ARUN PALAWAT,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, (CENTRAL),, JAIPUR

The appeal of the assessee is allowed

Bench: DR. MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal [Chief Commissioner or Chief Commissioner or Principal] Commissioner or Commissioner,— (a) the order is passed without making inquiries or verification which should have been made

ZARI SILK (INDIA) PRIVATE LIMITED,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), JAIPUR , JAIPUR

The appeal of the assessee is allowed

Bench: DR. MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal [Chief Commissioner or Chief Commissioner or Principal] Commissioner or Commissioner,— (a) the order is passed without making inquiries or verification which should have been made

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

transferring the shares to the group concern without any consideration would have requested for extension of time for making the payment of final call money of Rs. 9.90 crores as all these companies are group companies and it was not difficult for them to get the extension of time. Even otherwise when the assessee was holding 77800 bonus shares

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

transferring the shares to the group concern without any consideration would have requested for extension of time for making the payment of final call money of Rs. 9.90 crores as all these companies are group companies and it was not difficult for them to get the extension of time. Even otherwise when the assessee was holding 77800 bonus shares

DY. COMMISSIONER OF INCOME TAX, KOTA vs. MOTION EDUCATION PVT. LTD., KOTA

In the result, the appeals of the revenue stands dismissed, and the

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं. / ITA Nos.472 & 455/JP/2025 निर्धारण वर्ष / Assessment Years : 2017-18 & 2018-19 DCIT, Central Circle, Kota बनाम Vs. Motion Education Limited, 394, Rajeev Gandhi Nagar, Kota Private स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AAICM4637L अपीलार्थी / Appellant प्रत्यर्थी / Respondent Motion Limited, CO. Nos.20 & 21/JP/2025 (Arising out of ITA. Nos.472 & 455/JP/2025) निर्धारण वर्ष / Assessment Years : 2017-18 &

AC can resort to making an addition under section 63A of the Act only an respect of such monies/lassets/articles or things which are not recorded in the assessee's books of account. In the present case on hand, the cash deposits are duly recorded in the books of account and are made on the recept of coaching fee from students

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, JAIPUR vs. M/S. KEDIA REAL ESTATE LLP, JAIPUR

In the result, appeals of the revenue are dismissed whereas appeals of the assessee are allowed in part

Section 132(4) of the Income Tax Act, 1961, alone should not be the basis, for arriving at any adverse decision against the assessee. If the authorities under the Income Tax Act, 1961, have to be conferred with the power, to be exercised, solely on the basis of a statement, then it may lead to an arbitrary exercise of such

M/S. KEDIA REAL ESTATE LLP,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, JAIPUR

In the result, appeals of the revenue are dismissed whereas appeals of the assessee are allowed in part

Section 132(4) of the Income Tax Act, 1961, alone should not be the basis, for arriving at any adverse decision against the assessee. If the authorities under the Income Tax Act, 1961, have to be conferred with the power, to be exercised, solely on the basis of a statement, then it may lead to an arbitrary exercise of such

NITIN KEDIA,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, JAIPUR

In the result, appeals of the revenue are dismissed whereas appeals of the assessee are allowed in part

Section 132(4) of the Income Tax Act, 1961, alone should not be the basis, for arriving at any adverse decision against the assessee. If the authorities under the Income Tax Act, 1961, have to be conferred with the power, to be exercised, solely on the basis of a statement, then it may lead to an arbitrary exercise of such

DY. COMMISSIONER OF INCOME TAX, KOTA vs. MOTION EDUCATION PVT. LTD., KOTA

In the result, the appeals of the revenue stands dismissed, and the\ncross objection of the assessee are allowed

1) of section 1538, except with the prior approval of the Joint\nCommissioner:\nProvided that nothing contained in this section shall apply where the assessment or\nreassessment order, as the case may be, is required to be passed by the Assessing\nOfficer with the prior approval of the Principal Commissioner or Commissioner under sub-\nsection (12) of section 1448A.\"\nThere

DINESH HALDIA,JAIPUR vs. DCIT CIRCLE 1, JAIPUR, JAIPUR

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

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

AC. has finally added higher of the two amount namely trading addition and disallowances out of purchases, accordingly, considering the finding of the A.O., the final addition in AY 2007-08 is upheld on account of unverifiable purchase to the extent of Rs. 3.25,000/- and appellant will get the resultant relief." 9 Dinesh Haldia vs. DCIT In the earlier

SUNIL KUMAR AGARWAL,JAIPUR vs. ACIT, CEN. CIR-2, JAIPUR

In the result the appeal of the assessee in ITA no

1) Rs.2,03,500/- (2) Rs.4,53,000/- (3) Rs.51,038/- (4) Rs.1,11,420/- Rs.8,18,958 During the course of assessment proceedings, it was submitted that the assessee, while filing the return of income for AY 2020-21, has taken into consideration the above papers of undisclosed sales. It is on account of such papers and other discrepancies

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE AJMER vs. ANOOP KUMAR GUPTA, AJMER

In the result appeals of the revenue is dismissed and the cross

AC held that the above referred transfer of payments were in connection with the agreement held on 08.11.2019 between the sellers and purchasers as mentioned supra and that the agreement was actually in existence and was being executed as per the terms CO No. 26 & 27/JP/2022 DCIT vs. Anoop Kumar Gupta and conditions mentioned therein. The AO also observed that

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE AJMER vs. CHANDRA KANT SAINI , AJMER

In the result appeals of the revenue is dismissed and the cross

AC held that the above referred transfer of payments were in connection with the agreement held on 08.11.2019 between the sellers and purchasers as mentioned supra and that the agreement was actually in existence and was being executed as per the terms CO No. 26 & 27/JP/2022 DCIT vs. Anoop Kumar Gupta and conditions mentioned therein. The AO also observed that

MANJEET SINGH DUGGAL,JAIPUR vs. ACIT, JAIPUR

In the result, ground of assessee’s appeal is dismissed

1,47,64,740/- only. The facts are not denied that the assessee has already incurred total cost Rs.1.78 Cr. up to 30th Sep, 2012 (which was well within the permissible time limit of two years from the date of the transfer being 30.01.2012, expiring only on 31.01.2014) whereas, the assessee had incurred total cost much prior thereto. The investment

SHRI GANGA FOUR WHEELS PRIVATE LIMITED ,SIKAR vs. INCOME TAX OFFICER , SIKAR

In the result, the appeal of the assessee is allowed with no orders to cost

Bench: Hon’ble SHRI SANDEEP GOSAIN (Judicial Member)

AC, Computer Equipments, Electrical Equipments, Furniture, Diesel 07/01/15 98,59,500/- 98,59,500/- Generator, Office Equipments, Special Tools, Workshop Equipments 6 SHRI GANGA FOUR WHEELS PVT LTD VS ITO, WARD -SIKAR Spare parts of TATA Motors 07/01/15 69,11,500/- 69,11,500/- Passenger Vehicles Part of structure of Land & Building 07/01/15 60,00,000/- 42,29,000/- situated