SANJAY KUMAR KARNANI,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

आयकर अपीलीय अधिकरण, जयपुर न्यायाधिकरण, जयपुर
IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, "B" JAIPUR
डा० एस. सीथालक्ष्मी, न्यायिक सदस्य एवं श्री राठौड कमलेश जयन्तभाई, लेखा सदस्य के समक्ष
BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI,
आकर अपील सं./ITA Nos. 56 to 61/JP/2025
निर्धारण वर्ष / Assessment Years : 2014-15 to 2019-20
Central Circle-03,
Jaipur
स्थायी लेखा सं./जी.आई.आर सं./PAN/GIR No.: AATFS6984Q
अपीलार्था / Appellant प्रत्यर्थी/Respondent
आकर अपील सं./ITA Nos. 671 to 676/JP/2025
निर्धारण वर्ष / Assessment Years : 2014-15 to 2019-20
Sanjay Kumar Karnani
M-8, Mahesh Colony Tonk
Central Circle-03,
Jaipur
स्थायी लेखा सं./जी.आई.आर सं./PAN/GIR No.: AGZPK3972A
अपीलार्था / Appellant प्रत्यर्थी/Respondent
निर्धारिती की ओर से / Assessee by : Shri Deepak Sharma, Adv.
राजस्व की ओर से / Revenue by : Mrs. Alka Gautam, CIT
सुनवाई की तारीख / Date of Hearing : 17/09/2025
उद्घोषणा की तारीख / Date of Pronouncement: 15/10/2025
आदेश / ORDER
PER BENCH:
The present bunch of twelve appeals (Six appeals in the case of M/s
Ambica Garments and Six appeals in the case of Shri Sanjay Kumar
Karnani) have been filed by the assessee against twelve separate orders of the learned Commissioner of Income Tax, Appeals-4, Jaipur [ for short
CIT(A) ] passed as per the provision of section 250 of Income Tax Act,
1961 [ for short Act ] for AY 2014-15 to 2019-20. The details of the order disputed in these appeals are as under:
ITA No.
Assessment
Year
Name of Assessee
Date of Impugned order of CIT(Appeals)-
4, Jaipur
Reference to the section dated of the order passed by the ACIT, CC-
3,Jaipur
56/JPR/2025
2014-15
Shri Ambica
Garments
27-11-2024
153A dated
20/07/2021
57/JPR/2025
2015-16
Shri Ambica
Garments
19-11-2024
153A dated
20/07/2021
58/JPR/2025
2016-17
Shri Ambica
Garments
19-11-2024
153A dated
20/07/2021
59/JPR/2025
2017-18
Shri Ambica
Garments
19-11-2024
153A dated
20/07/2021
60/JPR/2025
2018-19
Shri Ambica
Garments
19-11-2024
153A dated
20/07/2021
61/JPR/2025
2019-20
Shri Ambica
Garments
19-11-2024
143(3) dated
20/07/2021
671/JPR/2025
2014-15
Sanjay Kumar
Karnani
26-02-2025
153A dated
16/07/2021
672/JPR/2025
2015-16
Sanjay Kumar
Karnani
26-02-2025
153A dated
16/07/2021
673/JPR/2025
2016-17
Sanjay Kumar
Karnani
26-02-2025
153A dated
16/07/2021
674/JPR/2025
2017-18
Sanjay Kumar
Karnani
26-02-2025
153A dated
16/07/2021
675/JPR/2025
2018-19
Sanjay Kumar
Karnani
26-02-2025
153A dated
16/07/2021
676/JPR/2025
2019-20
Sanjay Kumar
Karnani
26-02-2025
153A dated
16/07/2021
3.1 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 56/JPR/2025 for assessment year 2014-15;
1. Impugned assessment order dated 20.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in making addition on account of alleged opening unexplained capital of Rs. 2,65,47,685/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in making addition on account of alleged unexplained loan of Rs. 52,16,133/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
4. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in making total addition of Rs.
3,17,63,818/- u/s 68 of the Act.
5. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
3.2 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 57/JPR/2025 for assessment year 2015-
16:-
1. Impugned assessment order dated 20.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 2,06,55,593/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in making addition on account gross profit. The addition is unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
4. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs.2,12,56,630/- as against the returned income of Rs.6,01,040/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
5. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
3.3 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 58/JPR/2025 for assessment year 2016-
17;
1. Impugned assessment order dated 20.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 2,72,92,499/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
Ld. A.O. in making the addition on account of profit of Rs. 2,53,193/- on account of Gopala Garments and addition of Rs. 5,76,019/- on account of Race Kids Wears. The action is unjustified, illegal or excessive and deserves to be deleted in full.
4. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making addition on account of alleged opening unexplained loan of Rs.
10,53,150/- pertaining to Race Kids Wears. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
5. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making addition on account of alleged opening unexplained loan of Rs.
19,97,600/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
6. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs.3,16,30,330/- as against the returned income of Rs.4,57,870/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
7. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
3.4 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 59/JPR/2025 for assessment year 2017-
18;
1. Impugned assessment order dated 20.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 2,89,06,016/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making the addition on account of profit of Rs. 10,57,387/- on account of Gopala Garments and addition of Rs. 24,33,216/- on account of Race Kids Wears. The action is unjustified, illegal or excessive and deserves to be deleted in full.
4. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making addition on account of alleged opening unexplained loan of Rs.
1,17,440/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs. 3,31,14,520/- as against the returned income of Rs.6,00,460/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
6. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
3.5 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 60/JPR/2025 for assessment year 2018-
19:-
1. Impugned assessment order dated 20.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 3,14,70,928/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making the addition on account of profit of Rs. 8,93,428/- on account of Gopala Garments and addition of Rs. 21,15,481/- on account of Race Kids Wears. The action is unjustified, illegal or excessive and deserves to be deleted in full.
4. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs. 3,51,87,710/- as against the returned income of Rs. 7,07,870/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
3.6 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 61/JPR/2025 for assessment year 2019-
20;
1. Impugned assessment order dated 20.07.2021, passed U/s 153A/143(3) is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 52,44,593/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs. 58,89,080/- as against the returned income of Rs. 6,44,490/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
4. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
4.1 The assessee Sanjay Kumar Karnani has raised the following grounds of appeal vide ITA No. 671/JPR/2025 for assessment year 2014-
15;
1. Impugned assessment order dated 16.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
on account of alleged opening unexplained capital of Rs. 1,08,36,565/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances, Ld. A.O. has erred in making addition on account of alleged opening unexplained loan of Rs. 1,34,53,241/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
4. Under the facts and circumstances, Ld. A.O. has erred in making addition on account of alleged unexplained loan of Rs. 61,000/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.
CIT(A) erred in confirming the action of Ld. AO in making total addition of Rs.
3,17,63,818/- u/s 68 of the Act.
6. That the appellant craves your indulgence to add, amend or alter all or any grounds of appeal before or at the time of hearing.
4.2 The assessee Sanjay Kumar Karnani has raised the following grounds of appeal vide ITA No. 672/JPR/2025 for assessment year 2015-
16;
1. Impugned assessment order dated 16.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 1,72,39,251/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in making addition on account gross profit. The addition is unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
4. Under the facts and circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in making addition on account of alleged unexplained loan of Rs.5,74,018/-. The addition is unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs.3,31,14,520/- as against the returned income of Rs.4,57,870/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
6. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
3.4 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 59/JPR/2025 for assessment year 2017-
18;
1. Impugned assessment order dated 20.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 2,89,06,016/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making the addition on account of profit of Rs. 10,57,387/- on account of Gopala Garments and addition of Rs. 24,33,216/- on account of Race Kids Wears. The action is unjustified, illegal or excessive and deserves to be deleted in full.
4. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making addition on account of alleged opening unexplained loan of Rs.
1,17,440/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs. 3,31,14,520/- as against the returned income of Rs.6,00,460/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
6. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
3.5 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 60/JPR/2025 for assessment year 2018-
19:-
1. Impugned assessment order dated 20.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 3,14,70,928/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making the addition on account of profit of Rs. 8,93,428/- on account of Gopala Garments and addition of Rs. 24,33,216/- on account of Race Kids Wears. The action is unjustified, illegal or excessive and deserves to be deleted in full.
4. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making addition on account of alleged opening unexplained loan of Rs.
