ANSHU SAHAI (HUF), JAIPUR,JAIPUR vs. ACIT, CENTRAL CIRCLE 2, JAIPUR, JAIPUR

153C was issued after following due process and notice\nu/s 142(1)/144 were issued to the assessee to explain the transactions\nentered in with Gokul Kripa Group. The assessee has sold land situated at\nVillage Sarangpura, Tehsil Sanganer, Jaipur to M/s Gokul Kripa Colonisers\n& Developers Pvt. Ltd. for consideration of Rs.25,84,80,000/- as mentioned\nin registered

ACIT, JAIPUR vs. UDAI BUILDHOME PVT LTD, JAIPUR

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

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकर अपील सं. / ITA Nos.1399, 1400, 1401 & 1486/JP/2024 निर्धारण वर्ष / Assessment Years : 2014-15, 2015-16, 2017-18 & 2018-19 Asstt. Commissioner of Income बनाम M/s Udai Buildhome Pvt. Tax, Vs. Ltd. 302, Golden Sunrise Central Circle-02, Jaipur Apartment, Lajpat Marg, C- Scheme, Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AABCU 5068 J अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee

68. The jurisdictional AO would have to firstly be satisfied that the material received is likely to have a bearing on or impact the total income of years or years which may form part of the block of six or ten AYs' and thereafter proceed to place the assessee on notice under Section 153C. The power to undertake such

ACIT, JAIPUR vs. UDAI BUILDHOME PVT LTD, JAIPUR

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

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, JM आयकर अपील सं. / ITA Nos.1399, 1400, 1401 & 1486/JP/2024 निर्धारण वर्ष / Assessment Years : 2014-15, 2015-16, 2017-18 & 2018-19 Asstt. Commissioner of Income Tax, Central Circle-02, Jaipur बनाम Vs. M/s Udai Buildhome Pvt. Ltd. 302, Golden Sunrise Apartment, Lajpat Marg, C- Scheme, Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AABCU 5068 J अपीलार्थी / Appellant निर्धारिती की ओर से / Assessee by: प्रत्यर्थी / Respond

68. The jurisdictional AO would have to firstly be satisfied that the material received is likely to have a bearing on or impact the total income of years or years which may form part of the block of six or ten AYs' and thereafter proceed to place the assessee on notice under Section 153C. The power to undertake such

ACIT, JAIPUR vs. UDAI BUILDHOME PVT LTD, JAIPUR

section 153C is\nwithout any basis/authority and the implication of the same is that the notice under\nsection 153C of the Act is without jurisdiction and the assessment order in question\ncannot be sustained.\nFurther, Hon'ble Supreme Court in the case of Deputy Commissioner of Income-\ntax v. U. K. Paints (Overseas) Ltd. [2023] 150 taxmann.com

INCOME TAX OFFICER , SIKAR vs. BHASKAR CHAUHAN, JAIPUR

In the result the appeal of the revenue in ITA no

Bench: Him.

153C in the absence of any incriminating material pertaining to the appellant found during course of search under section 132 or requisition under section 132A. However third party information from sources other than seized material belonging to the appellant, shall be relied upon by the assessing officer to complete assessment u/s 143 rws 144. As a result, ground

DCIT, JAIPUR vs. VIMAL CHAND SURANA HUF, JAIPUR

In the result, the appeal of the revenue stands dismissed

68 SOT 449 (Jaipur Trib) while examining the provisions of 153C of the Income Tax Act which observed that “Satisfaction note itself must display reasons or basis of conclusion that the documents belong to a person other than the searched person. It is also settled law that the satisfaction note has to be read as it is without any addition

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SNEHLATA AGARWAL, SIKAR

In the result, the appeals of the revenue in ITA No

68 of the Act based on these observations ground no. 1 raised by the\nrevenue is dismissed.\nSince we have confirmed the action of the Id. CIT(A) in directing the\ndeletion of addition vide ground no. 1 the ground no. 2 being consequential\nto ground no. 1 the addition of alleged commission is also rightly directed\nto be deleted

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SUBHASH CHANDRA BANKA, SIKAR

In the result, the appeals of the revenue in ITA No

68 of the Act based on these observations ground no. 1 raised by the\nrevenue is dismissed.\nSince we have confirmed the action of the Id. CIT(A) in directing the\ndeletion of addition vide ground no. 1 the ground no. 2 being consequential\nto ground no. 1 the addition of alleged commission is also rightly directed\nto be deleted

