of the assessee are allowed

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

unexplained investment under section 69 of the Act. Thus the ld. AO made the entire cash deposit without seeing the withdrawals and nature of transactions. Koshal Kishor Sharma, Jaipur. Hence this appeal SUBMISSIONS: 1. Notice without jurisdiction: 1.1 At the very outsetit is submitted that the applicantassessee was/isan NRI. The assessee was residing at Japan from 24-25 years

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)

reassessment u/s 147 of the Act ignoring that the reason to belief of the AO is founded on information which has been received by the AO after completion of assessment, which is a sound foundation for exercising power u/s 147 r.w.s 148? 2.3 In ITA No. 874/JP/2024 the revenue has raised the following grounds; 1 Whether on the facts

INCOME TAX OFFICER, JAIPUR vs. KEDIA BUILDERS AND COLONIZERS PRIVATE LIMITED, JAIPUR

In the result, all appeals of the revenue are stands dismissed

147 was based on credible and\nindependently verified evidence, satisfying the legal requirements. The Hon’ble ITAT is\nrequested to uphold the reassessment and reverse the order of the CIT(A), quashing\nthe same.\nRespectfully Submitted on Behalf of the Revenue\n17. Per contra, ld. AR of the assessee supported the order of the ld.\nCIT(A) and in support

PRAMOD KUMAR CHOUDHARY,JAIPUR vs. ITO, JAIPUR

In the result, the appeal of the assessee is allowed

147 of the Act and allow grounds No. 3\nand 4 of the appeal.\nSince, we have quashed the reassessment proceedings initiated in the case of\nassessee, therefore, there is no need to adjudicate the other issues raised in\ngrounds No. 1,2 and 5 to 13 of the said appeal.\"\nIn view of above decision by the Tribunal

INCOME TAX OFFICER, JAIPUR vs. KEDIA BUILDERS AND COLONIZERS PRIVATE LIMITED, JAIPUR

In the result, all appeals of the revenue are stands dismissed

147 was based on credible and\nindependently verified evidence, satisfying the legal requirements. The Hon’ble ITAT is\nrequested to uphold the reassessment and reverse the order of the CIT(A), quashing\nthe same.\n\nRespectfully Submitted on Behalf of the Revenue\n\n17. Per contra, ld. AR of the assessee supported the order of the ld.\nCIT

DCIT, CC-2, JAIPUR vs. SHRI VIMAL CHAND SURANA(HUF), JAIPUR

In the result, the appeal of the revenue stands dismissed

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

147 of the Income Tax Act, 1961. Hence, in view of the above, it is fit case for re-assessment u/s 148 of the I.T Act”. Thus, the Assessing Officer has proceeded on the premises that the assessee along with Shri K.G. Kothari and Shri Vimal Chand Surana (Individual) had invested the money in purchase of land in the name

MALI RAM YADAV,THERKYO KI DHANI vs. ITO, 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. 1110/JPR/2025 निर्धारण वर्ष / Assessment Year : 2017-18 Shri Mali Ram Yadav Thekryo Ki Dhani, Village & Post: Jahota, Tehsil: Amer Distt: Jaipur 303 701 बनाम Vs. The ITO Ward - 7(2) Jaipur प्रत्यर्थी / Respondent स्थायी लेखा सं. / जीआईआर सं. / PAN/GIR No.: ABJPY 6715A अपीलार्थी / Appellant निर्धारिती की ओर से / Assesseeby : Shri Rakesh Kumar Kabra, CA Mrs. Prachela Kabra, CA राजस्व की ओर से /

reassessment proceedings u/s 147 of the Income Tax Act, 1961 and issuance of notice u/s 148A is illegal, arbitrary, and void ab initio as the same was issued beyond the prescribed time limit and without fulfilling the conditions laid down under the law. The action is thus without jurisdiction and liable to be quashed. 4. That in the facts

INCOME TAX OFFICER, JAIPUR vs. KEDIA BUILDERS AND COLONIZERS PRIVATE LIMITED, JAIPUR

Investment Pvt. Ltd.\n4. M/s Shareen Hire Purchase Pvt. Ltd.\nHowever, no replies were received from these entities.\n2.3 Field Enquiries by Income Tax Inspector\nField enquiries revealed that none of the above companies were physically\nexistent at their registered addresses, confirming their non-operational status.\n2.4 Summons and Commission\nSummons issued u/s 131 to the directors of these companies