1,17,440/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs. 3,31,14,520/- as against the returned income of Rs.6,00,460/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
6. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
3.6 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 61/JPR/2025 for assessment year 2019-
20;
1. Impugned assessment order dated 20.07.2021, passed U/s 153A/143(3) is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 52,44,593/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs. 58,89,080/- as against the returned income of Rs. 6,44,490/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
4. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
4.1 The assessee Sanjay Kumar Karnani has raised the following grounds of appeal vide ITA No. 671/JPR/2025 for assessment year 2014-
15;
1. Impugned assessment order dated 16.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
3.6 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 61/JPR/2025 for assessment year 2019-
20;
1. Impugned assessment order dated 20.07.2021, passed U/s 153A/143(3) is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 52,44,593/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs. 58,89,080/- as against the returned income of Rs. 6,44,490/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
4. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
4.1 The assessee Sanjay Kumar Karnani has raised the following grounds of appeal vide ITA No. 671/JPR/2025 for assessment year 2014-
15;
1. Impugned assessment order dated 16.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and circumstances, Ld. A.O. has erred in making addition on account of alleged opening unexplained capital of Rs. 1,08,36,565/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances, Ld. A.O. has erred in making addition on account of alleged opening unexplained loan of Rs. 1,34,53,241/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
4. Under the facts and circumstances, Ld. A.O. has erred in making addition on account of alleged unexplained loan of Rs. 61,000/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.
CIT(A) erred in confirming the action of Ld. AO in making total addition of Rs.
3,17,63,818/- u/s 68 of the Act.
6. That the appellant craves your indulgence to add, amend or alter all or any grounds of appeal before or at the time of hearing.
4.2 The assessee Sanjay Kumar Karnani has raised the following grounds of appeal vide ITA No. 672/JPR/2025 for assessment year 2015-
16;
1. Impugned assessment order dated 16.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 1,72,39,251/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in making addition on account gross profit. The addition is unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
4. Under the facts and circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in making addition on account of alleged unexplained loan of Rs.5,74,018/-. The addition is unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs.3,31,14,520/- as against the returned income of Rs.4,57,870/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
6. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
3.4 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 59/JPR/2025 for assessment year 2017-
18;
1. Impugned assessment order dated 20.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 2,89,06,016/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making the addition on account of profit of Rs. 10,57,387/- on account of Gopala Garments and addition of Rs. 24,33,216/- on account of Race Kids Wears. The action is unjustified, illegal or excessive and deserves to be deleted in full.
4. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making addition on account of alleged opening unexplained loan of Rs.
1,17,440/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs. 3,31,14,520/- as against the returned income of Rs.6,00,460/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
6. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
3.5 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 60/JPR/2025 for assessment year 2018-
19:-
1. Impugned assessment order dated 20.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 3,14,70,928/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making the addition on account of profit of Rs. 8,93,428/- on account of Gopala Garments and addition of Rs. 24,33,216/- on account of Race Kids Wears. The action is unjustified, illegal or excessive and deserves to be deleted in full.
4. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making addition on account of alleged opening unexplained loan of Rs.
1,17,440/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs. 3,31,14,520/- as against the returned income of Rs.6,00,460/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
6. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
3.6 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 61/JPR/2025 for assessment year 2019-
20;
1. Impugned assessment order dated 20.07.2021, passed U/s 153A/143(3) is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 52,44,593/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs. 58,89,080/- as against the returned income of Rs. 6,44,490/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
4. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
4.1 The assessee Sanjay Kumar Karnani has raised the following grounds of appeal vide ITA No. 671/JPR/2025 for assessment year 2014-
15;
1. Impugned assessment order dated 16.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
on account of alleged opening unexplained capital of Rs. 1,08,36,565/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances, Ld. A.O. has erred in making addition on account of alleged opening unexplained loan of Rs. 1,34,53,241/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
4. Under the facts and circumstances, Ld. A.O. has erred in making addition on account of alleged unexplained loan of Rs. 61,000/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.
CIT(A) erred in confirming the action of Ld. AO in making total addition of Rs.
3,17,63,818/- u/s 68 of the Act.
6. That the appellant craves your indulgence to add, amend or alter all or any grounds of appeal before or at the time of hearing.
4.2 The assessee Sanjay Kumar Karnani has raised the following grounds of appeal vide ITA No. 672/JPR/2025 for assessment year 2015-
16;
1. Impugned assessment order dated 16.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 1,72,39,251/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in making addition on account gross profit. The addition is unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
4. Under the facts and circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in making addition on account of alleged unexplained loan of Rs.5,74,018/-. The addition is unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs.3,31,14,520/- as against the returned income of Rs.4,57,870/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
6. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
3.4 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 59/JPR/2025 for assessment year 2017-
18;
1. Impugned assessment order dated 20.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 2,89,06,016/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making the addition on account of profit of Rs. 10,57,387/- on account of Gopala Garments and addition of Rs. 24,33,216/- on account of Race Kids Wears. The action is unjustified, illegal or excessive and deserves to be deleted in full.
4. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making addition on account of alleged opening unexplained loan of Rs.
1,17,440/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs. 3,31,14,520/- as against the returned income of Rs.6,00,460/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
6. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
3.5 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 60/JPR/2025 for assessment year 2018-
19:-
1. Impugned assessment order dated 20.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 3,14,70,928/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making the addition on account of profit of Rs. 8,93,428/- on account of Gopala Garments and addition of Rs. 24,33,216/- on account of Race Kids Wears. The action is unjustified, illegal or excessive and deserves to be deleted in full.
4. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making addition on account of alleged opening unexplained loan of Rs.
1,17,440/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs. 3,31,14,520/- as against the returned income of Rs.6,00,460/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
6. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
3.6 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 61/JPR/2025 for assessment year 2019-
20;
1. Impugned assessment order dated 20.07.2021, passed U/s 153A/143(3) is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 52,44,593/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs. 58,89,080/- as against the returned income of Rs. 6,44,490/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
4. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
4.1 The assessee Sanjay Kumar Karnani has raised the following grounds of appeal vide ITA No. 671/JPR/2025 for assessment year 2014-
15;
1. Impugned assessment order dated 16.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
on account of alleged opening unexplained capital of Rs. 1,08,36,565/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances, Ld. A.O. has erred in making addition on account of alleged opening unexplained loan of Rs. 1,34,53,241/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
4. Under the facts and circumstances, Ld. A.O. has erred in making addition on account of alleged unexplained loan of Rs. 61,000/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.
CIT(A) erred in confirming the action of Ld. AO in making total addition of Rs.
3,17,63,818/- u/s 68 of the Act.
6. That the appellant craves your indulgence to add, amend or alter all or any grounds of appeal before or at the time of hearing.
4.2 The assessee Sanjay Kumar Karnani has raised the following grounds of appeal vide ITA No. 672/JPR/2025 for assessment year 2015-
16;
1. Impugned assessment order dated 16.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 1,72,39,251/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in making addition on account gross profit. The addition is unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
4. Under the facts and circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in making addition on account of alleged unexplained loan of Rs.5,74,018/-. The addition is unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs.3,31,14,520/- as against the returned income of Rs.4,57,870/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
6. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
3.4 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 59/JPR/2025 for assessment year 2017-
18;
1. Impugned assessment order dated 20.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 2,89,06,016/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making the addition on account of profit of Rs. 10,57,387/- on account of Gopala Garments and addition of Rs. 24,33,216/- on account of Race Kids Wears. The action is unjustified, illegal or excessive and deserves to be deleted in full.
4. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making addition on account of alleged opening unexplained loan of Rs.
1,17,440/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs. 3,31,14,520/- as against the returned income of Rs.6,00,460/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
6. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
3.5 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 60/JPR/2025 for assessment year 2018-
19:-
1. Impugned assessment order dated 20.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 3,14,70,928/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making the addition on account of profit of Rs. 8,93,428/- on account of Gopala Garments and addition of Rs. 24,33,216/- on account of Race Kids Wears. The action is unjustified, illegal or excessive and deserves to be deleted in full.
4. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making addition on account of alleged opening unexplained loan of Rs.
1,17,440/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs. 3,31,14,520/- as against the returned income of Rs.6,00,460/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
6. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
3.6 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 61/JPR/2025 for assessment year 2019-
20;
1. Impugned assessment order dated 20.07.2021, passed U/s 153A/143(3) is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 52,44,593/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs. 58,89,080/- as against the returned income of Rs. 6,44,490/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
4. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
4.1 The assessee Sanjay Kumar Karnani has raised the following grounds of appeal vide ITA No. 671/JPR/2025 for assessment year 2014-
15;
1. Impugned assessment order dated 16.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
on account of alleged opening unexplained capital of Rs. 1,08,36,565/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances, Ld. A.O. has erred in making addition on account of alleged opening unexplained loan of Rs. 1,34,53,241/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
4. Under the facts and circumstances, Ld. A.O. has erred in making addition on account of alleged unexplained loan of Rs. 61,000/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.
