SVARAJ TRADING AND AGENCIES LTD,MAHARASHTRA vs. "ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, UDAIPUR", UDAIPUR

IN THE INCOME TAX APPELLATE TRIBUNAL JODHPUR BENCH, JODHPUR BEFORE DR. MITHA LAL MEENA, HON’BLE ACCOUNTANT MEMBER AND SHRI SUDHIR PAREEK, HON’BLE JUDICIAL MEMBER ITA Nos. 777, 778 & 779/Jodh/2025 (Assessment Years – 2020-21, 2021-22 & 2023-24) Svaraj Trading and Agencies Ltd. Assistant Commissioner of Office No. 30 380/82 Income Tax, Central Circle-1 Amrutesshwar CHS, 2nd Floor, Udaipur Jagannath Sunkersett Road, Mumbai - 400002 PAN No. AAACS 5412 R ITA Nos. 870, 871 & 872/Jodh/2025 (Assessment Years – 2020-21, 2021-22 & 2023-24) Miraj Creation Private Limited Assistant Commissioner of (Successor of Magenta Dealcom Income Tax, Central Circle-1 Pvt. Ltd. Udaipur 3rd Floor, Acme Plaza-II, Andheri Kurla Road, Opposite Sangam Big Cinema, Andheri (East), Mumbai City, Mumbai-400059 PAN No. AABCL 1157 B

ITA Nos. 746, 747, 748 & 790/Jodh/2025 (Assessment Years – 2020-21, 2021-22, 2023-24 & 2022-23) Mountain Vintrade Pvt. Ltd. Assistant Commissioner of 30, Floor-2 Plot-380/382, Nana Income Tax, Central Circle-1, Shankar Sheth Smruti JS Road Udaipur Kalbadevi, Mumbai-400002 PAN No. AAGCM 8818 B

2 ITA Nos. 777,778,779,870,871,872/Jodh/2025 ITA Nos. 746,747,748,790,749,750,751,793/Jodh/2025 Asst. Years: 2020-21 to 2023-24 ITA Nos. 749, 750, 751 & 793/Jodh/2025 (Assessment Years – 2020-21, 2021-22, 2023-24 & 2022-23) Akruti Tradehub Pvt. Ltd. Assistant Commissioner of Office No. 30, 2nd Floor 380/82 Income Tax, Central Circle-1, Amruteshwar CHL Ltd. Jagnath Udaipur Sunkersett Road Chira Bazar, Maharashtra-400002 PAN No. AAKCA 9315 P

Assessee by Shri M.S. Jhanwar, CA and Shri Kamlesh Mundra, CA (Physical) Smt. Seema Meena, CIT-DR (Virtual) Revenue by

Date of Hearing 19 / 05 / 2026 & 20 / 05 / 2026 Date of Pronouncement 03 / 06 / 2026. ORDER PER BENCH: This appeal by assessee is filed against the order of Ld. Commissioner of Income Tax Appeals, Udaipur-2 [hereinafter referred to CIT(A)] dated 30.07.2025, 10.07.2025 & 28.07.2025 with respect to Assessment Years 2020-21, 2021-22 & 2023-24.

3 ITA Nos. 777,778,779,870,871,872/Jodh/2025 ITA Nos. 746,747,748,790,749,750,751,793/Jodh/2025 Asst. Years: 2020-21 to 2023-24 ITA No. 777/Jodh/2025 (Assessment Year: 2020-21)

4 ITA Nos. 777,778,779,870,871,872/Jodh/2025 ITA Nos. 746,747,748,790,749,750,751,793/Jodh/2025 Asst. Years: 2020-21 to 2023-24 4. The appellant craves leave to add, amend, alter, delete or modify any of the above grounds of appeal, either before or during the hearing of this appeal. ITA No. 778/Jodh/2025 (Assessment Year: 2021-22)