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

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

unexplained investment u/s 69 of the Act. 6. Aggrieved from the order of Assessing Officer, assessee preferred an appeal before the ld. CIT(A). Apropos to the grounds so raised the relevant finding of the ld. CIT(A) is reiterated here in below: Sh. Dheeraj Singh Sisodiya vs. DCIT “Decision The facts of the case are considered. There

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

unexplained investment u/s 69 of the Act. 6. Aggrieved from the order of Assessing Officer, assessee preferred an appeal before the ld. CIT(A). Apropos to the grounds so raised the relevant finding of the ld. CIT(A) is reiterated here in below: Sh. Dheeraj Singh Sisodiya vs. DCIT “Decision The facts of the case are considered. There

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

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

unexplained investment u/s 69 of the Act. 6. Aggrieved from the order of Assessing Officer, assessee preferred an appeal before the ld. CIT(A). Apropos to the grounds so raised the relevant finding of the ld. CIT(A) is reiterated here in below: Sh. Dheeraj Singh Sisodiya vs. DCIT “Decision The facts of the case are considered. There

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं. / ITA Nos.931 to 936/JP/2024 निर्धारण वर्ष / Assessment Years : 2012-13 & 2014-15 to 2018-19 Dheeraj Singh Sisodiya 005, (Nayagaun) Ram Ganmandi, Kota बनाम DCIT, Vill. Beedmandi Vs. Central Circle, Kota स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: APAPS 6392 E अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by : Sh. P. C. Parwal, CA राजस्व की ओर से / Revenue by : Mrs. Alka Gautam,

unexplained investment u/s 69 of the Act. 6. Aggrieved from the order of Assessing Officer, assessee preferred an appeal before the ld. CIT(A). Apropos to the grounds so raised the relevant finding of the ld. CIT(A) is reiterated here in below: Sh. Dheeraj Singh Sisodiya vs. DCIT “Decision The facts of the case are considered. There

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं. / ITA Nos.931 to 936/JP/2024 निर्धारण वर्ष / Assessment Years : 2012-13 & 2014-15 to 2018-19 Dheeraj Singh Sisodiya 005, (Nayagaun) Ram Ganmandi, Kota बनाम DCIT, Vill. Beedmandi Vs. Central Circle, Kota स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: APAPS 6392 E अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by : Sh. P. C. Parwal, CA राजस्व की ओर से / Revenue by : Mrs. Alka Gautam,

unexplained investment u/s 69 of the Act. 6. Aggrieved from the order of Assessing Officer, assessee preferred an appeal before the ld. CIT(A). Apropos to the grounds so raised the relevant finding of the ld. CIT(A) is reiterated here in below: Sh. Dheeraj Singh Sisodiya vs. DCIT “Decision The facts of the case are considered. There

SH. DHEERAJ SINGH SISODIYA,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result the ground no

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

unexplained investment u/s 69 of the Act. 6. Aggrieved from the order of Assessing Officer, assessee preferred an appeal before the ld. CIT(A). Apropos to the grounds so raised the relevant finding of the ld. CIT(A) is reiterated here in below: Sh. Dheeraj Singh Sisodiya vs. DCIT “Decision The facts of the case are considered. There

SMT. SHEELA YOGI,JAIPUR vs. INCOME TAX OFFICER, JAIPUR

In the result, ground no. 3 & 4 of the assessee’s appeal are allowed

Bench: Him Under Rule 46A Of The Income Tax Act, 1962. 2(I) On The Facts & Circumstances Of The Case & In Law Also Ld. Lower Authorities Grossly Erred In Initiating Reassessment Proceedings U/S 147 Of The Act.

unexplained investment u/s 69 for which the notice has been issued u/s 148 of the Act, and thus, the very basis for reassessment doesn’t exist anymore, it is a settled legal proposition that the Assessing officer cannot travel beyond and extend his jurisdiction and bring to tax others transactions to tax u/s 68 of the Act during such reassessment