HEERA LAL KASARA,UDAIPUR vs. ITO, WARD-2(1), UDAIPUR

In the result, appeal of the assessee is allowed

Bench: Its Hearing Before Your Honours.”

reassessment proceedings initiated under section 147 of the Act. The objections of the assessee were duly disposed off by the AO vide his letter dated 15.12.2016.Thereafter, the AO issued show cause notice asking the assessee to show cause as to why the undisclosed GP of Rs. 47,79,046/- should not be treated as income from undisclosed sources vide letter

SHAHNAJ,NEAR BHERUDANJI WELL vs. INCOME TAX OFFICER, WARD-2, INCOME TAX OFFICE

In the result, the appeal of the assessee is allowed

Bench: Dr. S. Seethalakshmi & Dr Mitha Lal Meenasmt. Shanaj Vs The Ito W/O Shri Aslam Khan Ward-2, Churu, Near Bherudan Ji Well,Ward No. 22 Churu Sardarshahar,Churu – 331 403 (Appellant) (Respondent) Pan No. Fpmps 3570 D

reassessment proceeding U/s 147 of the Act without obtaining proper satisfaction and sanction from the superior authority U/s 151 of the Act. I have carefully considered the facts and submissions of the Learned AR and the decisions relied on by him. This is 3 SMT SHAHNAJ VS ITO, WARD-2, CHURU the case where originally the appellant had not filed

PREETI SINGHVI L/H SHRI AJAY SINGHVI,JODHPUR vs. ACIT, CIRCLE-3, JODHPUR

In the result, the appeal of the assessee is dismissed

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

10 E Road Sardarpura, Jodhpur 342001, Rajasthan [PAN: AOOPS6234G] (Appellant) (Respondent) Appellant by : None (W/S) Respondent by : Ms. Nidhi Nair, JCIT-DR Date of Hearing : 09.10.2023 Date of Pronouncement : 13.10.2023 ORDER Per Dr. M. L. Meena, AM: This captioned appeal has been filed by the assessee against the order of the ld.CIT(A) National Faceless Appeal Centre (NFAC), Delhi dated

M.G.B. GRAMIN BANK (THROUGH SUCCESSOR RAJASTHANMARUDHARA GRAMIN BANK),JODHPUR vs. ACIT, PALI

Appeals are disposed off in the terms indicated as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

section 147/148 by 10 ITA Nos. 504/Jodh/20218 &Ors. Asstt. CIT v. Rajasthan Marudhara Gramin Bank &Ors. way of reassessment proceedings without any reason to belief of escapement of income based on surmises, therefore, the assessee so framed deserves to be quashed. 3.2 In the present case, the Assessing Officer (AO) has supplied the copy of the reasons recorded

M.G.B. GRAMIN BANK (THROUGH SUCCESSOR RAJASTHANMARUDHARA GRAMIN BANK),JODHPUR vs. ADDITIONAL CIT, PALI

Appeals are disposed off in the terms indicated as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

section 147/148 by 10 ITA Nos. 504/Jodh/20218 &Ors. Asstt. CIT v. Rajasthan Marudhara Gramin Bank &Ors. way of reassessment proceedings without any reason to belief of escapement of income based on surmises, therefore, the assessee so framed deserves to be quashed. 3.2 In the present case, the Assessing Officer (AO) has supplied the copy of the reasons recorded

M.G.B. GRAMIN BANK (THROUGH SUCCESSOR RAJASTHANMARUDHARA GRAMIN BANK),JODHPUR vs. ADDITIONAL CIT, PALI

Appeals are disposed off in the terms indicated as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

section 147/148 by 10 ITA Nos. 504/Jodh/20218 &Ors. Asstt. CIT v. Rajasthan Marudhara Gramin Bank &Ors. way of reassessment proceedings without any reason to belief of escapement of income based on surmises, therefore, the assessee so framed deserves to be quashed. 3.2 In the present case, the Assessing Officer (AO) has supplied the copy of the reasons recorded

ACIT, CIRCLE, PALI. vs. M/S. RAJASTHAN MARUDHARA GRAMIN BANK, , JODHPUR

Appeals are disposed off in the terms indicated as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

section 147/148 by 10 ITA Nos. 504/Jodh/20218 &Ors. Asstt. CIT v. Rajasthan Marudhara Gramin Bank &Ors. way of reassessment proceedings without any reason to belief of escapement of income based on surmises, therefore, the assessee so framed deserves to be quashed. 3.2 In the present case, the Assessing Officer (AO) has supplied the copy of the reasons recorded

M.G.B. GRAMIN BANK (THROUGH SUCCESSOR RAJASTHANMARUDHARA GRAMIN BANK),JODHPUR vs. ACIT, PALI

Appeals are disposed off in the terms indicated as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

section 147/148 by 10 ITA Nos. 504/Jodh/20218 &Ors. Asstt. CIT v. Rajasthan Marudhara Gramin Bank &Ors. way of reassessment proceedings without any reason to belief of escapement of income based on surmises, therefore, the assessee so framed deserves to be quashed. 3.2 In the present case, the Assessing Officer (AO) has supplied the copy of the reasons recorded

M.G.B. GRAMIN BANK (THROUGH SUCCESSOR RAJASTHANMARUDHARA GRAMIN BANK),JODHPUR vs. ACIT, PALI

Appeals are disposed off in the terms indicated as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

section 147/148 by 10 ITA Nos. 504/Jodh/20218 &Ors. Asstt. CIT v. Rajasthan Marudhara Gramin Bank &Ors. way of reassessment proceedings without any reason to belief of escapement of income based on surmises, therefore, the assessee so framed deserves to be quashed. 3.2 In the present case, the Assessing Officer (AO) has supplied the copy of the reasons recorded