CIT(A) erred in confirming the action of Ld. AO in making total addition of Rs.
3,17,63,818/- u/s 68 of the Act.
6. That the appellant craves your indulgence to add, amend or alter all or any grounds of appeal before or at the time of hearing.
4.2 The assessee Sanjay Kumar Karnani has raised the following grounds of appeal vide ITA No. 672/JPR/2025 for assessment year 2015-
16;
1. Impugned assessment order dated 16.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 1,72,39,251/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in making addition on account gross profit. The addition is unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
4. Under the facts and circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in making addition on account of alleged unexplained loan of Rs.5,74,018/-. The addition is unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs.3,31,14,520/- as against the returned income of Rs.4,57,870/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
6. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
3.4 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 59/JPR/2025 for assessment year 2017-
18;
1. Impugned assessment order dated 20.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 2,89,06,016/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making the addition on account of profit of Rs. 10,57,387/- on account of Gopala Garments and addition of Rs. 24,33,216/- on account of Race Kids Wears. The action is unjustified, illegal or excessive and deserves to be deleted in full.
4. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making addition on account of alleged opening unexplained loan of Rs.
1,17,440/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs. 3,31,14,520/- as against the returned income of Rs.6,00,460/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
6. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
3.5 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 60/JPR/2025 for assessment year 2018-
19:-
1. Impugned assessment order dated 20.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 3,14,70,928/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making the addition on account of profit of Rs. 8,93,428/- on account of Gopala Garments and addition of Rs. 24,33,216/- on account of Race Kids Wears. The action is unjustified, illegal or excessive and deserves to be deleted in full.
4. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making addition on account of alleged opening unexplained loan of Rs.
1,17,440/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs. 3,31,14,520/- as against the returned income of Rs.6,00,460/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
6. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
3.6 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 61/JPR/2025 for assessment year 2019-
20;
1. Impugned assessment order dated 20.07.2021, passed U/s 153A/143(3) is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 52,44,593/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs. 58,89,080/- as against the returned income of Rs. 6,44,490/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
4. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
4.1 The assessee Sanjay Kumar Karnani has raised the following grounds of appeal vide ITA No. 671/JPR/2025 for assessment year 2014-
15;
1. Impugned assessment order dated 16.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
on account of alleged opening unexplained capital of Rs. 1,08,36,565/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances, Ld. A.O. has erred in making addition on account of alleged opening unexplained loan of Rs. 1,34,53,241/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
4. Under the facts and circumstances, Ld. A.O. has erred in making addition on account of alleged unexplained loan of Rs. 61,000/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.
CIT(A) erred in confirming the action of Ld. AO in making total addition of Rs.
3,17,63,818/- u/s 68 of the Act.
6. That the appellant craves your indulgence to add, amend or alter all or any grounds of appeal before or at the time of hearing.
4.2 The assessee Sanjay Kumar Karnani has raised the following grounds of appeal vide ITA No. 672/JPR/2025 for assessment year 2015-
16;
1. Impugned assessment order dated 16.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 1,72,39,251/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in making addition on account gross profit. The addition is unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
4. Under the facts and circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in making addition on account of alleged unexplained loan of Rs.5,74,018/-. The addition is unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs.3,31,14,520/- as against the returned income of Rs.4,57,870/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
6. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
3.4 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 59/JPR/2025 for assessment year 2017-
18;
1. Impugned assessment order dated 20.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 2,89,06,016/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making the addition on account of profit of Rs. 10,57,387/- on account of Gopala Garments and addition of Rs. 24,33,216/- on account of Race Kids Wears. The action is unjustified, illegal or excessive and deserves to be deleted in full.
4. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making addition on account of alleged opening unexplained loan of Rs.
1,17,440/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs. 3,31,14,520/- as against the returned income of Rs.6,00,460/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
6. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
3.5 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 60/JPR/2025 for assessment year 2018-
19:-
1. Impugned assessment order dated 20.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 3,14,70,928/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making the addition on account of profit of Rs. 8,93,428/- on account of Gopala Garments and addition of Rs. 24,33,216/- on account of Race Kids Wears. The action is unjustified, illegal or excessive and deserves to be deleted in full.
4. Under the facts and circumstances, Ld.CIT(A) erred in confirming the action of Ld. A.O. in making addition on account of alleged opening unexplained loan of Rs.
1,17,440/-. The addition is unjustified, illegal or excessive and deserves to be deleted in full.
5. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs. 3,31,14,520/- as against the returned income of Rs.6,00,460/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
6. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
3.6 The assessee M/s. Shri Amica Garments has raised the following grounds of appeal vide ITA No. 61/JPR/2025 for assessment year 2019-
20;
1. Impugned assessment order dated 20.07.2021, passed U/s 153A/143(3) is bad in law and on facts for want of juri iction and for many more other statutory reasons.
2. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in estimating the Gross Profit and Further erred by making addition of Rs. 52,44,593/-. The action is unjustified, illegal or excessive and deserves to be deleted in full.
3. Under the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in confirming the action of Ld. AO in assessing the total income at Rs. 58,89,080/- as against the returned income of Rs. 6,44,490/- shown by the assessee. The additions made and confirmed by CIT(A) unjustified, illegal or excessive, without considering the submissions in right perspective and deserves to be deleted in full.
4. That the appellant craves your indulgence to add, amend, modify, delete or alter all or any grounds of appeal before or at the time of hearing.
4.1 The assessee Sanjay Kumar Karnani has raised the following grounds of appeal vide ITA No. 671/JPR/2025 for assessment year 2014-
15;
1. Impugned assessment order dated 16.07.2021, passed U/s 153A is bad in law and on facts for want of juri iction and for many more other statutory reasons.
applicability of section 155BBE of the Act. These sections 68/69/69A etc. along with section 115BBE are in the nature of complete code in itself. In this regard it is held by Hon'ble Gujarat High Court in Fakir Mohmed Haji Hasan v. Commissioner of Income-tax [2002] 120 Taxman 11 (Gujarat)/[2001] 247 ITR 290
(Gujarat)/[2001] 165 CTR 111 (Gujarat) [10-(Gujarat)/[2001] 247 ITI 08-2000] that "6.2 The opening words of section 14 'Save as otherwise provided by this Act'
clearly leave scope for 'deemed income' of the nature covered under the scheme of sections 69, 69A, 69B and 69C being treated separately, because such deemed income is not income from salary, house property, profits and gains of business or profession, or capital gains, nor is it income from 'other sources'
because the provisions of sections 69, 69A, 69B, and 69C treat unexplained investments, unexplained money, bullion, etc., and unexplained expenditure as deemed income where the nature and source of investment, acquisition or expenditure, as the case may be, have not been explained or satisfactorily explained. Therefore, in these cases, the source not being known, such deemed income will not fall even under the head, 'Income from other sources'. Therefore, the corresponding deductions, which are applicable to the incomes under any of these various heads, will not be attracted in case of deemed incomes which are covered under the provisions of sections 69, 69A, 69B and 69C in view of the scheme of those provisions."
(11) Further, merely because in the present appeal the capital and loan transactions of the appellant are in cash and have been kept undisclosed and have been detected only during the course of search and seizure action does not make the appellant eligible for some extra premium benefit regarding exemption from not complying with legal requirements and taxability under section 68, 69
and 69D etc. of the Act.
(12) EXISTENCE OF UNEXPLAINED FUNDS AND UNEXPLAINED CREDITS
ITSELF IS EVIDENCE AND THESE ARE THE INCOME OF THE ASSESSEE:- in D.B. Income Tax Appeal No. 175/2012 in order dated 03/10/2017 the addition on account of unexplained cash deposits was upheld by the Hon'ble Rajasthan
High Court. As noted in the order of Hon'ble Tribunal as referred in the order of Hon'ble High Court, the explanation of the assessee was rejected by the Hon'ble
Tribunal in the following paras:-
"5.7 The law in the matter is trite, and for which we may refer to case laws by the hon'ble apex court, which has time and again explained that the receipt of money of which the assessee is a beneficiary is itself a prima facie evidence against him, who has to satisfactorily explain the same, i.e., render an explanation as to its nature and source, which is proper, reasonable and acceptable, even as a finding as to non- satisfaction therewith is to be rendered on the basis of proper appreciation of the material and other attending circumstances available on record; application of mind being a sine qua non for forming an opinion............
