SHREE CEMENT LIMITED,BEAWAR vs. NATIONAL FACELESS ASSESSMENT CENTRE, DEPUTY COMMISSIONEROF INCOME TAX, CIRCLE -2, AJMER, AJMER

In the result, the appeal of the Revenue in ITA No

Bench: or at the time of hearing of this appeal.

Section 80IA(8), the word "OR" is missing in provisions of Section 80A(6) of the ACIT vs. Shree Cement Ltd. Act. It is noted that as per provisions of Section 80A(6), if any goods or services whether sold or acquired falls within the category specified domestic transactions of Section 92BA then in such case it is mandatory

PROFESSIONAL AUTOMOTIVES PRIVATE LIMITED,JAMMU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JAIPUR

In the result the appeal of the assessee in ITA no

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील /ITA Nos.809 to 815/JP/2025 निर्धारण वर्ष /Assessment Years :2013-14 to 2019-20 Professional Automotives Pvt. बनाम ACIT, Ltd. Bahu Plaza, Bahu Plaza, Jammu Vs. Central Circle- 1, and Kashmir Jaipur स्थायी लेखा सं./जी.आई.आर. सं./PAN/GIR No.:AAACP9608E अपीलार्थी/Appellant प्र]त्यर्थी/Respondent निर्धारिती की ओर से / Assessee by :Shri Tarun Mittal, CA राजस्व की ओर से /Revenue by: Shri Ajey Malik, CIT (Th. V.C)

Section 194 and 200 were challenged. It was noted in P. RatnakarRao and others V. Govt. Of A.P. and others (1996 (5) SCC 359) that the discretion given under Section 200(1) to the State Government to prescribe maximum rates for compounding the offence is not unguided, uncanalised and arbitrary. It was, inter alia, held as follows: ……………….. ………………. It is indisputable

SHREE CEMENT LIMITED,BANGUR NAGAR vs. ACIT, CENTRAL CIRCLE, AJMER

In the result, the appeal of the assessee - appellant in ITA No

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

sections (4) to (10) and as increased by the applicable surcharge, for the purposes of the Union, calculated in the manner provided therein, shall be further increased by an additional surcharge, for the purposes of the Union, to be called the “Health and Education Cess on income-tax”, calculated at the rate of four per cent of such income

MUJMMEEL ,KOTA vs. ACIT-CENTRAL CIRCLE , KOTA

In the result, appeal of the assessee is allowed

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

131 of the 20 31 Act Copy of Show Cause Notice dated 24.03.2022 issued u/s 5. 32 33 142(1) of the Act 6. Copy of reply dated 24.03.2022 filed by the assessee 34 35 appellant 7. Copy of ledger account of Mukut Bihari Meena at pg. no. 36 39 34,49,56 and 58 of Exhibit-3 8. Copy

JAIPAL SINGH,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR

price of the immovable property was Rs.40 lakhs. In the\ncourse of search action it has been found that the appellant has been regularly\nindulging in transactions of sale and purchase of immovable properties and it\ncannot be said that he is not having other sources of income and he has been\nearning income as middleman and income as gain

DCIT, CC-1, JAIPUR vs. M/S. DANGAYACH HOTELS PRIVATE LIMITED, JAIPUR

In the result, the appeal of the Revenue is dismissed

Section 65B (2).” 36. It was submitted that the Apex Court held that these safeguards are taken to ensure the ‘source and authenticity’, which are “the two hallmarks pertaining to electronic record sought to be used as evidence. The importance of following this procedure was emphasized by the fact that electronic records are more susceptible to tampering, alteration, transposition, excision

LOVELY PROMOTERS PRIVATE LIMITED,KOLKATA vs. ACIT, CENTRAL CIRCLE, AJMER, AJMER

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

Bench: him regarding non mentioning of Document Identification Number (DIN) in the body of the order u/s. 127 of the Act dated 08-09-2021 and various other technical pleas raised in grounds of appeal regarding validity of notice u/s. 148 of the Act, thereby appellate order passed by the CIT(A) is non-speaking order and deserves to be quashed. 4. On the facts and in circumstances of the case and in law, the AO erred in issuing notice u/s. 148 of the Act as it was a search related case u/s. 132 r/w

131 or section 133 of the Act) is sought to be initiated; or (v) When the functionality to issue communication is not available in the system, 26 Lovely promoters Pvt. Ltd. vs. ACIT the communication may be issued manually but only after recording reasons in writing in the tile and with prior written approval of the Chief Commissioner / Director General