5 ITA Nos. 777,778,779,870,871,872/Jodh/2025 ITA Nos. 746,747,748,790,749,750,751,793/Jodh/2025 Asst. Years: 2020-21 to 2023-24 3. "Under the facts and circumstances of the case and in law, the Id. CIT(A) has grossly erred in the disallowance of Rs.23,21,940/- on account of Salary expenses as against actually claimed Rs.18,80,194/- which is also separately disallowed." 4. "That the learned CIT(A) further erred in confirming the levy of interest under Sections 234B and 234C, which is not chargeable on the facts of the case. The interest is purely consequential to the above disallowance and ought to be deleted if and to the extent the underlying addition is deleted. (The appellant denies its liability to such interest.) 5. “The appellant craves leave to add, amend, alter, delete or modify any of the above grounds of appeal, either before or during the hearing of this appeal." 2.1 The assessee Miraj Creations Pvt. Ltd. Has raised following grounds of appeal:

ITA No. 870/Jodh/2025 (Assessment Year: 2020-21)

6 ITA Nos. 777,778,779,870,871,872/Jodh/2025 ITA Nos. 746,747,748,790,749,750,751,793/Jodh/2025 Asst. Years: 2020-21 to 2023-24 1. “Under the facts and circumstances of the case and in law, the orders of the authorities below (the assessment order as upheld in the impugned CIT(A) order) have been passed without due consideration of relevant facts and applicable law, rendering are arbitrary, perverse and contrary to settled principles, and the assessment improper. The resultant disallowances/additions therefore the entire disallowance of Rs. 6,64,563/- deserves to be deleted and the impugned order quashed." 2. "That the learned CIT(A) erred in upholding the disallowance of Rs.6,64,563, being bona fide business expenditures (such as salaries, rent and administrative expenses) incurred wholly and exclusively for the purposes of the business, which are fully allowable under Section 37(1) of the Income Tax Act, 1961. The disallowance is unjustified on facts and in law." 3. "That the learned CIT(A) further erred in confirming the levy of interest under Sections 234B and 234C, which is not chargeable on the facts of the case. The interest is purely consequential to the above disallowance and ought to be deleted if and to the extent the underlying addition is deleted. (The appellant denies its liability to such interest.)" 4. “The appellant craves leave to add, amend, alter, delete or modify any of the above grounds of appeal, either before or during the hearing of this appeal." ITA No. 872/Jodh/2025 (Assessment Year: 2023-24)

7 ITA Nos. 777,778,779,870,871,872/Jodh/2025 ITA Nos. 746,747,748,790,749,750,751,793/Jodh/2025 Asst. Years: 2020-21 to 2023-24 2.2 The assessee Mountain Vintrade Pvt. Ltd. Has raised following grounds of appeal:

ITA No. 746/Jodh/2025 (Assessment Year: 2020-21)

8 ITA Nos. 777,778,779,870,871,872/Jodh/2025 ITA Nos. 746,747,748,790,749,750,751,793/Jodh/2025 Asst. Years: 2020-21 to 2023-24 consequential to the above disallowance and ought to be deleted if and to the extent the underlying addition is deleted. (The appellant denies its liability to such interest.) 4. The appellant craves leave to add, amend, alter, delete or modify any of the above grounds of appeal, either before or during the hearing of this appeal. ITA No. 747/Jodh/2025 (Assessment Year: 2021-22)

ITA No. 748/Jodh/2025 (Assessment Year: 2023-24)

