VIRENDRA PRAKASH SHARMA,JAIPUR vs. DCIT CIRCLE (INTL TAX), JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

transfer of funds was demonstrated by Id. AO which facts were not in\ndispute. In the present case, the lower authorities have arbitrarily presumed—\nwithout any direct or indirect evidence, basis, or corroboration—that a vague and\nrough entry found during search pertains specifically to the assessee. Such\ninference is wholly unjustified and devoid of any factual or legal basis

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

INCOME TAX OFFICER , SIKAR vs. BHASKAR CHAUHAN, JAIPUR

In the result the appeal of the revenue in ITA no

Bench: Him.

153B and section 153C, all other provisions of this Act shall apply to the assessment made under this section; (ii) in an assessment or reassessment made in respect of an assessment year under this section, the tax shall be chargeable at the rate or rates as applicable to such assessment year. Assessment of income of any other person. 153C

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-3, JAIPUR vs. SAPNA KARNANI, TONK PHATAK

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

153B of the Act of 1961. The\nrespondent authority was fully aware of the fact that proceedings under section 153C of\nthe Act of 1961 would be barred by limitation, therefore, recourse was taken to the\nprovisions contained in Section 148 and Section 148A of the Act of 1961 which has no\napplication in the present cases.\n\n18\nITA

SHRI MADHO LAL SAINI,JAIPUR vs. ITO, WARD-2(3), JAIPUR

In the result, the appeals of the assessees are allowed

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

153B. 53. The question now is - what is the scope of assessment or reassessment of total income u/s 153A (1) (b) and the first proviso? We are of the view that for answering this question, guidance will have to be sought from section 132(1). If any books of account or other documents relevant to the assessment had not been

ASSISTANT COMMISSIONER OF INCOME TAX,EXEMPTIONS,CIRCLE,JAIPUR, JAIPUR vs. GLOBAL INSTITUTE OF TECHNOLOGY SOCIETY, JAIPUR RAJASTHAN

In the results the appeal of the revenue stands dismissed

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

transfer pricing proceedings that no one would have lent money to the subsidiary unless there was an implied guarantee by the parent company. (The loan agreement did have a clause for a corporate guarantee to be provided if required by the lenders but, on facts, no such guarantee was called for.) However, the TPO made an addition

SANDEEP KHERADA,JAIPUR vs. THE INCOME TAX OFFICER, JAIPUR

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

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

section 144 r.w.s 153B(1)(b) of the Income Tax Act, by ITO, Ward-5(2), Jaipur. 2. In this appeal, the assessee has raised following grounds: - 2 Sandeep Kherada vs. ITO 1. On the facts and in the circumstances of the case and in law, Id.CIT(A) has grossly erred in not accepting the plea of assessee regarding purchases

VINODKUMAR AGARWAL,AJMER vs. DCIT, CENTRAL CIRCLE, AJMER

Price. Cost Expens Cost of\nel Year Year\nes Improvel\nCost\nPLOT 87, HBU NAGAR\nAJMER\n15/02/2\n006\n034/32\n670000\n311740\n000\n000\n000\n358260\n0.00\n670000\n165000\n0.00\n00\n00\nPEARL ANANDA (500\n2013-14\n280041\n0.00\n0.00\n0.00\n0.00\n260041\n0.00\n260041\n0.00\n0.00\nVALUE\n00\n00\nTotal\n930041\n311740\n0.00\n000\n000\n618301\n0.00\n930041\n165000\n0.00

KAILASH CHAND MAHESHWARI,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX , JAIPUR

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

section 57 (iii) of the Act. We thus decline to interfere with the action of the Assessing Officer and the First Appellate Authority." The onus is on the appellant to show one-to-one matching and prove that the interest expenditure for the borrowed funds have been used wholly and exclusively only for the purpose of making investments which have

KAILASH CHAND MAHESHWARI,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX,CENTRALCIRCLE-2, JAIPUR

section 57 (iii) of the Act. We thus decline to\ninterfere with the action of the Assessing Officer and the First Appellate Authority.\"\nThe onus is on the appellant to show one-to-one matching and prove that the\ninterest expenditure for the borrowed funds have been used wholly and exclusively\nonly for the purpose of making investments which have

KAILASH CHAND MAHESHWARI,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, , JAIPUR

section 57 (iii) of the Act. We thus decline to\ninterfere with the action of the Assessing Officer and the First Appellate Authority.\"\nThe onus is on the appellant to show one-to-one matching and prove that the\ninterest expenditure for the borrowed funds have been used wholly and exclusively\nonly for the purpose of making investments which have

ACIT, CENTRAL CIRCLE, KOTA vs. BANAS MINERALS PRIVATE LIMITED, JHALAWAR

In the result the appeal of the revenue in ITA no

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

price disclosed in the excel sheet with that of the book being added for an amount of Rs. 5,05,81,050/- in the hands of the assessee is required to be sustained. The ld. AO even in the remand proceedings confirmed the statement of the assessee which accountant Shri Devendra Shekhawat. Subsequently, retracted at the remand proceedings, therefore

ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. BANAS MINERALS PRIVATE LIMITED, JHALAWAR

In the result the appeal of the revenue in ITA no

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

price disclosed in the excel sheet with that of the book being added for an amount of Rs. 5,05,81,050/- in the hands of the assessee is required to be sustained. The ld. AO even in the remand proceedings confirmed the statement of the assessee which accountant Shri Devendra Shekhawat. Subsequently, retracted at the remand proceedings, therefore

ASSISTANT COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE, KOTA vs. BANAS BUILDERS AND DEVELOPERS LLP, JHALAWAR

In the result the appeal of the revenue in ITA no

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

price disclosed in the excel sheet with that of the book being added for an amount of Rs. 5,05,81,050/- in the hands of the assessee is required to be sustained. The ld. AO even in the remand proceedings confirmed the statement of the assessee which accountant Shri Devendra Shekhawat. Subsequently, retracted at the remand proceedings, therefore

WHOLE SALE CLOTH MERCHANT ASSOCIATION ,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE KOTA , KOTA

price) from the concerning person of all the 22 plots has not been taken in\nbooks.\n\n4. The trust property is used Personal benefit of the president\nShri Tejndra Pal Singh has taken loan & advances of Rs.31,50,000/- from the\ntrust and violated the provisions of section 13(2) of the Act. Further no proper\nbooks of accounts

WHOLE SALE CLOTH MERCHANT ASSOCIATION ,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE KOTA , KOTA

In the result, the appeals of the assessee in ITA no

price) from the concerning person of all the 22 plots has not been taken in\nbooks.\n4. The trust property is used Personal benefit of the president\nShri Tejndra Pal Singh has taken loan & advances of Rs. 31,50,000/- from the\ntrust and violated the provisions of section 13(2) of the Act. Further no proper\nbooks of accounts

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)

153B of the Act were issued to the assessee. In response, the assessee filed return of income for the AY 2007-08 on 28.03.2008 declaring total income of Rs. 83,69,090/-. Accordingly, after making complete inquiry, the assessment order u/s 153A of the Act was passed on 24.12.2009 making certain addition of Rs. 99,63,801/- on account