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. PRIYA DEWAN, SIKAR

In the result, the appeals of the revenue in ITA No

68 of the Act based on these observations ground no. 1 raised by the\nrevenue is dismissed.\nSince we have confirmed the action of the Id. CIT(A) in directing the\ndeletion of addition vide ground no. 1 the ground no. 2 being consequential\nto ground no. 1 the addition of alleged commission is also rightly directed\nto be deleted

DCIT, CENTRAL CIRCLE-1, JAIPUR , JAIPUR vs. USHA BANKA, SIKAR

In the result, the appeals of the revenue in ITA No

68 of the Act based on these observations ground no. 1 raised by the\nrevenue is dismissed.\nSince we have confirmed the action of the Id. CIT(A) in directing the\ndeletion of addition vide ground no. 1 the ground no. 2 being consequential\nto ground no. 1 the addition of alleged commission is also rightly directed\nto be deleted

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. USHA BANKA, SIKAR

In the result, the appeals of the revenue in ITA No

68 of the Act based on these observations ground no. 1 raised by the\nrevenue is dismissed.\nSince we have confirmed the action of the Id. CIT(A) in directing the\ndeletion of addition vide ground no. 1 the ground no. 2 being consequential\nto ground no. 1 the addition of alleged commission is also rightly directed\nto be deleted

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SARITA DEWAN, SIKAR

In the result, the appeals of the revenue in ITA No

68 of the Act based on these observations ground no. 1 raised by the\nrevenue is dismissed.\nSince we have confirmed the action of the Id. CIT(A) in directing the\ndeletion of addition vide ground no. 1 the ground no. 2 being consequential\nto ground no. 1 the addition of alleged commission is also rightly directed\nto be deleted

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. TRILOK DEWAN, SIKAR

In the result, the appeals of the revenue in ITA No

68 of the Act based on these observations ground no. 1 raised by the\nrevenue is dismissed.\nSince we have confirmed the action of the Id. CIT(A) in directing the\ndeletion of addition vide ground no. 1 the ground no. 2 being consequential\nto ground no. 1 the addition of alleged commission is also rightly directed\nto be deleted

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. VIPUL BANKA, SIKAR

In the result, the appeals of the revenue in ITA No

68 of the Act based on these observations ground no. 1 raised by the\nrevenue is dismissed.\nSince we have confirmed the action of the Id. CIT(A) in directing the\ndeletion of addition vide ground no. 1 the ground no. 2 being consequential\nto ground no. 1 the addition of alleged commission is also rightly directed\nto be deleted

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SARITA DEWAN, SIKAR

In the result, the appeals of the revenue in ITA No

68 of the Act based on these observations ground no. 1 raised by the\nrevenue is dismissed.\nSince we have confirmed the action of the Id. CIT(A) in directing the\ndeletion of addition vide ground no. 1 the ground no. 2 being consequential\nto ground no. 1 the addition of alleged commission is also rightly directed\nto be deleted

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. PRIYA DEWAN, SIKAR

In the result, the appeals of the revenue in ITA No

68 of the Act based on these observations ground no. 1 raised by the\nrevenue is dismissed.\nSince we have confirmed the action of the Id. CIT(A) in directing the\ndeletion of addition vide ground no. 1 the ground no. 2 being consequential\nto ground no. 1 the addition of alleged commission is also rightly directed\nto be deleted

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. ANIMESH AGARWAL, SIKAR

In the result, the appeals of the revenue in ITA No

68 of the Act based on these observations ground no. 1 raised by the\nrevenue is dismissed.\nSince we have confirmed the action of the Id. CIT(A) in directing the\ndeletion of addition vide ground no. 1 the ground no. 2 being consequential\nto ground no. 1 the addition of alleged commission is also rightly directed\nto be deleted

RAMESH CHAND BANSAL,BEAWAR vs. DCIT, AJMER

In the result, the appeals of the assessee are allowed

68,040/-. Hence, the pleading on the ground of equity also fails. 5.7 Thus though surrender was during the search in course of statements u/s 132(4), the disclosure u/s 132(4), by itself cannot redeem the appellant from deeming provisions of the explanation 5A to section 271(1)( c) of the Act. Factually speaking the statement