ITAT Jodhpur Judgments — January 2025

The Tribunal held that the assessee had sufficient cash on hand, and the reasons for accumulation, while not fully substantiated, were considered by the CIT(A). Regarding property sales, the Tribunal upheld the CIT(A)'s view that some plots were held as stock-in-trade and others as capital assets, based on the nature of holdings and prior treatment.

The Tribunal held that the assessee had submitted a valuation report from an accountant, which was not doubted by the AO or CIT(A). The Tribunal relied on its coordinate bench's decision and directed the AO to delete the addition.

The Tribunal found that the AO and CIT(A) erred in discrediting a later municipal letter which stated the land was outside municipal limits, especially when it referenced a relevant gazette notification. The Tribunal set aside the addition to income and capital gains tax.

The Tribunal upheld the CIT(A)'s decision to estimate the net profit at 0.11%. The revenue failed to demonstrate any perversity in the CIT(A)'s findings or provide contrary material to deviate from the binding precedent of the earlier year's order.