(13) ADDITION UNDER SECTION BOOKS OF ACCOUNTS:-68 OF THE MENT
ACT AFTER REJECTION OF The issue in appeal is specifically held in favour of Revenue by the Hon'ble
Supreme Court in the case of Commissioner of Income-tax v. Devi Prasad
Vishwanath [1969] 72 ITR 194 (SC) [01-08-1968] and by Hon'ble Allahabad High
Court in the case of Commissioner of Income-tax-l v. G.S. Tiwari & Co. [2014] 41
taxmann.com 17 (Allahabad)/[2014] 220 Taxman 111 (Allahabad) (Mag.)/[2013]
357 ITR 651 (Allahabad) [30-05-2013].
The Hon'ble Supreme Court in the case of Commissioner of Income-tax v. Devi
Prasad Vishwanath [1969] 72 ITR 194 (SC) [01-08-1968] has held as under:-
"There is nothing in law which prevents the Income-tax Officer in an appropriate case in taxing both the cash credit, the source and nature of which is not satisfactorily explained, and the business income estimated by him under section 13 of the Income-tax Act, after rejecting the books of account of the assessee as unreliable. This was so decided in Kale Khan Mohammad Hanif v. Commissioner of Income-tax [1963] 50 ITR 1 (SC). Whether in a given case the Income-tax
Officer may tax the cash credit entered in the books of account of the business, and at the same time estimate the profit must, however, depend upon the facts of each case.
The High Court, in disposing of the application under section 66(2), expressed the view that because the amount of Rs. 20,000 was entered in the books of account of the business, there was some material to hold that the amount was income of the assessee from the business and not from some other source.
But it was not open to the High Court to direct the Tribunal to state a case on a question which was never raised before or decided by the Tribunal at the hearing of the appeal. The question again assumes that it was for the Income-tax Officer to indicate the source of the income before the income could be held taxable and unless he did so, the assessee was entitled to succeed. That is not, in our judgment, the correct legal position. Where there is an explained cash credit, it is open to the Income-tax Officer to hold that it is income of the assessee and no further burden lies on the Income-tax Officer to show that that income is from any As per the headnotes "Section 145 of the Income-tax Act, 1961 [Corresponding to section 13 of the Indian Income tax Act, 1922] Method of accounting System of accounting Assessment year 1946-47 Whether where there is an unexplained cash credit it is open to ITO to hold that it is income of assessee and no further burden lies on ITO to show that income is from any particular source - Held, yes".
As per the above judgement, the observations of the Hon'ble Allahabad High
Court that because the amount was entered in the books of account of the business, there was some material to hold that the amount was income of the assessee from the business and not from some other source, were not approved by the Hon'ble Supreme Court and was reversed, as it was held by the Hon'ble
Supreme Court that it assumed it was for the Income-tax Officer to indicate the source of the income which was not the correct legal position and that where there is an explained cash credit, it is open to the Income-tax Officer to hold that it is income of the assessee and no further burden lies on the Income-tax Officer to show that that income is from any particular source. It is for the assessee to prove that even if the cash credit represents income it is income from a source which has already been taxed.
Further it is held by Hon'ble Allahabad High Court in the case of Commissioner of Income-tax-l v. G.S. Tiwari & Co. [2014] 41 taxmann.com 17 (Allahabad)/[2014]
220 Taxman 111 (Allahabad) (Mag.)/[2013] 357 ITR 651 (Allahabad) [30-05-2013]
that (headnote extract) In course of assessment, Assessing Officer noted that assessee had not maintained proper books of account He thus rejected book results and estimated net profit rate of 8 per cent under section 44AD Assessing
Officer also made certain addition under section 68 in respect of unexplained cash credit Commissioner (Appeals) as well as Tribunal held that once addition was made on estimate basis under section 44AD, no separate addition could be made in respect of cash credit under section 68 - Whether there is nothing in law which prevents Assessing Officer in an appropriate case in taxing both sundry credit, source and nature of which is not satisfactorily explained, and business income estimated by him after rejecting books of account of assessee as unreliable - Held, yes. The relevant part of the judgement is as under:-
"10. It may be mentioned that in the case of CIT v. Maduri Rajaiahgari Kistaiah
[1979] 120 ITR 294 (AP), it was observed that where a particular business income of the assessee has been estimated and determined and in such a case certain sundry creditors are found, the AO may be precluded from adding the said unexplained sundry creditors as undisclosed income from the business, the income of which was determined on estimate basis. But where the unexplained
12. Further, the Hon'ble Apex Court in the case of CIT v. Devi Prasad Vishwanath
Prasad [1969] 72 ITR 194 observed that where there is an unexplained credit, it is open to the AO to hold that it is income of the assessee, and no further burden lies on the AO to show that the income is from any particular source. It is for the assessee to prove that, even if the sundry creditors represents income, it is income from a source which has already been taxed. There is nothing in law which prevents the AO in an appropriate case in taxing both the sundry credit, the source and nature of which is not satisfactorily explained, and the business income estimate by him after rejecting the books of account of the assessee as unreliable.
In the case of Kale Khan Mohd. Hanif (50 ITR 1) Hon'ble Supreme Court inter-alia held that even if income was computed on estimate basis the addition u/s 68 can be done.
(14) Alternatively and without prejudice to the above:-
The funds received by the appellant are shown in the books of the appellant in the form of balance as on 01.01.2014. The following position emerges:-
(i) The funds were received by the appellant.
(ii) The funds received are in nature of loan and capital which is undisputed.
Undisputedly, the funds received are not in the nature of receipt against sales.
Thus the profit which is a percentage on the sales does not cover and does not include the unexplained money from unknown/unexplained sources.
Further, merely because in the present appeal the cash from partner and loan transactions of the appellant are in cash and have been kept undisclosed and have been detected only during the course of search and seizure action does not and the same are unexplained. It is held accordingly.
This also distinguishes the case in present appeal from the facts and ratio of the judgement in the case of Commissioner of Income-tax, Patiala v. Dulla Ram,
Labour Contractor, Kotakpura [2014] 42 taxmann.com 349 (Punjab &
Haryana)/[2014] 223 Taxman 24 (Punjab & Haryana) (MAG) [22-10-2013].
(15) Another most important fact of the case in the present appeal is that parallel sets of books of accounts were maintained by the appellant for the year under appeal. Some of the transactions were recorded and shown in the audited books of accounts and appellant maintained and another set of books of accounts 'Jai
Shree Ram' in which the transactions shown in the audited books of accounts are so recorded and transactions not recorded in audited books are also recorded.
The crucial fact is that the financials / Books of accounts of 'Jai Shree Ram' have not been rejected. In the earlier paras, the issue of reliability of books 'Jai Shree
Ram' has been discussed in detail and the same is hereby referred to and not repeated for the sake of brevity. Only the audited books of accounts have been rejected. The addition challenged in present ground of appeal has not been made from such audited books of accounts and has been made from the financials/books 'Jai Shree Ram' which have not been rejected. Thus the legal ground raised by the appellant is infructuous.
(16) The Id. AR also argued that the capital from partner is not taxable in the hands argued that the capital from parti of the firm and the same can only be taxed in the hands of partners. This contention of the appellant is discussed here under.
Firstly, the appellant has not even filed any confirmation from the partner regarding introduction of capital which is shown in the or as part of the capital balance as on 01.01.2014. The appellant has also not filed any affidavit from the partner regarding the same. There are no personal books of accounts of the partners to see whether the capital balance as on 01.01.2014 as reflected in 'Jai
Shree Ram' has been duly shown in such books of accounts. Thus on the one hand the appellant is claiming that the credit should be taxed in the hands of the partners and on the other hand the partners (who are representing the appellant firm in the assessment and appeal of the appellant firm), have not filed any conformation, affidavit, source evidences etc. -thus the approach of the appellant is not bonafide.
In the case of Commissioner of Income-tax v. Kishorilal Santoshilal [1995] 216
ITR 9 (Rajasthan)/[1995] 129 CTR 450 (Rajasthan) [06-02-1995), it has been held that cash credit entry in books of firm in partner's account or in respect of any credit by third party stands on same footing and, if firm is not in position to establish genuineness of such credit entry then it can be added as income from undisclosed sources in hands of assessee-firm.
In that case during the course of assessment proceedings the ITO found that certain amount was credited in one of the partner's account in the books of the assessee firm. The assessee firm explained that the investment had been made by the partner out of the recoveries made from money-lending business carried on by the partner and out of the sale proceeds of groundnut on the agricultural land of the partner and that such income had been declared in his individual return. The ITO however found that no such return was filed by partner and therefore he concluded that the amount was the assessee's income from undisclosed sources. The CIT (Appeals) affirmed the decision of the ITO. The Tribunal however deleted the addition holding that cash credit in the account of one of the partners, could not be assessed in the hands of the firm.