9 ITA Nos. 777,778,779,870,871,872/Jodh/2025 ITA Nos. 746,747,748,790,749,750,751,793/Jodh/2025 Asst. Years: 2020-21 to 2023-24 2.1 Under the facts and circumstances of the case and in law, the ld. CIT(A) has grossly erred in confirming the disallowance of ₹2,43,000 /- in respect of Salary expenses. 2.2 Under the facts and circumstances of the case and in law, the ld. CIT(A) has erred in upholding the disallowance of ₹41,908/- being Office Expenses. 2.3 Under the facts and circumstances of the case and in law, the Id. CIT(A) has erred in confirming the disallowance of ₹5,058/- incurred on Printing & Stationery Expenses. 2.4 Under the facts and circumstances of the case and in law, the Id. CIT(A) has erred in sustaining the disallowance of ₹17,788/- towards Conveyance charges. 2.5 Under the facts and circumstances of the case and in law, the ld. CIT(A) has erred in confirming the disallowance of ₹7,596/- relating to expenses. Telephone 2.6 Under the facts and circumstances of the case and in law, the ld. CIT(A) has erred in upholding the disallowance of ₹21,425/- under the head "Travelling Expense". 2.7 Under the facts and circumstances of the case and in law, the ld. CIT(A) has erred in upholding the disallowance of ₹10,944/ under the head "Misc. Expenses". 2.8 Under the facts and circumstances of the case and in law, the ld. CIT(A) has erred in upholding the disallowance of ₹47,200/- under the head "Office Rent". 2.9 Under the facts and circumstances of the case and in law, the ld. CIT(A) has erred in upholding the disallowance of ₹11,800/- under the head "Secretarial Audit Fees". 3. Under the facts and circumstances of the case and in law, the Id. CIT(A) has erred in upholding the disallowance of ₹18,339/- under the head "Previous Year Income Tax". 4. That the learned CIT(A) further erred in confirming the levy of interest under Sections 234B and 234C, which is not chargeable on the facts of the case. The interest is purely consequential to the above disallowance and ought to be deleted if and to the extent the underlying addition is deleted. (The appellant denies its liability to such interest.) 5. The appellant craves leave to add, amend, alter, delete or modify any of the above grounds of appeal, either before or during the hearing of this appeal. ITA No. 790/Jodh/2025 (Assessment Year: 2022-23)

10 ITA Nos. 777,778,779,870,871,872/Jodh/2025 ITA Nos. 746,747,748,790,749,750,751,793/Jodh/2025 Asst. Years: 2020-21 to 2023-24 2. That the learned CIT(A) erred in upholding the disallowance of ₹1,46,213/-, being bona fide business and administrative expenditures (such as rent, and administrative expenses) incurred wholly and exclusively for the purposes of the business, which are fully allowable under Section 37(1) of the Income Tax Act, 1961. The disallowance is unjustified on facts and in law. 2.1 Under the facts and circumstances of the case and in law, the ld. CIT(A) has erred in upholding the disallowance of ₹47,200/- being Office Rent. 2.2 Under the facts and circumstances of the case and in law, the ld. CIT(A) has erred in confirming the disallowance of ₹13,650/- incurred on Travelling. 2.3 Under the facts and circumstances of the case and in law, the Id. CIT(A) has erred in sustaining the disallowance of ₹13,240/- towards Conveyance charges 2.4 Under the facts and circumstances of the case and in law, the ld. CIT(A) has erred in confirming the disallowance of ₹7.950/- relating expenses. to Telephone 2.5 Under the facts and circumstances of the case and in law, the Id. CIT(A) has erred in upholding the disallowance of ₹49.863/- under the head "Office Expense". 2.6 Under the facts and circumstances of the case and in law, the Id. CIT(A) has erred in upholding the disallowance of ₹14,310/- under the head "Misc. Expense". 3. Under the facts and circumstances of the case and in law, the learned CIT(A) grossly erred in disallowing Salary expenses of ₹2,40,000/- and Printing & Stationery of ₹7,680/- , even though the same had been duly examined and allowed by the Assessing Officer after verification. Disallowance of Salary and Printing & Stationery are unjustified, beyond the scope of appellate jurisdiction, and contrary to the settled principle that expenses incurred wholly and exclusively for business purposes which are fully allowable under Section 37(1) of the Income Tax Act, 1961. The disallowance is unjustified on facts and in law. The disallowance of Salary expenses is therefore bad in law and deserves to be deleted in full. 4. That the learned CIT(A) further erred in confirming the levy of interest under Sections 234B and 234C. The above interest is the purely consequential to disallowance and ought to be deleted if and to the extent the underlying addition is deleted. (The appellant denies its liability to such interest.) 5. The appellant craves leave to add, amend, alter, delete or modify any of the above grounds of appeal, either before or during the hearing of this appeal.

