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 :

153D of the Act 9. Under the facts and circumstances of the case and in law, Ld. CIT (A) erred in holding that on money of Rs. 1,42,50,000/- was paid by Assessee. 10. Under the facts and circumstances of the case and in law, Ld. CIT (A) erred in confirming the impugned addition

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 :

153D of the Act 9. Under the facts and circumstances of the case and in law, Ld. CIT (A) erred in holding that on money of Rs. 1,42,50,000/- was paid by Assessee. 10. Under the facts and circumstances of the case and in law, Ld. CIT (A) erred in confirming the impugned addition

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

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

153D of the\nAct\n9. Under the facts and circumstances of the case and in law, Ld. CIT (A)\nerred in holding that on money of Rs.1,42,50,000/- was paid by Assessee.\n10. Under the facts and circumstance of the case and in law, Ld. CIT (A) erred\nin confirming the impugned addition of Rs.78

PRAMILA AGARWAL,JAIPUR vs. THE INCOME TAX OFFICER WARD-2(5), JAIPUR

In the result, the appeal of the assessee is allowed

153D have prevalence over regular provisions for assessment or\nreassessment under sections 148 & 147/148 - Held, yes - Whether therefore, where\nbasis for initiation of section 148 proceedings in case of assessee was material seized\nrelating to or belonging to assessee during search conducted on ‘M' Group, notices\nissued under section 148 and impugned orders rejecting objections filed to issuance of\nnotice

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

153D and Section 148 are different Applicability of Section 153C in cases where the\n17\nITA Nos.709/JP/2025\nDCIT vs. Sapna Karnani\nseized material related to or belonged toperson other than on whom search is conducted\nor requisition made does not render Section 148 otiose Section 148 shall continue to\napply to the regular proceedings and also in cases where

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

153D and Section 148 are different Applicability of Section 153C in cases where the\n17\nITA Nos.709/JP/2025\nDCIT vs. Sapna Karnani\nseized material related to or belonged toperson other than on whom search is conducted\nor requisition made does not render Section 148 otiose Section 148 shall continue to\napply to the regular proceedings and also in cases where

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

153D and Section 148 are different Applicability of Section 153C in cases where the\n\n17\nITA Nos.709/JP/2025\nDCIT vs. Sapna Karnani\nseized material related to or belonged toperson other than on whom search is conducted\nor requisition made does not render Section 148 otiose Section 148 shall continue to\napply to the regular proceedings and also in cases where

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

153D is not found to be acceptable.\n5.2.7 No Prejudice is Caused to the Assessee\nWithout prejudice to the above, there is no prejudice is caused by the assessee in\ngranting approval by the Additional CIT in small period of time. The appellant has\nnot discussed what prejudice is caused to the assessee if the approval is granted\nin small

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 &

153D is not found to be acceptable. 5.2.7 No Prejudice is Caused to the Assessee Without prejudice to the above, there is no prejudice is caused by the assessee in granting approval by the Additional CIT in small period of time. The appellant has not discussed what prejudice is caused to the assessee if the approval is granted in small

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

price agreed and the same was not transferred on account of pandemic but were subsequently based on the consideration paid transferred and relevant capital gain is also offered. So as to find the truth on the issue bench directed the ld. DR to call for the status report to confirm the contentions of the assessee as confirmed

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

price agreed and the same was not transferred on account of pandemic but were subsequently based on the consideration paid transferred and relevant capital gain is also offered. So as to find the truth on the issue bench directed the ld. DR to call for the status report to confirm the contentions of the assessee as confirmed

INCOME TAX OFFICER , SIKAR vs. BHASKAR CHAUHAN, JAIPUR

In the result the appeal of the revenue in ITA no

Bench: Him.

153D have prevalence over the regular provisions for assessment or reassessment under Section 143 & 147/148. 27. Section 153A and 153C starts with non-obstante clause. The procedure for assessment/reassessment in Section 153A, 153C in cases of search or requisition has an overriding effect to the regular provisions for assessment or reassessment under Sections

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

section 147 in the reason was typographical error, if considered correct, 46 Lovely promoters Pvt. Ltd. vs. ACIT non-observation of such serious typographical error by two senior officers i.e. (i) Range Head forwarding reason to approval authority with recommendation for approval and (ii) Pr. CIT, approving Authority. Non observation of such serious typographical error led to the conclusion that

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

In the result, both appeals of the assessee are allowed

transfer\npricing orders wherein downward adjustments were made to the price\npaid for the equipment imported by the AE. The Assessee had filed an\nappeal to this Tribunal against the appellate order for Assessment Year\n2013-14 (arising from the assessment under Section 143(3) and the TPO\norder). This appeal was disposed in RKM POWERGEN PRIVATE\nLIMITED

ANSHU SAHAI (HUF),JAIPUR vs. ACIT, CENTRAL CIRCLE, CENTRAL CIRCLE

153D has vitiated the assessment order.\n3. In the facts and circumstances of the case and in law, ld. CIT(A) has erred \nin upholding the addition amounting to Rs.16,21,91,214/- (albeit as part of capital \ngains). The action of the ld. CIT(A) is illegal, unjustified, arbitrary and against the \nfacts of the case. Relief may please

AJAY BAKLIWAL,KOTA vs. ACIT, CENTRAL CIRLE, KOTA, KOTA

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

section 132 of the Income Tax act together. The documents related to dissolution of JV of both of them were found from the premises of both the persons. Both of them accepted that the transaction in question was not loan but an accommodation entry against the settlement of dispute. In fact, some of the amounts as per seized paper

DCIT, JAIPUR vs. AMRAPALI JEWELS PVT. LTD. , JAIPUR

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

Bench: Him.

153D of the Act. 3. Under the facts and circumstances of the case and in law, the Ld. CIT(A)- 4, Jaipur has erred in sustaining the very invocation of provision of Section 69B of the Act by the Ld. AO as bad in law. 4. Under the facts and circumstances of the case

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

section 153A of the Act. Thus the said judgment is inapplicable under the facts of the present case. Another judgment cited by ld. D/R is in the case of Harshvardhan Johari vs. DCIT (2020) 118 taxmann.com 449 (Jaipur-Trib) wherein it was held that the notice under section 143(2) of the Act was not issued though the time