On reference, in this judgement, it is held by the Hon'ble Rajasthan High Court as under:-
"In A. Govindarajulu Mudaliar v. CIT [1958] 34 ITR 807, it was observed by the Supreme Court that there is ample authority for the position that where an assessee fails to prove satisfactorily the source and nature of certain amounts of cash received during the accounting year, the Income tax Officer is entitled to draw the inference that the receipts are of an assessable nature.
In P.V. Raghdva Reddi v. CIT [1956] 29 ITR 942, it was observed by the Andhra
Pradesh High Court that the burden of proof is not dependent upon the fact of a credit entry in the name of the assessee or in the name of a third party. In either case, the burden lies upon the assessee to explain the credit entry, though the onus might shift to the Income-tax Officer under certain circumstances. Otherwise a clever assessee can always throw the burden of proof on the income-tax authorities by making a credit entry in the name of a third party either real or pseudonymous. The same High Court in M.M.A.K. Mohindeen Thamby and Co. v.
CIT [1959] 36 ITR 481, relying on the said decision came to the conclusion that there is no distinction between the entries in the names of the partners and those in the names of the third parties, and the nature of the entry is not distinguishable.
In Hardwarmal Onkarmal v. CIT [1976] 102 ITR 779, it was observed by the Patna High Court that if cash credits are found in the account books of a partnership firm in the names of the partners, the credits are surely in the names of persons who constitute the firm itself. In such a case, the onus was on the assessee to establish that the partners had actually deposited the money and that the entries were not fictitious.
On the basis of the language used under section 68 and the various decisions of different High Courts and the apex court, the only conclusion which could be arrived at is:
(i)that there is no distinction between the cash credit entry existing in the books of the firm whether it is of a partner or of a third party,
(ii)that the burden to prove the identity, capacity and genuineness has to be on the assessee,
(iii)if the cash credit is not satisfactorily explained the Income-tax Officer is.
justified to treat it as income from "undisclosed sources",
(iv)the firm has to establish that the amount was actually given by the lender,
(v)the genuineness and regularity in the maintenance of the account has to be taken into consideration by the taxing authorities,
(vi)if the explanation is not supported by any documentary or other evidence, then the deeming fiction credited by section 68 can be invoked.
In these circumstances, we are of the view that simply because the amount is credited in the books of the firm in the partner's capital account it cannot be said that it is not the undisclosed income of the firm and in all cases it has to be assessed as an undisclosed income of the partner alone.
In these circumstances, we are of the view that the Tribunal was not justified in holding that the cash credits of Rs. 11,502 in the account of Shri Kishorilal, one of the partners, could not be assessed in the hands of the firm and in deleting the same. Since the matter was not considered by the Tribunal on the merits, the Tribunal would be free to hear the arguments of both the parties and decide afresh in view of the observations made above.
Accordingly, the reference is answered in favour of the Revenue and against the assessee.
In the case of Kailash Chand Agarwal v. Income Tax Officer, Ward-3, Bharatpur
[2017] 88 taxmann.com 540 (Rajasthan)/[2017] 394 ITR 771 (Rajasthan) [17-01
2017] it has been held that regard to the sources of the capital contributions by the partners, the assessee firm had given enough evidences in the shape of (i) entries in the books of account of the firm as well as the partners for those capital contributions, (ii) confirmations from the creditors who had given the money to the partners and (iii) returns of income/statements of computation of income/capital accounts of all such creditors; and that there was no ground to reject the findings adopted by the CIT(A) and no reasons were adopted by the Tribunal while reversing the finding of the CIT(A). In this judgement also, judgement of Commissioner of Income-tax v. Kishorilal Santoshilal (supra) has been referred
ITR 9), A. Govindarajulu Mudaliar v. CIT [1958] 34 ITR 807 (Supreme Court), V.
Raghdva Reddi v. CIT [1956] 29 ITR 942 (Andhra Pradesh High Court),
Hardwarmal Onkarmal v. CIT [1976] 102 ITR 779 (Patna High Court) credit entry in books of firm in partner's account or in respect of any credit by third party stands on same footing and, if firm is not in position to establish genuineness, identity and creditworthiness regarding such credit then it can be added as income from undisclosed sources in hands of assessee-firm.
It is also important to note that in the present case under appeal the appellant has not even filed any confirmation of affidavit along with source details and evidences from the partner regarding introduction of capital which is shown in the or as part of the capital balance as on 01.01.2014. There are no personal books of accounts of the partners to see whether the capital balance as on 01.01.2014
as reflected in 'Jai Shree Ram' has been duly shown in such books of accounts.
In view of the above discussion, this issue taken by appellant is hereby rejected.
(17) Appellant has also contended that the Jai Shri Ram is the consolidated affairs of the assessee, thus regular books of accounts of Shri Ambica Garments are also included in Jai Shri Ram. The verification of said fact has also been made during the course of assessment and accordingly from the total sale as appearing in Jai Shri Ram. GP with respect to sale already recorded in regular books of accounts has been eliminated, however while making the addition of alleged unexplained opening capital and loans, the amount already recorded in regular books of accounts was not eliminated.
In the assessment order as well as in earlier paragraphs of this order it has been uphheld that for the year under appeal (in some other subsequent years there is issue of other unreported segments books of accounts also which is not present in year under appeal) Jai Shri Ram is the consolidated affairs of the assessee, thus regular books of accounts of Shri Ambica Garments are also included in Jai
Shri Ram. The appellant has also filed an entry wise comparison and matching of the ledger account of capital and loan accounts in submission dated 11.11.2024. The appellant has specifically highlighted that the bank transaction entries are matching. A few minor mismatch have been identified by appellant and from a partners' capital on the same date in the audited books of accounts.
Accordingly, this contention of the appellant is allowed.
(18) The appellant has raised similar contention w.r.t. the loan balances as on 01.01.14 in the books 'Jai Shree Ram' and the audited books. This contention of the appellant was rejected in the assessment order on the ground that there was absence of evidence to prove that the parties of unsecured loans appearing in Jai
Shree Ram and Shri Ambica Garments are the same. In the appeal proceedings also the appellant has also not proven this. Even though in principle it has been upheld that Jai Shri Ram is the consolidated affairs of the assessee for the year however the contention of the appellant raised on this issue regarding loans is hereby rejected on the grounds that (i) possibility of some minor errors is not ruled out, and (ii) not proven by appellant that parties of unsecured loans appearing in Jai Shree Ram and Shri Ambica Garments are the same, (iii) the appellant has not submitted the ledger accounts of loan parties and their comparison of ledgers in books as Jai Shree Ram and Ambika Garments which was specifically requested vide hearing dated 06.11.2024, (iv) conditions of section 68 of the Act are not satisfied. However the appellant / Id. AR has submitted ledger account of Kotak Bank loan and made arguments regarding Kotak Bank Loan and contended that bank loan cannot be treated as unexplained and that the substantial entries are matching in the ledger account in Jai Shree Ram and Ambika Garments. Accordingly the addition of Rs. 2,56,996 made w.r.t. Kotak
Bank Loan is hereby directed to be deleted.
In view of the above, this ground of appeal is partly allowed.
6. Ground of Appeal No. 4 is as under:
Ground No. 4: Under the facts and circumstances, Ld. A.O. has erred in holding that there is violation of provisions of Section 269SS for the amount of Rs.1,45,000/- and consequently initiating the penalty u/s 271D. The action is unjustified, illegal or excessive and deserves to be deleted in full.
6.1 This ground of appeal is regarding the passing on of information by the assessing authority to the Joint Commissioner / Additional Commissioner for consideration for initiation of penalty proceedings under section 271D of the Act.
The Joint Commissioner / Additional Commissioner may or may not initiate such of the Joint Commissioner / Additional Commissioner.
Thus the ground of appeal is premature. Penalty proceedings are independent proceedings and the appellant is required to make its submissions before the appropriate authority during the penalty proceedings, if any. Accordingly, the ground of appeal raised by the appellant on this issue is treated as disposed off.
7. Ground of Appeal No. 5 is as under:
Ground No. 5: Under the facts and circumstances, Ld.AO has erred by initiating the levying penalty U/s 271(1)(c), the penalty. The action is unjustified, illegal or excessive and deserves to be deleted in full.
7.1 The ground is general in nature. The grounds are pre-mature as these are against mere initiation of penalty proceedings. Penalty proceedings are independent proceedings and the appellant is required to make his submissions before the appropriate authority during the penalty proceedings. Accordingly, the ground of appeal raised by the appellant on this issue is treated as disposed off.
8. Ground of Appeal No. 6 is as under:
Ground No. 6: That the appellant craves your indulgence to add, amend or alter all or any grounds of appeal before or at the time of hearing.
8.1 The appellant has not added and altered any of the above mentioned ground of appeal. Accordingly such mention by the appellant in its ground is treated as general in nature, not needing any specific adjudication and is accordingly treated as disposed off.