RAJ KUMAR GOLECHA,PALI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JODHPUR, AAYKAR BHAWAN, JODHPUR

In the result, appeal of the assessee is allowed

147,\nsection 148, section 149, section 151 and section 153, in the case of a person\nwhere a search is initiated under section 132 or books of account, other\ndocuments or any assets are requisitioned under section 132A after the 31st\nday of May, 2003, the Assessing Officer shall—\n(a) issue notice to such person requiring him to furnish

DAWOODI BOHRA JAMAT,UDAIPUR vs. ITO WARD EXEMPTION UDAIPUR, UDAIPUR

In the result, appeal of the assessee is allowed

Bench: DR. MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

section 147 and 151 and accordingly notice u/s 148 was issued to assessee— Proceedings u/s 147/148 were initiated after recording reasons on basis of information received from Investigation Wing of Department on basis of search and seizure operation. During course of assessment proceedings, assessee was specifically asked to explain and justify transaction with G received as share application money/share capital

M/S. SUPER SHIV SHAKTI MINCHEM PVT. LTD.,JODHPUR vs. ITO, WARD-3, , BHILWARA

In the result, both the above appeals filed by the Assessee are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), DR. MITHA LAL MEENA (Accountant Member)

reassessment order framed under section 147 read with sections 144 and 254 of the Income Tax Act, 1961 for the Assessment Year 2009–10. 2. Since the issues involved in both the above appeals are common and were heard together, therefore, they are being disposed off by this consolidated order for the sake of convenience and brevity. We shall take

M/S. SUPER SHIV SHAKTI MINCHEM PVT. LTD.,JODHPUR vs. ITO, WARD-3, , BHILWARA

In the result, both the above appeals filed by the Assessee are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), DR. MITHA LAL MEENA (Accountant Member)

reassessment order framed under section 147 read with sections 144 and 254 of the Income Tax Act, 1961 for the Assessment Year 2009–10. 2. Since the issues involved in both the above appeals are common and were heard together, therefore, they are being disposed off by this consolidated order for the sake of convenience and brevity. We shall take

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

In the result, appeal of the assessee is dismissed

reassessment or reopening of the assessment. The\ncase is squarely covered by the above judgment. Therefore, to complete\nassessment on the basis of illegal notice is illegal and void.\nOn the similar principals, the order of the Karnataka High Court in the case of\nManjunath Cotton Corp and M/s. SSSA Emerald Meadows, on the issue of\npenalty u/s

SAMPAT LAL LODHA ,NATHDWARA vs. ITO, WARD-2, RAJSAMAND

In the result, both appeals of the assessee are allowed

reassessment proceedings an invalid........” iv] On the identical facts the Hon’ble ITAT Agar Bench in the case of Shri. Raj Singh Vs ITO (ITAT Agra) ITA No. 408/Agra/2018 Date of Order : 22/03/2019 "29. The text of the reasons recorded do proves that virtually there has been no application of mind by the learned Assessing officer so as to form

SAMPAT LAL LODHA ,NATHDWARA vs. ITO, WARD-2, RAJSAMAND

In the result, both appeals of the assessee are allowed

reassessment proceedings an invalid........” iv] On the identical facts the Hon’ble ITAT Agar Bench in the case of Shri. Raj Singh Vs ITO (ITAT Agra) ITA No. 408/Agra/2018 Date of Order : 22/03/2019 "29. The text of the reasons recorded do proves that virtually there has been no application of mind by the learned Assessing officer so as to form

PRAKASH CHANDRA JAIN,UDAIPUR vs. ITO, WARD-1(1), UDAIPUR

In the result, the appeal filed by the revenue is dismissed

Bench: Shri B. R. Baskaran & Shri Sandeep Gosainsh. Prakash Chandra Jain, Vs Income Tax Officer 67-68, Hiran Magri, Sector Ward 1(1), Udaipur No. 08, Udaipur (Appellant) (Respondent) Pan No. Aavpj 3696 E

u/s 147 of the I.T. Act. As discussed above, in my opinion, source of amount deposited in the saving bank account at Rs. 16,00,000/- may be verified and same has escaped assessment within the meaning of Sec 147 of the IT. Act. 1961. Issue notice under section 148 of IT. Act. 1961.” 8 Prakash Chandra Jain Udaipur

JS ENGINEERING WORKS,SAWA, CHITTORGARH vs. DCIT, CENTRAL CIRCLE, CHITTORGARH

In the result, all these 6 appeals filed by the assessee are allowed

Bench: Dr. Mitha Lal Meena, Hon’Ble & Sudhir Pareek, Hon’Blestay Application No. 8 To 13/Jodh/2024 (Arising Out Of Ita Nos. 620, 621, 622, 624, 625 &628/Jodh/2024) (Assessment Year – 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 & 2017-18) Js Engineering Works Dcit, Central Circle, J-16, M/S. Sclj & Associates, Chittorgarh. Lal Kothi Yojana, Sahakar Marg, Jaipur – 302015. Pan No. Aaffj 9260 Q

10,40,76,946 7,59,08,853 2,81,68,093 6 622/Jodh/2024 & Others Assessment Years 2012-13 to 2017-18 2016-17 11,58,22,004 9,00,99,045 2,57,22,959 2017-18 8,91,78,138 8,64,93,022 26,85,116 The ld. AO has observed during the assessment proceedings that shut