2.3 The assessee Aakruti Tradehub Pvt. Ltd. Has raised following grounds of appeal:

11 ITA Nos. 777,778,779,870,871,872/Jodh/2025 ITA Nos. 746,747,748,790,749,750,751,793/Jodh/2025 Asst. Years: 2020-21 to 2023-24 ITA No. 749/Jodh/2025 (Assessment Year: 2020-21)

12 ITA Nos. 777,778,779,870,871,872/Jodh/2025 ITA Nos. 746,747,748,790,749,750,751,793/Jodh/2025 Asst. Years: 2020-21 to 2023-24 1. Under the facts and circumstances of the case and in law, the orders of the authorities below (the assessment order as upheld in the impugned CIT(A) order) have been passed without due consideration of relevant facts and applicable law, rendering the assessment improper. The resultant disallowances/additions are arbitrary, perverse and contrary to settled principles, and therefore the entire disallowance of ₹2,62,522/- deserves to be deleted and the impugned order quashed. 2. That the learned CIT(A) erred in upholding the disallowance of ₹2,62,522, being bona fide business expenditures (such as salaries, rent, administrative expenses) incurred wholly and and exclusively for the purposes of the business, which are fully allowable under Section 37(1) of the Income Tax Act, 1961. The disallowance is unjustified on facts and in law. 2.1 Under the facts and circumstances of the case and in law, the ld. CIT(A) has grossly erred in confirming the disallowance of ₹84,000 /- in respect of Salary expenses. 2.2 Under the facts and circumstances of the case and in law, the ld. CIT(A) has erred in upholding the disallowance of ₹96,000/- being Office Rent. 2.3 Under the facts and circumstances of the case and in law, the Id. CIT(A) has erred in confirming the disallowance of ₹3,240/- incurred on Travelling. 2.4 Under the facts and circumstances of the case and in law, the ld. CIT(A) has erred in sustaining the disallowance of ₹2,240/- towards Conveyance charges. 2.5 Under the facts and circumstances of the case and in law, the ld. CIT(A) has erred in confirming the disallowance of ₹2,950/- relating to Telephone expenses. 2.6 Under the facts and circumstances of the case and in law, the ld. CIT(A) has erred in upholding the disallowance of ₹3,977/- under the head "Office Expense". 2.7 Under the facts and circumstances of the case and in law, the ld. CIT(A) has erred in upholding the disallowance of ₹69,350/- under the head “Preliminary Expenses". 2.8 Under the facts and circumstances of the case and in law, the ld. CIT(A) has erred in upholding the disallowance of ₹3/- under the head "Other Expenses " 3. That the learned CIT(A) further erred in confirming the levy of interest under Sections 234B and 234C, which is not chargeable on the facts of the case. The interest is purely consequential to the above disallowance and ought to be deleted if and to the extent the underlying addition is deleted. (The appellant denies its liability to such interest.) 4. The appellant craves leave to add, amend, alter, delete or modify any of the above grounds of appeal, either before or during the hearing of this appeal. ITA No. 751/Jodh/2025 (Assessment Year: 2023-24)

