GILLETTE INDIA LIMITED,SPA-65A, INDUSTRIAL AREA, BHIWADI, DISTRICT- ALWAR vs. PCIT, JAIPUR-1, JAIPUR

In the result, the appeal of the assessee is partly allowed

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

Permanent Establishment in India) or reimbursement of expenses. (c) not considering the detailed reconciliation submitted along with documentary evidence in response to notice u/s 263 of the Act. (d) not appreciating the fact that clause 34(a) of the form only reflects the amounts on which TDS is deducted u/s 195 of the Act with regard to payments made

SHRI KALYAN BUILDMART PVT. LTD,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-2, JAIPUR, JAIPUR

Bench: The Date Of Hearing.”

transferring the majority shareholding to a company & an Individual from where share capital and share premium has flown in on the basis of Asset Based method, speaks of a broader nexus of creating bogus assets and creation of bogus share premium. The authenticity of the credits, share capital and share premium has not been established. 4. Therefore, due to above

M/S. MAHARAJA SHREE UMAID MILLS LTD. JAIPUR,JAIPUR vs. DCIT CIRCLE-6, JAIPUR, CIRCLE-6, JAIPUR

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

transfer pricing adjustments. The Assessing Officer disallowed the same since the additional depreciation under Section 32(1)(iia) was allowable only in the first year of purchase. The Dispute Resolution Panel held that the claim of additional depreciation on assets installed during the period 1.10.2008 was allowable and directed allowance of additional depreciation claimed by the assessee under Section

SHRI MANOJ AMAR CHAND TAILOR,MASUDA BIJAINAGAR vs. INCOME TAX OFFICER, WARD-1, BEAWAR

In the result, the appeal filed by the Revenue is dismissed

permanently shifted to Bijainnagar and started a small saree shop. On receipt of assessment order and appellate order whereby a huge demand was created against him he went into depression. He, thus, could not make decision whether to file appeal before Hon'ble Bench or not. By the time his family and friends could make him realize the necessity

INCOME TAX OFFICER, WARD-1, BEAWAR vs. SHRI MANOJ AMAR CHAND TAILOR, MASUDA BIJAINAGAR

In the result, the appeal filed by the Revenue is dismissed

permanently shifted to Bijainnagar and started a small saree shop. On receipt of assessment order and appellate order whereby a huge demand was created against him he went into depression. He, thus, could not make decision whether to file appeal before Hon'ble Bench or not. By the time his family and friends could make him realize the necessity

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

Bench: This Tribunal Are As Under :

establish the truth of those recitals, otherwise it will be very easy to make self-serving statements in documents either executed or taken by a party and rely on those recitals. [Hon'ble Supreme Court in CIT v. Durga Prasad More [1971] 82 ITR 540]. An appellant is to explain the delay w.r.t. the period of the delay in chronological

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

Bench: This Tribunal Are As Under :

establish the truth of those recitals, otherwise it will be very easy to make self-serving statements in documents either executed or taken by a party and rely on those recitals. [Hon'ble Supreme Court in CIT v. Durga Prasad More [1971] 82 ITR 540]. An appellant is to explain the delay w.r.t. the period of the delay in chronological

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

Bench: This Tribunal Are As Under :

establish the truth of those recitals, otherwise it will be very easy to make self-serving statements in documents either executed or taken by a party and rely on those recitals. [Hon'ble Supreme Court in CIT v. Durga Prasad More [1971] 82 ITR 540]. An appellant is to explain the delay w.r.t. the period of the delay in chronological

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

Bench: This Tribunal Are As Under :

establish the truth of those recitals, otherwise it will be very easy to make self-serving statements in documents either executed or taken by a party and rely on those recitals. [Hon'ble Supreme Court in CIT v. Durga Prasad More [1971] 82 ITR 540]. An appellant is to explain the delay w.r.t. the period of the delay in chronological

