KANAK KUMAR JAIN L/H OF PARTNER OF M/S. KESARIYAJI FILLING STATION,UDAIPUR vs. DCIT, CIRCLE-1, UDAIPUR

In the result, appeals of the assessee are allowed

6) of section\n159.\nAs per provisions of section 189(3) all the legal heirs of the deceased partner(s) are jointly and\nseverally liable for any tax, penalty or other sum payable under Income tax Act, 1961 but for\naffixing such liability all the legal heir must be served with notice(s) and all the them must be\nmade

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

KANAK KUMAR JAIN L/H OF PARTNER OF M/S. KESARIYAJI FILLING STATION,UDAIPUR vs. DCIT, CIRCLE-1, UDAIPUR

In the result, appeals of the assessee are allowed

6) of section\n159.\nAs per provisions of section 189(3) all the legal heirs of the deceased partner(s) are jointly and\nseverally liable for any tax, penalty or other sum payable under Income tax Act, 1961 but for\naffixing such liability all the legal heir must be served with notice(s) and all the them must be\nmade

KANAK KUMAR JAIN L/H OF PARTNER OF M/S. KESARIYAJI FILLING STATION,UDAIPUR vs. DCIT, CIRCLE-1, UDAIPUR

In the result, appeals of the assessee are allowed

6) of section\n159.\nAs per provisions of section 189(3) all the legal heirs of the deceased partner(s) are jointly and\nseverally liable for any tax, penalty or other sum payable under Income tax Act, 1961 but for\naffixing such liability all the legal heir must be served with notice(s) and all the them must be\nmade

KANAK KUMAR JAIN L/H OF PARTNER OF M/S. KESARIYAJI FILLING STATION,UDAIPUR vs. DCIT, CIRCLE-1, UDAIPUR

In the result, appeals of the assessee are allowed

6) of section\n159.\nAs per provisions of section 189(3) all the legal heirs of the deceased partner(s) are jointly and\nseverally liable for any tax, penalty or other sum payable under Income tax Act, 1961 but for\naffixing such liability all the legal heir must be served with notice(s) and all the them must be\nmade

PARASMAL SAREMAL GOGAD,PALI vs. ITO, , PALI

In the result, appeal of the assessee is allowed

6) Guard File\nSd\n(DRAMITHA LAL MEENA)\nACCOUNTANT MEMBER\nBy Oder\nAssistant Registrar,\nIncome Tax Appellate Tribunal,\nJodhpur Bench,\nJodhpur.", "summary": {"facts": "The assessee's original return declared an income of Rs. 4,61,380/-. An assessment u/s 143(3) r.w.s. 153A was completed at Rs. 4,61,380/-. Subsequently, reassessment proceedings u/s 147 were initiated based on search

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 under section 147 of the IT Act after recording reasons duly approved by the PCIT vide his letter no. 3822 dated 22.03.2016 and accordingly issued notice u/s 148 of the IT Act on 22.03.2016 which was duly 13 Heera Lal Kasara, Udaipur. served on the assessee. In response, the assessee submitted that the return filed earlier

LALIT JOHARI,JODHPUR vs. ACIT, CENTRAL CIRCLE-2,, JODHPUR

In the result, the appeal of the assessee is allowed

Bench: Shri Kul Bharat & Shri Manish Borad40/Jodh/2019 (Assessment Year- 2014-15) Vs The Acit Shri Lalit Johri 65-A, Bank Colony, Rai Central Circle-2 Ka Bagh, Jodhpur Jodhpur (Appellant) (Respondent) Pan No. Agfpj 5542 H

147, section 148, section 1549, section 151 and section 153 in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003, the Assessing Officer shall – (a) Issue notice to such person requiring him to furnish within

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

reassessment proceedings only after properly after properly appreciating and analyzing the evidences. The information on the foundation of which Assessing Officer had initiated proceedings under section 147, was certain and constitutes sufficient and relevant material on the basis of which a reasonable person could have formed a belief that income of the appellant company had escaped assessment on account

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

reassessment proceeding u/s 148 is without any belief of escapement and on surmise and therefore assessment framed on such belief liable to be quashed. Assessment so framed may kindly be declared void ab initio. 2. That on the facts and in the circumstances of the case, the Ld. CIT (A) 1, Jodhpur erred in sustaining the assessment order framed

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

reassessment proceeding u/s 148 is without any belief of escapement and on surmise and therefore assessment framed on such belief liable to be quashed. Assessment so framed may kindly be declared void ab initio. 2. That on the facts and in the circumstances of the case, the Ld. CIT (A) 1, Jodhpur erred in sustaining the assessment order framed

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

reassessment proceeding u/s 148 is without any belief of escapement and on surmise and therefore assessment framed on such belief liable to be quashed. Assessment so framed may kindly be declared void ab initio. 2. That on the facts and in the circumstances of the case, the Ld. CIT (A) 1, Jodhpur erred in sustaining the assessment order framed

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

reassessment proceeding u/s 148 is without any belief of escapement and on surmise and therefore assessment framed on such belief liable to be quashed. Assessment so framed may kindly be declared void ab initio. 2. That on the facts and in the circumstances of the case, the Ld. CIT (A) 1, Jodhpur erred in sustaining the assessment order framed

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

reassessment proceeding u/s 148 is without any belief of escapement and on surmise and therefore assessment framed on such belief liable to be quashed. Assessment so framed may kindly be declared void ab initio. 2. That on the facts and in the circumstances of the case, the Ld. CIT (A) 1, Jodhpur erred in sustaining the assessment order framed

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

reassessment proceeding u/s 148 is without any belief of escapement and on surmise and therefore assessment framed on such belief liable to be quashed. Assessment so framed may kindly be declared void ab initio. 2. That on the facts and in the circumstances of the case, the Ld. CIT (A) 1, Jodhpur erred in sustaining the assessment order framed

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)

u/s 147 may kindly be declared as erroneous and void ab initio. 2. That on the facts and in the circumstances of the case, the Ld. CIT (A) erred in sustaining the addition made by Ld. AO for Rs. 78,60,000/-treating the amount received towards subscription of share capital as unexplained cash credit. The addition so sustained

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)

u/s 147 may kindly be declared as erroneous and void ab initio. 2. That on the facts and in the circumstances of the case, the Ld. CIT (A) erred in sustaining the addition made by Ld. AO for Rs. 78,60,000/-treating the amount received towards subscription of share capital as unexplained cash credit. The addition so sustained