13 ITA Nos. 777,778,779,870,871,872/Jodh/2025 ITA Nos. 746,747,748,790,749,750,751,793/Jodh/2025 Asst. Years: 2020-21 to 2023-24 1. Under the facts and circumstances of the case and in law, the orders of the authorities below (the assessment order as upheld in the impugned CIT(A) order) have been passed without due consideration of relevant facts and applicable law, rendering the assessment improper. The resultant disallowances/additions are arbitrary, perverse and contrary to settled principles, and therefore the entire disallowance of ₹7,68,593/- deserves to be deleted and the impugned order quashed. 2. That the learned CIT(A) erred in upholding the disallowance of ₹7,68,593, being bona fide business expenditures (such administrative salaries, as rent, expenses) incurred wholly and and exclusively for the purposes of the business, which are fully allowable under Section 37(1) of the Income Tax Act, 1961. The disallowance is unjustified on facts and in law. 2.1 Under the facts and circumstances of the case and in law, the ld. CIT(A) has grossly erred in confirming the disallowance of ₹4,32,750 /- in respect of Salary expenses. 2.2 Under the facts and circumstances of the case and in law, the ld. CIT(A) has erred in upholding the disallowance of ₹47,200/- being Office Rent. 2.3 Under the facts and circumstances of the case and in law, the ld. CIT(A) has erred in confirming the disallowance of ₹6,780/- incurred on Travelling. 2.4 Under the facts and circumstances of the case and in law, the Id. CIT(A) has erred in sustaining the disallowance of ₹2,640/- towards Conveyance charges. 2.5 Under the facts and circumstances of the case and in law, the ld. CIT(A) has erred in confirming the disallowance of ₹2,590/- relating to expenses. Telephone 2.6 Under the facts and circumstances of the case and in law, the ld. CIT(A) has erred in upholding the disallowance of ₹23,000/- under the head "Office Expense". 2.7 Under the facts and circumstances of the case and in law, the ld. CIT(A) has erred in upholding the disallowance of ₹2,53,128/- under the head "Parking Expenses". 2.8 Under the facts and circumstances of the case and in law, the ld. CIT(A) has erred in upholding the disallowance of ₹16/- under the head "Share Charges". 2.9 Under the facts and circumstances of the case and in law, the ld. CIT(A) has erred in upholding the disallowance of ₹490/- under the head "Staff & Labour Expenses". 3. That the learned CIT(A) further erred in confirming the levy of interest under Sections 234B and 234C, which is not chargeable on the facts of the case. The interest is purely consequential to the above disallowance and ought to be deleted if and to the extent the underlying addition is deleted. (The appellant denies its liability to such interest.) 4. The appellant craves leave to add, amend, alter, delete or modify any of the above grounds of appeal, either before or during the hearing of this appeal.

14 ITA Nos. 777,778,779,870,871,872/Jodh/2025 ITA Nos. 746,747,748,790,749,750,751,793/Jodh/2025 Asst. Years: 2020-21 to 2023-24 ITA No. 793/Jodh/2025 (Assessment Year: 2022-23)

15 ITA Nos. 777,778,779,870,871,872/Jodh/2025 ITA Nos. 746,747,748,790,749,750,751,793/Jodh/2025 Asst. Years: 2020-21 to 2023-24 be deleted if and to the extent the underlying addition is deleted. (The appellant denies its liability to such interest.) 5. The appellant craves leave to add, amend, alter, delete or modify any of the above grounds of appeal, either before or during the hearing of this appeal.

16 ITA Nos. 777,778,779,870,871,872/Jodh/2025 ITA Nos. 746,747,748,790,749,750,751,793/Jodh/2025 Asst. Years: 2020-21 to 2023-24 Rs. 1,39,17,193/- with an addition of Rs. 39,56,583/-, the sole addition comprising of disallowance of business expenses claimed by the appellant company by holding that appellant was a bogus shell company operating from dummy address, with minimal business transactions.

