notice u/s 148 ,
the AO is under obligation to cause inquiries and to have reasons for issuing
notice u/s 148 . No notice ... Assessing
Officer has erred in passing the order u/s 147 read with section 144B
of the Income Tax Act, 1961 which is without recording
validity of reopening of the case of the assessee under section
147 read with section 148 of the IT Act.
2. Before ... Jaipur. Consequently the AO while initiating
proceedings under section 148 recorded following reasons under section 147 of the
Act :-
"An inquiry report
general accumulation
u/s 11(1)(a) : Rs. 24,72,465/-
Less: Accumulation u/s 11(2) : Rs. 1,64,996/-
For the year under ... general accumulation u/s 11(2) amounting to Rs. 24,72,465/-.
(iv) Accumulation u/s 11(2) amounting
general accumulation
u/s 11(1)(a) : Rs. 24,72,465/-
Less: Accumulation u/s 11(2) : Rs. 1,64,996/-
For the year under ... general accumulation u/s 11(2) amounting to Rs. 24,72,465/-.
(iv) Accumulation u/s 11(2) amounting
noted from the above details that during the course of survey u/s
133A of the Act, Shri Naresh Jain, the Director of the appellant ... Shri Naresh Jain and Shri Bunkar recorded
during the course of survey u/s 133A of the Act. The AO disallowed 75%
of the stipend
said allowances were exempt from tax under Section 10(14) and, therefore, the provisions of Section 192(1) did notapply in respect thereto ... under Section 192(1) and Rs. 1,48,465 as interest under Section 201 (1A) thereupon. The Board appealed
Jaipur, after recording reasons and taking prior approval of
appropriate authority, notice u/s 148 dated 28/02/2014 was issued
and served through registered ... Less: Deduction u/s Chapter VI-A Rs. 60,823/-
Total Taxable Income Rs. 14,27,465/-
Rounded Off-- Rs. 14,27,470/-
Even
Weaving Mills Ltd. 274 ITR 465, it is held that the above expenditure is
allowable as a deduction ... u/s
37(1) . For this reliance is placed on the following cases:-
CIT Vs. Rajasthan Spinning and Weaving Mills Ltd. 274 ITR 465
above provision, it is evident that
before invoking the provision of this section following two conditions
must be satisfy simultaneously:
a. Order passed ... submits that during the
assessment proceedings, various notices were issued including notice
u/s 142(1) of the Act dated 07.11.2019 was issued
Sanjay Kumar Karnani,Jaipur vs Acit, Central Circle-3, Jaipur on 15 October, 2025
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