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

unexplained investment under section 69 of the IT Act and completed the\nassessment under 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

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

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

unexplained share application money\nand commission payments.\n\nB. Grounds of Appeal\n\n1. Whether on the facts and circumstances of the case, the Ld. CIT(A) is justified in\nquashing the reopening and reassessment 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

unexplained investment under section 69 of the IT Act and completed the\nassessment under 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

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

unexplained investment under section 69 of the IT Act and completed the\nassessment under 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

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

unexplained investment under section 69 of the IT Act and completed the\nassessment under 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

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)

money u/s 69A of the Act. And made the addition of Rs.52,54,225/- u/s 69A. 6.The ld. AO further stated that It is also noted that during the year under consideration, the assessee, purchased mutual fund of Rs. 7,50,000/- but failed in furnishing documentary evidence substantiating the source of the same. Therefore, in absence to supporting documentary

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)

money u/s 69A of the Act. And made the addition of Rs.52,54,225/- u/s 69A. 6.The ld. AO further stated that It is also noted that during the year under consideration, the assessee, purchased mutual fund of Rs. 7,50,000/- but failed in furnishing documentary evidence substantiating the source of the same. Therefore, in absence to supporting documentary

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

unexplained share application money\nand commission payments.\nB. Grounds of Appeal\n1. Whether on the facts and circumstances of the case, the Ld. CIT(A) is justified in\nquashing the reopening and reassessment u/s 147

SH. MUKUT BEHARI AGARWAL,JAIPUR vs. THE DCIT, CIRCLE 1, JAIPUR

In the result, the appeals of the assessee is allowed as indicated hereinabove

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

reassessment proceedings is not in accordance with law as notices u/s 148A and 148 as well as order u/s 148A(d) have been passed by JAO instead of FAO, which 19 SHRI MUKUT BEHARI AGARWAL VS DCIT,CIRCLE-1, JAIPUR is not in accordance with specific provisions of statue. Thus order passed u/s 147 is bad in law and deserves

SUSHILA DEVI JANGID,JAIPUR vs. ITO, WD 7(2), JAIPUR

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

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं. / ITA. No. 374/JP/2025 निर्धारणवर्ष / AssessmentYears : 2010-11 Smt. Sushila Devi Jangid 65, Koshaliya Vihar Hajyawala,Muhana Mandi Ke Pass, Sanganer, Jaipur 302 029 बनाम Vs. The ITO Ward 7(2) Jaipur अपीलार्थी / Appellant प्रत्यर्थी / Respondent स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: AFMPJ 2091 P निर्धारिती की ओरसे / Assesseeby : Shri Utkarsh Mishra, Advocate राजस्व की ओरसे / Revenue by :Shri Gautam Sing

Reassessment proceedings u/s 147 of the Act for relevant A.Y still reflect as on-going proceedings under ‘For your action’ list on ‘e-proceedings’ tab on the Income Tax profile of the assessee. Also, there is no Order u/s 144 r.w.s 147 dated 24.12.2017 available under ‘For your information’ list on ‘e- proceedings’ tab on the income tax profile

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

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)

147 of the Act is bad in law and deserves to be quashed. 1.4. That, the Ld. CIT(A) has further erred in confirming the action of ld. AO in reopening the assessment, beyond the specified time line. Thus, the reassessment proceedings initiated is time barred and entire proceedings are void ab initio. 1.5. That

SAVITA GUPTA,KOTA vs. ITO, DELHI

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

unexplained investment under Sec.69 of the Act is upheld. In the result, the appeal is "Dismissed".” 5. That order of the ld. CIT(A) is under challenge before this tribunal on the grounds as stated herein above in para 2. To support the various grounds so raised by the assessee, ld. AR of the assessee, has filed a detailed written

SHRI MADHO LAL SAINI,JAIPUR vs. ITO, WARD-2(3), JAIPUR

In the result, the appeals of the assessees are allowed

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

Reassessment pursuant to material found in search can be done through recourse to section 153C only and not by invoking the provisions of section 147/148. 1.12. The provisions of section 153C are over-riding in nature and contain non obstante clause for sections 139,147,148,149,151 and 153. 1.13. Section 147 and 153C are not interchangeable

JAI DEEP SINGH,JAIPUR vs. INCOME TAX OFFICER, WARD-7-2, JAIPUR

In the result, the appeal of the assessee is allowed

Unexplained cash deposit Rs.20,00,000/- 4. It was submitted that before Ld. CIT(A), the assessee challenged the reopening of assessment. The Ld. CIT(A), however, upheld the validity of reopening by giving following findings:- (a) The AO has received specific information from the department regarding the income which was likely to have escaped assessment in case

SHIV VEGPRO PRIVATE LIMITED ,KOTA vs. PCIT-UDAIPUR , UDAIPUR

In the result, the appeal filed by the assessee is allowed

reassessment order subjected to revision passed on 15.04.2021\nwhereas the Checkmate (Supra) decision came one and a half year later\nthereto i.e. 12.10.2022. Therefore, the CIT could not have found any\nfault in the assessment order or could neither held as the subject\nreassessment as erroneous nor prejudicial to the revenue interest. On\nthis is aspect the law is well

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

In the result, appeal of the assessee is allowed

money so invested belongs to the assessee and the same has been advanced by way of cash loans through Ramesh Manihar group. And once it is established that these two conditions are satisfied regarding money so invested ITA Nos. 1190 & 1298/JP/2019 & 66/JP/2020 47 Sh. Prakash Chand Kothari, Jaipur vs. DCIT, Jaipur belongs to the assessee and making investment

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

In the result, appeal of the assessee is allowed

money so invested belongs to the assessee and the same has been advanced by way of cash loans through Ramesh Manihar group. And once it is established that these two conditions are satisfied regarding money so invested ITA Nos. 1190 & 1298/JP/2019 & 66/JP/2020 47 Sh. Prakash Chand Kothari, Jaipur vs. DCIT, Jaipur belongs to the assessee and making investment