Rameshwar Prasad Shringi Vs PCIT (ITAT Jaipur) Assessing officer has carried out exhaustive enquiries and verifications regarding source of cash deposits in the bank account during the financial year relevant to impugned assessment year. The bank statements, the cash book, the ledger accounts, the financial statements for the year under consideration and for the earlier […]
Bansiwala Iron & Steel Rolling Mills Vs DCIT (ITAT Jaipur) Since the A.O. is a quasi-judicial authority, who has to collect the evidences, material and then to adjudicate the matter after due and complete application of mind. The A.O. expected to record his own satisfaction before reaching to any conclusion. In our view, the A.O. […]
ITAT Jaipur: Challenge against PCIT invoking Section 263 for large share premium. AO’s proper examination defended. Grounds and merits discussed.
Naina Saraf Vs PCIT (ITAT Jaipur) Section 56(2)(vii)(b)(ii) cannot be applied prior to a A.Y. 2014-15 as section comes into effect from A.Y. 2015-16 The Finance Act, 2013 inserted clause (ii) in S. 56(2)(vii)(b) reading as under: ‘(ii) for a consideration which is less than the stamp duty value of the property by an amount […]
Sanjay Matai Vs ITO (ITAT Jaipur) From perusal of record, we observed that Section 254 of the Act read with Rule 29 of the Income Tax (Appellate Tribunal) Rules, 1963 states about power to admit additional evidences, whether mere fact that evidence sought to be produced is vital and important does not provide a substantial […]
Learned counsel submits that the petitioner moved an application in terms of Section 144B 7(vii) seeking an opportunity of personal hearing which has been denied. Learned counsel submits that fair opportunity has not been provided to put up their submissions and defence and the order goes beyond the contents of the show cause notice.
ACIT Vs M/s. Mayo College General Council (ITAT Jodhpur) The deduction of depreciation for Rs.300.37 Lacs as claimed by the assessee was denied by Ld. AO on the reasoning that cost of fixed asset is an application of income and therefore further deduction of depreciation tantamount to double deduction. The Ld. CIT(A) allowed depreciation by […]
A Comprehensive Guide to E-Assessment- A Faceless, Nameless and Jurisdictionless Assessment. Article explains Historical Development related to Income Tax E-Assessment, E-proceedings v/s E-Assessment, Assessment through E-proceeding – Recent Past, Prime Objective of Income Tax E-Assessment, Expected Benefits of Income Tax E-Assessment, Organizational Structure for Income Tax E-Assessment, Role of various Agencies such as NeAC, ReAC, […]
1. The provisions related to reassessment u/s 147 to 151 of the Income Tax Act, 1961 (Act) has been the most litigated piece of legislation and this saga continues so. The powers conferred upon the Assessing Office, under section 147 of the Act, to reopen a concluded assessment is certainly wide in scope and the […]