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

establish the truth of those recitals,\notherwise it will be very easy to make self-serving statements in documents either\nexecuted or taken by a party and rely on those recitals. [Hon'ble Supreme Court\nin CIT v. Durga Prasad More [1971] 82 ITR 540]. An appellant is to explain the\ndelay w.r.t. the period of the delay in chronological

RAJASTHAN EXPORT PROMOTION COUNCIL,JAIPUR vs. CIT (EXEMPTION), JAIPUR, JAIPUR

In the result, appeal of the assessee is allowed for statistical\npurpose

permanent registration\nu/sec.80G on 30.09.2023. The ld.AR explained that ld.CIT(E) has\nrejected the assessee's application only on one ground that\nassessee's application was filed beyond the time allotted\nu/sec.80G(5) of the Act, hence, the ld.CIT(E) held that assessee's\napplication was not maintainable. The ld.AR relied on the order of\nthe Hon'ble Madras High

M/S ANGEL INFRASTRUCTURE (P) LTD.,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR

In the result, appeal of the assessee is partly allowed and the

establish the correctness of the fact recorded in the reasons for reopening. Thus, what is needed at the stage of reopening is the nexus between the material and believe that there was escapement of income. The relevance of reasons is justifiable and not the adequacy or sufficiency. The ld. CIT-DR has relied upon the findings

ASSISTANT COMMISSIONER OF INCOME TAX , CIRCLE-2, JAIPUR vs. M/S. ANGEL INFRASTRUCTURE PRIVATE LIMITED, JAIPUR

In the result, appeal of the assessee is partly allowed and the

establish the correctness of the fact recorded in the reasons for reopening. Thus, what is needed at the stage of reopening is the nexus between the material and believe that there was escapement of income. The relevance of reasons is justifiable and not the adequacy or sufficiency. The ld. CIT-DR has relied upon the findings

DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), CIRCLE, JAIPUR vs. MODERN SCHOOL SOCIETY, KOTA

In the result, this appeal of the revenue stands dismissed

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 1361 & 1362/Jp/2018 Assessment Years: 2011-12 & 2012-13 Deputy Commissioner Of Cuke M/S Modern School Society, Vs. Income Tax (Exemptions) Sector-A, Talwandi, Kota Circle, Jaipur. (Rajasthan) Pan No.: Aaatm 7045 H Vihykfkhz@Appellant Izr;Fkhz@Respondent Vk;Dj Vihy La-@Ita No. 357/Jp/2019 Assessment Year: 2013-14 Deputy Commissioner Of Cuke M/S Modern School Society, Vs. Income Tax (Exemptions) Sector-A, Talwandi, Kota Circle, Jaipur. (Rajasthan) Pan No.: Aaatm 7045 H Vihykfkhz@Appellant Izr;Fkhz@Respondent Jktlo Dh Vksj Ls@ Revenue By : Smt. Rooni Paul (Addl.Cit-Dr) Fu/Kzkfjrh Dh Vksj Ls@ Assessee By: Shri Rajiv Sogani (Ca) Lquokbz Dh Rkjh[K@ Date Of Hearing : 21/12/2020 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 18/01/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. These Are The Appeals Filed By The Revenue Against The Separate Orders Of The Ld. Cit(A)-3, Jaipur Dated 04/09/2018 & 12/12/2018 For The A.Y. 2011-12 To 2013-14 Respectively.

Transfer of Undertakings) Act, 1980 (40 of 1980), or any other bank being a bank included in the Second Schedule to the Reserve Bank of India Act, 1934 (2 of 1934); (iv) investment in units of the Unit Trust of India established under the Unit Trust of India Act, 1963 (52 of 1963); (v) investment in any security for money

DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), CIRCLE, JAIPUR vs. MODERN SCHOOL SOCIETY, KOTA