KIRAN FINE JEWELLERS PRIVATE LIMITED,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, JAIPUR

In the result ground no 2 raised by the assessee is allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

section 145(3) of the Act is hereby upheld. This ground of Appeal is hereby dismissed. 23 Kiran Fine Jewellers Pvt. Ltd. vs. DCIT Ground No. 2 5.2 I have considered the facts of the case and written submissions of the appellant as against the observations/findings of the AO in the assessment order for the year under consideration. The contentions/submissions

PINK CITY JEWEL HOUSE PRIVATE LIMITED ,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), JAIPUR

Section 14A of the Act can\nbe made if the assessee had not earned any exempt income? - HELD THAT:- A\nperusal of the Memorandum of the Finance Bill, 2022 reveals that it explicitly stipulates\nthat the amendment made to Section 14A will take effect from 1st April, 2022 and will\napply in relation to the assessment year

SURYA SINGHAL,KOTA vs. ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

131 of the IT Act,\nadmitted the same as undisclosed income of the appellant-\ncompany. However, subsequently while filing the return of\nincome for the relevant assessment year, the appellant-company\ndid not offer the said undisclosed income to tax.\nTherefore, in this case, surrender was backed by cash\nfound during the search.\nBut in the case of the assessee

SPECTRUM FOODS LIMITED,JAIPUR vs. INCOME TAX OFFICER, JAIPUR

In the result, the appeal of the assessee is allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

131 (1A) of the Income Tax Act 1961 and during the investigation, it was confirmed that the brokers were placing fake profits/losses on the orders of the clients. The code modification facility has been misused. Since, the assessee is one of the beneficiaries of such fraudulent profits/losses; the assessee's case was opened for reassessment under section

JAIPAL SINGH,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR

price of the immovable property was Rs.40 lakhs. In the\ncourse of search action it has been found that the appellant has been regularly\nindulging in transactions of sale and purchase of immovable properties and it\ncannot be said that he is not having other sources of income and he has been\nearning income as middleman and income as gain

RAJRAJESHWARI GUPTA ,KOTA vs. ITO , WARD 1(1),KOTA, KOTA

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

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

Section 131 to both the brokers (No notices u/s 131 were issued to the broker) from whom shares were purchased and sold and statements were recorded. The AO also analyzed the balance sheet of M/s Ankur International Ltd. (The balance sheet of Bakra Pratisthan was not available before the AO, what to talk of its analysis) to justify

MADAN MOHAN GUPTA ,KOTA vs. ITO WARD 1(3) , KOTA

Section 131 to both\nthe brokers (No notices u/s 131 were issued to the broker) from whom shares\nwere purchased and sold and statements were recorded. The AO also analyzed\nthe balance sheet of M/s Ankur International Ltd. (The balance sheet of\nBakra Pratisthan was not available before the AO, what to talk of its analysis)\nto justify

GIRNAR SOFTWARE PRIVATE LIMITED,6TH FLOOR, JAIPUR TEXTILE MARKET, B-2, NEAR MODEL TOWN, MALVIYA NAGAR, JAIPUR vs. PCIT – 2, JAIPUR, NEW CENTRAL REVENUE BUILDING

In the result, the appeal of the assessee is allowed

Bench: HON’BLE SHRI SANDEEP GOSAIN, JM & HON’BLE SHRI RATHOD KAMLESH JAYANTBHAI (Accountant 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

KANTA AGARWAL ,JAIPUR vs. DCIT CIRCLE 6, JAIPUR

Bench: HON’BLE SHRI SANDEEP GOSAIN (Judicial Member)

section 10(38) of the IT Act, 1961 from bogus scrip transactions during the year as under :- Name of Sale price Purchase price Transfer Exempt income company (in Rs.) (in Rs.) expenses claimed u/s 10(38) (In Rs.) M/s. Unno 22,58,954/- 1,19,618/- Claimed Nil 21,39,336/- Industries Ltd. Total : 21,39,336/- During the course

KANTA DEVI,JAIPUR vs. ITO WARD 6(5), JAIPUR

Bench: HON’BLE SHRI SANDEEP GOSAIN (Judicial Member)

section 10(38) of the IT Act, 1961 from bogus scrip transactions during the year as under :- Name of Sale price Purchase price Transfer Exempt income company (in Rs.) (in Rs.) expenses claimed u/s 10(38) (In Rs.) M/s. Unno 22,58,954/- 1,19,618/- Claimed Nil 21,39,336/- Industries Ltd. Total : 21,39,336/- During the course

JAIPAL SINGH,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR

price of the immovable property was Rs.40 lakhs. In the\ncourse of search action it has been found that the appellant has been regularly\nindulging in transactions of sale and purchase of immovable properties and it\ncannot be said that he is not having other sources of income and he has been\nearning income as middleman and income as gain