VIKRAM ANJANA,PRATAPGARH vs. ACIT, CIRCLE, CHITTORGARH

In the result, the appeal of the assessee is allowed

Bench: Shri N.K. Sainishri Vikram Anjana, Vs The Acit, Vill - Kesunda, Circle-Chittorgarh Tehsil Chhotisadri, Pratapgarh (Raj.) 312604

B). h) The said deeming provisions are not applicable to the orders passed by the Commissioner of Appeals and the Commissioner. i) The imposition of penalty is not automatic. j) Imposition of penalty even if the tax liability is admitted is not automatic. k) Even if the assessee has not challenged the order of assessment levying tax and interest

CHAINARAM,JODHPUR vs. ITO, WARD-3(1), JODHPUR

In the result, the captioned appeals of the assesses in ITA Nos

Bench: Shri Laliet Kumar, Hon'Ble & Dr. Mitha Lal Meena, Hon'Ble

reassessment proceedings. Accordingly, he pleaded that the matter may be remanded back to the AO to pass de novo assessment after granting adequate opportunity of being heard. In support, he placed reliance on Judgement of Delhi High Court in the case of "Bharat Aluminium Company Ltd. vs. Union of India", [2022] 134 taxmann.com 187 (Delhi) where it was observed that

CHAINARAM,JODHPUR. vs. ITO, WARD-3(1), JODHPUR

In the result, the captioned appeals of the assesses in ITA Nos

Bench: Shri Laliet Kumar, Hon'Ble & Dr. Mitha Lal Meena, Hon'Ble

reassessment proceedings. Accordingly, he pleaded that the matter may be remanded back to the AO to pass de novo assessment after granting adequate opportunity of being heard. In support, he placed reliance on Judgement of Delhi High Court in the case of "Bharat Aluminium Company Ltd. vs. Union of India", [2022] 134 taxmann.com 187 (Delhi) where it was observed that

CHAINARAM,JODHPUR vs. ITO, WARD-3(1), JODHPUR

In the result, the captioned appeals of the assesses in ITA Nos

Bench: Shri Laliet Kumar, Hon'Ble & Dr. Mitha Lal Meena, Hon'Blechainaram V/P Doli Tehsil Luni, Jodhpur - 342001. Pan No Biкpr9270C Assessee By Revenue By Date Of Hearing Date Of Pronouncement Ito, Ward-3(1), Jodhpur. Shri Anil Bhansali, Advocate. Shri Karni Dan, Addl. Cit (Sr. D.R.) 21.05.2025. 26.06.2025. 17

reassessment proceedings. Accordingly, he pleaded that the matter may be remanded back to the AO to pass de novo assessment after granting adequate opportunity of being heard. In support, he placed reliance on Judgement of Delhi High Court in the case of "Bharat Aluminium Company Ltd. vs. Union of India", [2022] 134 taxmann.com 187 (Delhi) where it was observed that

DEEPAK KUMAR RAJORIA,AHMEDABAD vs. ITO, WARD-1(2), BIKANER

In the result, the appeal of the assessee is allowed

Bench: Assessing Authority Tax Was Paid & Adjust From Tds The Appellant Was Aware Of The Fact That There Is Any Form By Filing Which The Penalty May Be Dropped So The Penalty Was Never Leviable In This Case Therefore The Penalty U/S 270A May Please Be Cancelled. 3. The Appellant Prays For Justice & Relief. 4. The Appellant May Please Be Permitted To Raise Any Addition Or Alternative Ground At Or Before The Hearing.”

reassessment under sub- section (3) of section 143 or section 147, as the case may be, has been paid within the period specified in such notice of demand; and (b) no appeal has been filed The application has to be made in form No. 68 within 30 days from the end of the month in which the order has been

RACHNA GOYAL,JODHPUR vs. ITO, WARD-1(2), JODHPUR

In the result, appeal of the assessee is dismissed

b) of\nexplanation 2 to section 147 are applicable in this case, obtained necessary\nsanction separately to issue notice under section 148 from Principal Commissioner\nof Income Tax as per the provisions of section 151 of the IT Act, 1961. Notice\nunder section 148 of the IT Act was issued on 26.03.2021 and duly served upon the\nassessee through ITBA