9. In the result, the appeal of the appellant is partly allowed.
8. Feeling dissatisfied from the above order of the ld. CIT(A), the assessee has preferred the present appeal before this Tribunal on the ground as reproduced hereinabove. To support the various grounds raised by the assessee, ld. AR of the assessee, has filed a detailed written submissions which reads as under :
GIST of Written Submissions:
1. Statutory Mandate under Section 153D of the Income-tax Act, 1961
1.1 As per the explicit and mandatory provisions enshrined under Section 153D of the Income-tax Act, 1961 (“the Act”), any Assessing Officer (“AO”) who is below the rank of the Joint Commissioner of Income Tax (“JCIT”) is required to obtain prior approval u/s 153D by forwarding the draft assessment order before passing the final assessment order under Section 153A read with Section 143(3) in cases arising out of a search.
1.2 In compliance with the said statutory requirement, the Respondent AO in the present case sought approval of the Joint Commissioner of Income Tax, Central
Range, Jaipur under Section 153D of the Act, and such approvals were granted in the following manner:
In the case of Shri Sanjay Kumar Karnani:
• A common approval for Assessment Years 2013–14 and 2014–15 vide letter dated 16.07.2021 (PBP-II-1);
• A common approval for Assessment Years 2015–16 to 2018–19 vide letter dated
16.07.2021 (PBP-257);
• Approval for Assessment Year 2019–20 vide letter dated 16.07.2021 (PBP-256).
In the case of M/s. Ambica Garments:
• A common approval for Assessment Years 2013–14 to 2015–16 vide letter dated
16.07.2021 (PBP-269);
• A common approval for Assessment Years 2016–17 to 2019–20 vide letter dated
20.07.2021 (PBP-270).
2. Lack of Application of Mind by the Approving Authority
2.1 A plain reading of the above approvals makes it abundantly evident that there is a total absence of application of mind, much less an independent application of mind, as contemplated by law. The approvals have been granted in a purely mechanical manner, devoid of any expression, observation, or reasoning that would indicate that the competent authority had applied its mind to the material placed before it.
2.2 The Ld. Joint CIT in all the cases has merely recorded a bald statement that “the draft assessment order in the following cases submitted by you are hereby approved u/s 153D of Income Tax Act, 1961”, followed by a tabular list containing basic particulars of the assessee. There is complete silence as to the consideration of issues involved or the basis on which such approval was accorded. Even the minimum requirement—of recording a brief indication of thought process or satisfaction after due examination of the draft order—is conspicuously absent.
“seen” or “approved” amounts only to rubber-stamping and does not meet the statutory mandate under Section 153D.
2.4 It is further submitted that the provisions of Section 153D cannot be construed as a mere procedural or empty formality. The legislative intent behind its enactment is twofold:
• Firstly, to safeguard the interests of the assessee by ensuring that no arbitrary, irrelevant, or unjustified additions are made in the assessment order; and • Secondly, to ensure that the assessment is made after proper enquiry and scrutiny under the supervision of a senior officer.
Thus, the involvement of a senior officer envisaged under Section 153D serves as a crucial check and balance, providing protection both to the Revenue and to the assessee, ensuring fairness and objectivity in the process of assessment.
3. Judicial Precedents Supporting the Contention
3.1 Jaipur ITAT in Resonance Eduventures Ltd Vs ACIT Central Circle-Kota in ITA No. 669 to 672/JPR/2024 vide order dated 10-03-2025
3.2 Delhi ITAT in Apple Commodities Limited Vs DCIT, Central Circle-II, Noida in ITA No. 1510/Del/2022 vide order dated 16.04.2025
3.3 Delhi ITAT in Shri Prateek Nagpal Vs ACIT, Central Circle-15 in ITA
No.522/Del/2022 vide order dated 10.01.2025
3.4 Delhi High Court in PCIT-15 Vs Shiv Kumar Nayyar in ITA No. 285/2024
vide order dated 15.05.2024
3.5 ACIT v. Serajuddin & Co. (2023) 333 CTR (Ori) 228
4. Prayer:
In view of the statutory requirement under Section 153D and the authoritative judicial pronouncements cited hereinabove, it is respectfully submitted that the approvals accorded by the JCIT, Central Range, Jaipur, having been granted in a mechanical manner without any application of mind, are invalid in law.
Consequently, the assessment orders passed pursuant to such defective
Hari Om and Jai Shree Ram:
Facts: The AO observed that during the search proceedings, the first balance sheet for the period from 01.01.2014, to 31.12.2014, of the firm M/s Hari Om, which was seized, indicated a Prop. capital of ₹ 1,08,36,565/- and unsecured loans of ₹1,34,53,241/- and ₹ 61,000/- The AO inquired why these amounts should not be treated as undisclosed cash credits.
In response, the assessee submitted that adding the amounts of capital and unsecured loans based on the tally data was unjustified due to the numerous errors and inconsistencies present in the data. The assessee asserted that the tally data lacked independent validity for income determination and required significant corrections. Despite this explanation duly supported by the evidence and instances, the AO disregarded the assessee's contention and the tally data found in the name of “Hari Om” were considered as the real books of account of the assessee by observing as under:
Although the tally data so found in the name of “Hari Om” was considered as the real books of accounts of the assessee but pointing out certain defects in the same, the alleged books of accounts were rejected u/s 145(3) and profits were estimated based by holding as under:
5.7 In view of aforesaid specific defects in the books of accounts, these books are not reliable or otherwise not capable of deducing the correct profitability of M/s Shree Ram Enterprises, therefore, provisions of Section 145(3) are invoked and the books of assessee are hereby rejected. Since the books have been rejected, profits are to be estimated u/s 144 on the basis of best judgment.
Going further, Ld. AO pointed out that the opening unsecured loans appearing in M/s Hari Om appeared to be merely the assessee’s own funds, disguised as unsecured loans, with no satisfactory explanation of their source. The seized tally data showed unsecured loans of ₹1,20,13,344/- as of 31.12.2014, compared to an opening balance of ₹ 1,34,53,241/- as of 01.01.2014. As a result, the AO made an addition of ₹ 2,43,50,806/- to the assessment on account of unexplained opening capital and unsecured loans by holding as under:
2014-15, the total cash withdrawals were Rs.7,00,000/- as against the cash introduction of Rs.11,000/- leaving with unexplained increase in balance by Rs.61,000/-. Therefore, the same is added to the total income of the assessee for A.Y. 2014-15. 6.8 Therefore, unexplained capital of Rs.1,08,36,565/-, opening unexplained capital in form of unsecured loan Rs.1,34,53,241/- and Rs.61,000/- cash received in excess of withdrawal namely unexplained, hence, the amount of Rs.2,43,50,806/- (10836565+13453241+61000) is added to the total income of the assessee for A.Y. 2014-15. Penalty proceedings u/s 271(1)(c) of the Act is hereby initiated for concealed particulars of income. The assessee accepted loan of Rs.1,34,53,241/- in cash and made cash addition of Rs.8,11,000/- totalling to Rs.1,42,64,241/- is clear violation of provisions of section 269SS of the Act. Therefore, proposal of initiating of penalty proceedings u/s 271D for violation of provisions of section 269SS of the Act is being sent to the Joint Commissioner of Income Tax, Central
Range- Jaipur.
(Addition of Rs.2,43,50,806/-)
Submission:
1.1 Addition u/s 68 based on Tally Data with Various Discrepancies is Arbitrary: At the outset, it is contended that the addition of ₹1,08,36,565/- to the opening capital was made by the AO based on hypothetical and erroneous entries found in the tally data. The assessee has consistently explained that the tally data was a consolidated record created by the staff primarily for calculating staff incentives.
This data was not intended to represent the true financial position of the business and contained numerous errors and inconsistencies. Specifically, entries had been inaccurately posted, some directly to the proprietor's account, and several outstanding balances were either un-posted or not properly written off. Therefore, the tally data was essentially a rough draft and lacked reliability for accurately determining income.
1.3 The AO’s addition was solely based on the seized tally data, which was incomplete and rife with errors. This data, comprising records of multiple businesses, was not a reliable basis for making additions. Furthermore, the AO did not find any defects or discrepancies in the regular books of accounts. The tally data, created for staff incentive calculation, was not intended to be used for income determination.
1.4 The arbitrary nature of the AO’s action is evident, particularly as the addition of ₹1,08,36,565/- was based on data starting from 01.01.2014, and the capital balance as of 31.12.2014, purportedly included profits for the entire period from 01.01.2014, to 31.12.2014. The data from “Hari Om” was fraught with errors and inconsistencies. The date chosen for the tally data, starting 01.01.2014, indicates that arbitrary figures were used, without a valid basis.
