DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. SAPNA KARNANI, TONK PHATAK

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

transferred from the lenders' respective bank accounts,\nwhich is a significant factor in establishing their capacity to lend.\n13.2 The Income Tax Appellate Tribunal (ITAT) in Gopal Krishan v. ACIT, ITA\nNo. 892/JP/2019, underscores this principle by affirming that when the source of\nfunds can be traced back to the bank accounts of the lenders, the onus of\nproving their

DCIT, CENTRAL CIRCLE, AJMER vs. M/S SILVERTOSS COMMODITIES PVT. LTD., KOLKATA

The appeals of the revenue stand dismissed and the cross objections of the assessee are partly allowed

132A of the Act, it is apparent that: (a) the assessments or reassessments, which stand abated in terms of II proviso to Section .153A of the Act, the AO acts under his original jurisdiction, for which, assessments have to he made; (b) regarding other cases, the addition to the income that has already been assessed, the assessment will be made

SAURABH AGROTECH PRIVATE LIMITED,ALWAR vs. DCIT, CENTRAL CIRCLE, ALWAR

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

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

132A of the Act, 1961. However, the completed/unabated assessments can be reopened by the AO in exercise of powers under sections 147/148 of the Act, subject to fulfilment of the conditions as envisaged/mentioned under sections 147/148 of the Act. If the interpretation as made by the Ld. CIT(A) is accepted then the direction of Hon’ble Supreme Court that

SOURABH AGROTECH PRIVATE LIMITED ,ALWAR vs. DCIT, CENTRAL CIRCLE, ALWAR

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

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

132A of the Act, 1961. However, the completed/unabated assessments can be reopened by the AO in exercise of powers under sections 147/148 of the Act, subject to fulfilment of the conditions as envisaged/mentioned under sections 147/148 of the Act. If the interpretation as made by the Ld. CIT(A) is accepted then the direction of Hon’ble Supreme Court that

JUHI BHANDARI, JAIPUR,JAIPUR vs. DCIT CIRCLE (INTL TAX), JAIPUR, JAIPUR

In the result, both appeals of the assessee are allowed

132A of the Act, 1961. However, the\ncompleted/unabated assessments can be re-opened by the AO in\nexercise of powers under Sections 147/148 of the Act, subject to\nfulfilment of the conditions as envisaged/mentioned under sections\n147/148 of the Act and those powers are saved.\nHon'ble Supreme Court in the case of DCIT v. U.K. Paints (Overseas)\nLtd

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. SAPNA KARNANI, TONK PHATAK

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

transferred from the lenders' respective bank accounts,\nwhich is a significant factor in establishing their capacity to lend.\n13.2 The Income Tax Appellate Tribunal (ITAT) in Gopal Krishan v. ACIT, ITA\nNo. 892/JP/2019, underscores this principle by affirming that when the source of\nfunds can be traced back to the bank accounts of the lenders, the onus of\nproving their

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S. MULTI METAL PRIVATE LTD., KOTA

132A, as the case may be, shall abate. Sub-section (2) of section 153A of the Act provides that if any proceeding or any order of assessment or reassessment made under sub-section (1) is annulled in appeal or any other legal provision, then the assessment or reassessment relating to any assessment year which had abated under the second proviso

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S. MULTI METAL PRIVATE LTD., KOTA

132A, as the case may be, shall abate. Sub-section (2) of section 153A of the Act provides that if any proceeding or any order of assessment or reassessment made under sub-section (1) is annulled in appeal or any other legal provision, then the assessment or reassessment relating to any assessment year which had abated under the second proviso

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S. MULTI METAL PRIVATE LTD., KOTA

132A, as the case may be, shall abate. Sub-section (2) of section 153A of the Act provides that if any proceeding or any order of assessment or reassessment made under sub-section (1) is annulled in appeal or any other legal provision, then the assessment or reassessment relating to any assessment year which had abated under the second proviso

M/S. MULTI METAL PRIVATE LTD.,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

132A, as the case may be, shall abate. Sub-section (2) of section 153A of the Act provides that if any proceeding or any order of assessment or reassessment made under sub-section (1) is annulled in appeal or any other legal provision, then the assessment or reassessment relating to any assessment year which had abated under the second proviso

M/S. MULTI METAL PRIVATE LTD.,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

132A, as the case may be, shall abate. Sub-section (2) of section 153A of the Act provides that if any proceeding or any order of assessment or reassessment made under sub-section (1) is annulled in appeal or any other legal provision, then the assessment or reassessment relating to any assessment year which had abated under the second proviso

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S. MULTI METAL PRIVATE LTD., KOTA

132A, as the case may be, shall abate. Sub-section (2) of section 153A of the Act provides that if any proceeding or any order of assessment or reassessment made under sub-section (1) is annulled in appeal or any other legal provision, then the assessment or reassessment relating to any assessment year which had abated under the second proviso

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S. MULTI METAL PRIVATE LTD., KOTA

132A, as the case may be, shall abate. Sub-section (2) of section 153A of the Act provides that if any proceeding or any order of assessment or reassessment made under sub-section (1) is annulled in appeal or any other legal provision, then the assessment or reassessment relating to any assessment year which had abated under the second proviso

M/S. MULTI METAL PRIVATE LTD.,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

132A, as the case may be, shall abate. Sub-section (2) of section 153A of the Act provides that if any proceeding or any order of assessment or reassessment made under sub-section (1) is annulled in appeal or any other legal provision, then the assessment or reassessment relating to any assessment year which had abated under the second proviso

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S. MULTI METAL PRIVATE LTD., KOTA

132A, as the case may be, shall abate. Sub-section (2) of section 153A of the Act provides that if any proceeding or any order of assessment or reassessment made under sub-section (1) is annulled in appeal or any other legal provision, then the assessment or reassessment relating to any assessment year which had abated under the second proviso

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, JAIPUR vs. M/S N. M. AGROFOOD PRODUCTS PVT. LTD., SRIGANGANAGAR

In the result the appeal of the revenue is dismissed

price is considered and rejected as the assessee has issued shares of Rs. 10 face value at a premium of Rs. 190 which by no stretch of imagination appears to be reasonable. iii. The assessee cannot at any time answer the fact that with such financial credentials how can a company or individual Invest such high share application money without

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S ORIENTAL POWER CABLES LTD., KOTA

132A, as the case may be, shall abate. Sub-section (2) of section 153A of the Act provides that if any proceeding or any order of assessment or reassessment made under sub-section (1) is annulled in appeal or any other legal provision, then the assessment or reassessment relating to any assessment year which had abated under the second proviso

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S ORIENTAL POWER CABLES LTD., KOTA

132A, as the case may be, shall abate. Sub-section (2) of section 153A of the Act provides that if any proceeding or any order of assessment or reassessment made under sub-section (1) is annulled in appeal or any other legal provision, then the assessment or reassessment relating to any assessment year which had abated under the second proviso