In the result, this appeal of the revenue stands dismissed

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 1361 & 1362/Jp/2018 Assessment Years: 2011-12 & 2012-13 Deputy Commissioner Of Cuke M/S Modern School Society, Vs. Income Tax (Exemptions) Sector-A, Talwandi, Kota Circle, Jaipur. (Rajasthan) Pan No.: Aaatm 7045 H Vihykfkhz@Appellant Izr;Fkhz@Respondent Vk;Dj Vihy La-@Ita No. 357/Jp/2019 Assessment Year: 2013-14 Deputy Commissioner Of Cuke M/S Modern School Society, Vs. Income Tax (Exemptions) Sector-A, Talwandi, Kota Circle, Jaipur. (Rajasthan) Pan No.: Aaatm 7045 H Vihykfkhz@Appellant Izr;Fkhz@Respondent Jktlo Dh Vksj Ls@ Revenue By : Smt. Rooni Paul (Addl.Cit-Dr) Fu/Kzkfjrh Dh Vksj Ls@ Assessee By: Shri Rajiv Sogani (Ca) Lquokbz Dh Rkjh[K@ Date Of Hearing : 21/12/2020 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 18/01/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. These Are The Appeals Filed By The Revenue Against The Separate Orders Of The Ld. Cit(A)-3, Jaipur Dated 04/09/2018 & 12/12/2018 For The A.Y. 2011-12 To 2013-14 Respectively.

Transfer of Undertakings) Act, 1980 (40 of 1980), or any other bank being a bank included in the Second Schedule to the Reserve Bank of India Act, 1934 (2 of 1934); (iv) investment in units of the Unit Trust of India established under the Unit Trust of India Act, 1963 (52 of 1963); (v) investment in any security for money

DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), CIRCLE, JAIPUR vs. MODERN SCHOOL SOCIETY, KOTA

In the result, this appeal of the revenue stands dismissed

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 1361 & 1362/Jp/2018 Assessment Years: 2011-12 & 2012-13 Deputy Commissioner Of Cuke M/S Modern School Society, Vs. Income Tax (Exemptions) Sector-A, Talwandi, Kota Circle, Jaipur. (Rajasthan) Pan No.: Aaatm 7045 H Vihykfkhz@Appellant Izr;Fkhz@Respondent Vk;Dj Vihy La-@Ita No. 357/Jp/2019 Assessment Year: 2013-14 Deputy Commissioner Of Cuke M/S Modern School Society, Vs. Income Tax (Exemptions) Sector-A, Talwandi, Kota Circle, Jaipur. (Rajasthan) Pan No.: Aaatm 7045 H Vihykfkhz@Appellant Izr;Fkhz@Respondent Jktlo Dh Vksj Ls@ Revenue By : Smt. Rooni Paul (Addl.Cit-Dr) Fu/Kzkfjrh Dh Vksj Ls@ Assessee By: Shri Rajiv Sogani (Ca) Lquokbz Dh Rkjh[K@ Date Of Hearing : 21/12/2020 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 18/01/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. These Are The Appeals Filed By The Revenue Against The Separate Orders Of The Ld. Cit(A)-3, Jaipur Dated 04/09/2018 & 12/12/2018 For The A.Y. 2011-12 To 2013-14 Respectively.

Transfer of Undertakings) Act, 1980 (40 of 1980), or any other bank being a bank included in the Second Schedule to the Reserve Bank of India Act, 1934 (2 of 1934); (iv) investment in units of the Unit Trust of India established under the Unit Trust of India Act, 1963 (52 of 1963); (v) investment in any security for money

SHRI MAMCHAND GURJAR,ALWAR vs. ITO, ALWAR

In the result, all the six appeals of the assessees are allowed on the

transferred from the owner who was a schedule caste person. Beyond that the purpose of conversion was nothing. This fact has not been properly appreciated by the Learned CIT(A) even though he has acknowledged the facts in his order. To this extent the order of the Learned CIT(A) is erroneous and deserves to be quashed. The Learned

SHYAM LAL,JAIPUR vs. ITO, ALWAR

In the result, all the six appeals of the assessees are allowed on the

transferred from the owner who was a schedule caste person. Beyond that the purpose of conversion was nothing. This fact has not been properly appreciated by the Learned CIT(A) even though he has acknowledged the facts in his order. To this extent the order of the Learned CIT(A) is erroneous and deserves to be quashed. The Learned