2. 1 Kindly refer CIT vs. H. S. Rathi (2015) 374 ITR 164 (Delhi): In this case, the court held that the addition made on the basis of inaccurate and incomplete data could not be sustained. The data used for the addition must be accurate and reliable for it to be considered valid.
2. 2 CIT vs. Smt. S. V. P. S. A. K. & Co. (2001) 251 ITR 646 (Kar): The court observed that the AO must apply his mind to the accounts and should not rely solely on discrepancies in incomplete data. The correctness of entries in the books of accounts needs to be verified in light of the entire evidence.
2.3 CIT vs. Calcutta Discount Co. Ltd. (1961) 41 ITR 191 (SC): The Supreme
Court emphasized that any addition to income should be based on clear and cogent evidence and not on hypothetical or incomplete data.
2.4 CIT vs. M/s. D. S. S. Industries (2017) 400 ITR 568 (Cal): The court ruled that if the data relied upon for making an addition is inconsistent and flawed, such additions cannot be sustained.
3. Opening Balance cannot be added u/s 68:
1,08,36,565/- which is the 1,34,53,241/- which is also an opening termed these amounts as opening capital and opening unsecured loans. The finding so rendered by the Ld.AO makes it evident that the said amount was opening balance of the alleged capital. Similarly at Page-10, Para 6.4 the opening balance of alleged unsecured loan has been taken by recording a similar finding reproduced hereunder:
3.2 It is a well-established principle of law that opening balances cannot be added to income u/s 68 of the Act. This provision is specifically designed to address the issue of unexplained credits in the books of account for the current financial year, and not for balances carried forward from previous years.
Kindly refer CIT vs. H.S. Rathi (2015) 374 ITR 164 (Delhi): The Delhi High
Court held that additions u/s 68 must be made for credits appearing during the year under consideration. The court clarified that opening balance, which are carried forward from previous years, cannot be subject to additions u/s 68. CIT vs. G. K. K. Enterprises (2002) 257 ITR 371 (Guj): The Gujarat High
Court ruled that S.68 pertains only to unexplained credits introduced during the year and not to opening balances. The addition u/s 68 should be restricted to credits during the financial year under review.
CIT vs. Orient Trading Co. (2001) 248 ITR 258 (Cal): This judgment emphasized that S.68 deals with the unexplained credit entries for the current assessment year. It cannot be used to add amounts that were part of opening balances or carried forward from previous years.
We further rely the decision of Hon’ble Juri ictional Jaipur Bench of ITAT in the case of DCIT Vs Alok Malpani in ITA No.334/JP/2022 vide order dated
08.12.2022. 3.3 In the present case, since the amounts of ₹1,08,36,565/- (opening capital) and ₹ 1,34,53,241/- (unsecured loans) represent balances from earlier financial years.
The addition of these amounts u/s 68 is therefore not permissible. Sec. 68 cannot be applied to opening balances, as it is intended to address unexplained credits appearing during the financial year under assessment.
3.4 Furthermore, the AO did not raise any issues regarding new unsecured loans taken during the year under consideration, and these were deemed genuine.
Therefore, if there were any discrepancies or issues, they should have been addressed with respect to fresh credits introduced during the current year, not with opening balances.
4. No addition u/s 68 when books of account are rejected:
4.1 Another crucial aspect to consider in this case is the principle that at the one hand, books of accounts have been rejected and on the other hand falling on the very same set of books to make the addition u/s 68. As submitted above, at Page-4,
Para-5.5 Ld. AO has pointed out the several defects in the books of accounts viz. not maintained financial year wise, not maintaining any stock records thus taking the stock value at the end of year on presumption only and any other deficiencies pointed out by the assessee and admitted by the Ld.AO and on the basis of these defects and deficiencies, the books of accounts were rejected u/s 145(3).
4.3 Upon rejecting the books of account u/s 145(3), the AO estimated the average gross profit rate at 12.15% based on best judgment, resulting in a trading addition of ₹3,10,688/-. This estimation was made u/s 144, which pertains to assessments based on the best judgment of the AO.
4.4 It is important to note that when the AO rejects the books of account and estimates profit based on S., no separate addition u/s 68 can be made, even if the 305 (Raj) wherein the Hon’ble Juri ictional High Court held that when net profit is estimated by the AO by rejecting the book result u/s 145(3) of the Act, no separate addition can be made on account of cash creditor the finding reads as under:
“AO having estimated the profit by applying a higher net profit rate to total contract receipts after rejecting assessee's books of account by invoking the provisions of section 145(3), no separate addition can be made on account of cash credit u/s.68, even though the assessee has failed to discharge its onus of proof in explaining the amount shown in the books of account”
From the decision compilation as serviced by the assessee by relying in the case of Dulla Ram vs. CIT (2014) 42 taxmann.com 349 (P&H High Court) we note that Hon’ble High court reaffirmed the principle that when the AO resorts to estimating profit after rejecting books of account, it encompasses all potential discrepancies, including unexplained credits. The estimation should be deemed sufficient to address the income and no additional separate addition under Section 68 is warranted unless clear evidence of unexplained credits is presented. Once the AO has rejected the books of account u/s 145(3) and estimated the profit, such estimation should account for all discrepancies, including those related to unexplained credits. No separate addition u/s 68 is appropriate in this context unless specific and concrete evidence of unexplained cash credits is provided.
The principles established in the cases of G. K. Contractor and Dulla Ram independent additions u/s 68. A Similar view has been taken in the case of Even otherwise the addition of Rs.1,08,36,565/- shown as the opening balance of Raghav Karnani Minor son of Mr. Sanjay Karnani capital u/s 68 of the Act considering the same as unexplained capital.
Section 68 of the act casts a duty upon the assessee to explain the source of any sum found credited in the books of accounts. In the instant case, the assessee duly explained that the sum so found credited is the opening balance of Propertor’s capital account, which is carried forwarded balance of earlier years. Under these circumstances, the onus casted upon the assessee stood discharged once it was explained and resultantly the addition so made in the hands of the assessee cannot be sustained.
Record also reveals that the addition has been made on account of a ledger account appearing in the “Hari Om” in the name of Raghaw Karnani, who is minor son of the assessee, treating the same as unexplained capital account of Shri Ram Enterprises, proprietorship concern of Shri Sanjay
Kumar Karnani. Therefore, the addition of Rs.1,08,36,565/- on account of alleged opening capital and addition of Rs.1,34,53,241/- are carried forwarded balances from the prior period, thus not involving any amount for the same is required to be made in AY 2014-15 and thereby directed to be delete.
From the records the bench noted that the nature of the entries recorded in the Raghaw Karnani account, the impugned ledger account, which was found and seized, pertains to the period from January 1, 2014 to December 31, 2017. Over the span of these four years, the account solely consists of book entries, with no evidence of any actual flow of funds. This clearly indicates that the account is merely a notional record and does not reflect any real transfer of money or funds by the assessee to constitute any alleged unexplained capital. The nature of entries posted in the said account clearly highlights that opening balance is nothing but the amount lying accumulated in the account due to certain book entries passed without involving any actual flow of the funds, therefore, it cannot be construed as a basis for any addition under section 68 of the Income Tax
Act. The bench also noted the opening amount punched in the tally were not indicating any actual balances or financial positions of the assessee. As the tally so maintained was full of errors are omissions, some of those instances as pointed out in the written submission which was not controverted are as under :
books to ensure correct quantification of profits. In the tally data of “Hari Om” so found and impounded, it is evident that the inventory details are not maintained and neither the same was carried out. Instead of detailed records reflecting the actual stock, only an imaginary single figure was "punched in" that too at the end of December. This method, rather than relying on an accurate and methodical approach to stock valuation, represents a superficial entry that does not provide any real or meaningful information about the actual state of the stock and in turn actual profitability, making the entire data as deaf and dumb for the purpose of determining the profitability of the assessee or to assume that amount so recorded in the capital accounts or unsecured loans constitute the real affairs of the assessee.
(b) The unauthenticity and non-reliability of Hari Om is further evident from the fact that the closing balance sheet of Hari Om is depicting the cash in hand of Rs.27,55,263.35/-, whereas during the course of search, no such cash was found.