17 ITA Nos. 777,778,779,870,871,872/Jodh/2025 ITA Nos. 746,747,748,790,749,750,751,793/Jodh/2025 Asst. Years: 2020-21 to 2023-24 coordinate Jodhpur Bench, in the case of KBK and others Vs. ACIT in ITA No. 720/Jodh/2025 and others with respect to assessment year 2020-21, 2021-22 and 2023-24 dated 21.05.2026 granted relief to the assessee by observing as under:

18 ITA Nos. 777,778,779,870,871,872/Jodh/2025 ITA Nos. 746,747,748,790,749,750,751,793/Jodh/2025 Asst. Years: 2020-21 to 2023-24 In the appellant's case, the authorities below disallowed basic administrative expenditure by claiming that these were not necessary due to "non-statutory". The Supreme Court has categorically held that such subjective assessment is impermissible. If the appellant considers it necessary to maintain employees, office premises and administrative infrastructure to carry out statutory filing, document preparation, banking and audit coordination, commercial expediency is clearly present. The disallowance ignores the ratio of S. A. Builders and is unsustainable in law. iii. CIT v. Malayalam Plantations Ltd. (1964) 53 ITR 140 (SC): In Malayalam Plantations, the assessee claimed certain expenses relating to statutory liabilities and management obligations. The department contended that these were not strictly for the purpose of earning income. The Supreme Court held that expenditure incurred for the preservation of the business and performance of statutory duties is allowable under section 37. Expenditure incidental to carrying on business is regarded as for the purposes of business. The appellant LLP has incurred statutory compliance expenses office expenses, such as accounting, documentation, filing, banking and administrative coordination. Salary, rent, postage and travelling are integral to carrying out statutory obligations under the Companies Act, Income Tax Act and GST laws. The CIT Appeal accepted statutory expenses but illogically disallowed the operational expenses required to incur them. Under Malayalam Plantations, all such incidental and statutory- supporting expenditure is allowable. The disallowance is contrary to this binding precedent. iv. Dhakeshwari Cotton Mills Ltd. v. CIT (1954) 26 ITR 775 (SC): In this landmark judgment, the Supreme Court held that assessment cannot be based on suspicion, conjecture surmise. Additions must be grounded in tangible material or evidence. The Court rejected an assessment that was based solely on loose statements and assumptions without supporting documents. In the present case, the Assessing Officer and CIT Appeal relied entirely on uncorroborated search statements of third parties (a peon, an accountant and a group employee) none of whom were linked to the appellant's management. The CIT Appeal himself records that the Assessing Officer brought no seized profit and loss account, balance sheet, bank statement or other Incriminating material specific to the appellant. Disallowance based on assumption that the appellant was "at a dummy address" without evidence violates the principle laid down in Dhakeshwari Cotton Mills. The disallowance has no evidentiary backing and must be deleted.

19 ITA Nos. 777,778,779,870,871,872/Jodh/2025 ITA Nos. 746,747,748,790,749,750,751,793/Jodh/2025 Asst. Years: 2020-21 to 2023-24 v. Umacharan Shaw and Bros. v. CIT (1959) 37 ITR 271 (SC): In this case, the department made additions based on presumption without any direct evidence. The Supreme Court held that suspicion, however strong, cannot take the place of proof and additions must be supported by credible material. The disallowance in the appellant's case rests solely on suspicion derived from third-party statements and an alleged common address issue. No document, voucher or bank entry has been shown to be non-genuine. Salary vouchers, rent agreements, GST invoices, TDS records and office expenditure bills were all produced and accepted by the AO. The disallowance is purely suspicion-based and therefore contrary to this Supreme Court decision. vi. Mehta Parikh & Co. v. CIT (1956) 30 ITR 181 (SC): The assessee in this case produced affidavits and documentary evidence supporting its claims. The department rejected them without any cross-examination or contradiction. The Supreme Court held that when evidence remains uncontroverted, the revenue cannot disregard it without giving reasons. In the appellant's case, ledger statements, TDS return, bank statements and other documents were submitted. Nowhere in the assessment order did the AO dispute their genuineness. The rejection of expenditure despite unchallenged evidence violates the law laid down in Mehta Parikh. vii. Radhasoami Satsang v. CIT (1992) 193 ITR 321 (SC): The Supreme Court held that once a consistent view has been taken material has emerged, the in earlier years and department should maintain consistency and cannot arbitrarily deviate. no new In earlier scrutiny assessments of the appellant (AY 2015-16, AY 2017-18), identical expenditure patterns were accepted under section 143(3). No new incriminating material was found during search pertaining to the appellant. The sudden disallowance contradicts the principle of consistency. 21. From the record, it is evident that the Ld. CIT(A) did not appropriately consider the factual matrix of the case while accepting the statutory and compliance related expenses such as accounting charges, ROC filing fee and bank charges is genuine and sustain the disallowances of expenses related to administrative and other operational activities merely on the basis of presumption that such expenses are non-statutory in the nature and due to perceived minimal business activity. This observation of the Ld. CIT(A) has been arrived without identifying any specific deficiency in the books of account and without demonstrating any personal or non-business element or without pointing out any lack of business evidence.