(c) The rule of classification has not been followed properly, like account of Raghaw
Karnani classified under capital, which is purely a notional account. Similary,
Mahesh Munhdra account which is towards purchases thus constituting creditor classified under unsecured loans and in some period the very same account has been classified under capital account. Same is the case with Ramesh Mundhra
Account, who is nor the proprietor still his account has been wrongly classified under Capital account. In this regards, screenshot of tally is placed hereunder:
(e) An account titled as “Old Difference” carried in the Hari Om and shown under the category of capital account. Similarly, suspense account also shown in the Hari
Om
(f) The aforesaid instances further go on to show that Hari Om data was full of error and not maintained systematically and accounts classified under capital were not strictly capital accounts in the nature because the assessee being a proprietorship concern, only one capital account can be there and the same was Sanjay Karnani Person account maintained in the very same tally (enclosed in paper book at Page-10), thus finding of Ld.AO that Raghaw Karani account is capital account of assessee is unreasonable and contrary to the correct facts of the case.
So far as alleged opening loan of Rs.1,34,53,241/- is concerned, the same consists of opening balance of alleged loan punched in the following names:
Closing Balance
Credit
Ajit Ji Advocate 967832.00
Jain Vastralaya 3628051.51
MAHESH JI
MUNDHRA
5643011.00
Milan Rathi
413020.00
Grand Total 1,34,53,240.62/-
From the submission made we note that the names listed above shows that these were accounts created in the name of family members and amounts have been shown therein by way of book entries. Certain accounts are towards expense payable to advocate, which is in fact in the nature of creditor. Similarly, Jain Vastralay is a supplier of clothes thus in the nature of sundry creditor. Similarly, Mahesh Mundhra account is also towards purchases made, thus not falling under category of unsecured loans to make any addition u/s 68 of the Act. Therefore, considering the facts and judicial precedent we hold that the addition of Rs. 1,08,36,565/-
(opening capital) and Rs. 1,34,53,241/- (unsecured loans) represent balances from earlier financial years and cannot be added in the year under consideration as per provision of section 68 of the Act and therefore,
ITA No.56/JPR/2025 and Ground No. 2, 3, 4 and 5 in ITA No.
671/JPR/2025 (AY 2014-15) are allowed.
22. Vide Ground No. 3, 4 and 5 of ITA No. 58/JP/2025, Ground No. 3
and 4 of ITA No.59/JP/2025 and Ground No. 3 of ITA No.60/JP/2025, wherein the above named assessee – appellant contested the additions made on account of Race Kids wear and Gopala Garments.
The brief facts related to the disputes are that while search proceedings, several loose papers were discovered at the residential premises of Shri Ramesh Kumar Mudhra, (Partner of assessee firm) located at H/3 – Mahamandir, Nathji Ka Asan, Outside Second Pole,
Jodhpur. Among these documents was a page titled "M/s. Gopala
Garments," covering the period from 01.01.2016 to 31.12.2017. This document was seized and was marked as Exhibit-17 of Annexure-AS (Party No. A-1). Other pages were found titled "M/s. Race Kids Wear,
Delhi," which pertains to the financial activities and transactions for the period from 01.01.2016 to 31.12.2017. These documents were seized and were marked as Exhibit-17 of Annexure-AS (Party No. A-1) and are placed on record at Page-2-6 of Paper Book-II filed by the assessee.
to make any addition u/s 68. An alternative plea was taken that if these are considered belonging to the assessee firm, then no separate addition for these is required as Jai Shree Ram is the consolidated data and no such incriminating and corroborative evidence was found to suggest that these documents have any standalone existence.
On this issue the ld. AR of the assessee submitted that while search proceedings, several loose papers were discovered at the residential premises of Shri Ramesh Kumar Mudhra, located at H/3 – Mahamandir,
Nathji Ka Asan, Outside Second Pole, Jodhpur. Among these documents was a page titled "M/s. Gopala Garments," covering the period from 01.01.2016 to 31.12.2017. This document was seized and is recorded as Exhibit-17 of Annexure-AS (Party No. A-1) whose image reads as under :
to make any addition u/s 68. An alternative plea was taken that if these are considered belonging to the assessee firm, then no separate addition for these is required as Jai Shree Ram is the consolidated data and no such incriminating and corroborative evidence was found to suggest that these documents have any standalone existence.
On this issue the ld. AR of the assessee submitted that while search proceedings, several loose papers were discovered at the residential premises of Shri Ramesh Kumar Mudhra, located at H/3 – Mahamandir,
Nathji Ka Asan, Outside Second Pole, Jodhpur. Among these documents was a page titled "M/s. Gopala Garments," covering the period from 01.01.2016 to 31.12.2017. This document was seized and is recorded as Exhibit-17 of Annexure-AS (Party No. A-1) whose image reads as under :
trading additions. Clearly documents/sheets seized during the search should not be considered the books of accounts of the assessee. These sheets do not have independent validity for determining income. This means that the same cannot be relied upon as a standalone source for assessing the financial performance of the business. Therefore, these points, it is clear that the seized Tally data cannot serve as a reliable basis for any financial conclusions regarding the assessee's income. Proper documentation and verifiable records are essential for ensuring fair and accurate tax assessments. Revenue also not proved that the assessee or that of the family members really operates the firm M/s Race Kids Wear,
Delhi, or Gopala Garments. Instead, these businesses are owned by his relatives, who are relatively new to the business. The assessee contended that these relatives sought his assistance in their ventures, but did so partners where they operate. It is further important to peruse the nature of expenses shown in the seized profit and loss account. A bare perusal thereof clearly shows that most of the expenses are nil. We also note from the seized profit and loss accounts which shows that most of the expenses are in the nature of manufacturing expenses such as factory rent, master assessee or that of Shri Ramesh Kumar. The absence of such evidence further reinforces the assertion that these firms are distinct entities owned by other individuals, not the assessee. Similarly the addition of Rs.
10,53,150/- relates to the unsecured loans in the assessee's financial records is based exclusively on loose papers, specifically an alleged balance sheet for M/s Race Kids Wear dated 31.12.2016. The assessee contends that this inference is fundamentally flawed, as it relies on the decision of the co-ordinate bench Jaipur’s decision M/s Hari Om
Enterprises vs. ITO (ITA No. 1234/JP/2023), the tribunal clearly stated that justify additions to an assessee's income. The court emphasized that the integrity of financial records is crucial and that any assertions made based on loose or unverified documents are insufficient for tax purposes. Even otherwise the averments of the revenue that M/s Gopala Garments and M/s
Race Kids Wear are related to the assessee lacks any corroborative rather than conjecture or assumptions. The Hon`ble Court made it clear that mere presumption, without solid proof, cannot justify the addition of income. These ruling underscores the principle that the burden of proof lies with the tax authorities to demonstrate a clear connection between the taxpayer and any alleged income or liabilities. The legal framework requires that tax assessments should not be based on presumption or assumption having speculative conclusions. The lack of tangible evidence linking the assessee to the operations or financial outcomes of Gopala Garments and Race Kids Wear calls into question the validity of any additions made to the assessee's income. When Shri Ramesh Kumar have clarified about the assessee that the contention of the ld. AO was that M/s. Gopala Garments and M/s. Race Kids Wear are not independent entities but rather operational units of M/s Ambica Garments. This characterization carries significant implications for the assessment of income and taxation. Given this relationship, the consolidated financial affairs of Ambica Garments are already reflected in the financial statements of Jai Shri Ram. Since any profits generated by Gopala Garments and Race Kids Wear are included attempt to add these profits to the assessee's income would constitute
58/JP/2025, Ground No. 3 and 4 of ITA No.59/JP/2025 and Ground No. 3
of ITA No.60/JP/2025 are allowed.
In the result, all appeals of the assessee are disposed off in terms of the above observations.
Order pronounced in the open court on 15/10/2025. ( डा० एस. सीथालक्ष्मी )
(Dr. S. Seethalakshmi)
U;kf;d lnL;@Judicial Member ( राठौड कमलेश जयन्तभाई )
(Rathod Kamlesh Jayantbhai) lys[kk lnL;@Accountant Member
जयपुर / Jaipur
दिनांक/Dated:- 15/10/2025
*Ganesh Kumar, Sr. PS vkn s'k dh izfrfyfi vxzsf’kr@Copy of the order forwarded to:
1. The Appellant- Shri Ambica Garments, Jodhpur
Shri Sanjay Kumar Karnani, Jaipur
2. izR;Fkh Z@ The Respondent- ACIT, Central Circle-03, Jaipur
3. vk;dj vk;Dr@ The ld CIT
4. vk;dj vk;qDr¼vihy½@The ld CIT(A)
5. foHkkxh; izfrfuf/k] vk;dj vihyh; vf/kdj.k] t;iqj@DR, ITAT, Jaipur
6. xkMZ QkbZy@ Guard File (ITA Nos. 56 to 61/JP/2025 & 671 to 676/JP/2025) vkns'kku qlkj@ By order, lgk;d iathdkj@Asstt.