20 ITA Nos. 777,778,779,870,871,872/Jodh/2025 ITA Nos. 746,747,748,790,749,750,751,793/Jodh/2025 Asst. Years: 2020-21 to 2023-24 22. Thus, the Ld. CIT(A) has allowed the fruit but denined the tree that bears it. In the present case, this is not merely inconsistent but it is logically impossible that a LLP firm cannot incur accounting charges, bank charges, and secretarial audit fee in physical and operational vaccum is a disallowance sustained by the Ld. CIT(A) as those expenses are the necessary pre-condition for the allowed expenses to exist. 23. It is well settled principle of law through judicial pronouncement that routine administrative and operational expenses which are necessary for maintaining corporate existence and ensuring statutory compliance, cannot be disallowed unless they are specifically shown to be non-genuine, excessive, or unrelated to the business. In the present case, neither the Assessing Officer nor the Ld. CIT(A) has brought any material on record to establish that the impugned expenses are bogus, inflated, unverifiable or not incurred for business purposes. We find that all the disallowed expenditures are duly supported by documentary evidence and are intrinsically linked to the normal functioning and compliance requirements of the appellant LLP. The acceptance of statutory expenses, while simultaneously disallowing the genuine administrative and other expenses results in an internally inconsistent and legally unsustainable conclusion. 24. In the above view, we hold that in the absence of any specific adverse finding against the genuineness of the expenditure claimed by the appellant assessee, the disallowance sustained by the Ld. CIT(A) amounting to Rs. 4,44,780/- is perverse to the facts on record and the same is as such deleted. 7. Respectfully following the judgment delivered by coordinate jodhpur bench (supra) on identical facts, we hold that in absence of any specific adverse finding given by either of the lower authorities on the genuineness of the expenditure claimed by the appellant assessee, the disallowance sustained by the Ld. CIT(A) amounting to Rs. 30,64,577/- is perverse to the facts on record and as such deleted. Thus, the ground no. 1 and 2 of the assessee are allowed.

21 ITA Nos. 777,778,779,870,871,872/Jodh/2025 ITA Nos. 746,747,748,790,749,750,751,793/Jodh/2025 Asst. Years: 2020-21 to 2023-24 8. Ground no. 3 of the appeal is consequential in nature which does not require specific adjudication.

Order pronounced in the open court on 03/06/2026.

Sd/- Sd/- (SUDHIR PAREEK) (DR. MITHA LAL MEENA) JUDICIAL MEMBER ACCOUNTANT MEMBER Dated : 03/06/2026. Nimisha Sr. PS True Copy

22 ITA Nos. 777,778,779,870,871,872/Jodh/2025 ITA Nos. 746,747,748,790,749,750,751,793/Jodh/2025 Asst. Years: 2020-21 to 2023-24 Copies to : (1) The appellant. (2) The respondent. (3) CIT (4) CIT(A) (5) Departmental Representative (6) Guard File BY ORDER,