Sanjay Kumar Karnani, Jaipur vs. ACIT, Central Circle-3, Jaipur
In the result, all appeals of the assessee are disposed off in terms of
ITA 673/JPR/2025[2016-17]Status: DisposedITAT Jaipur15 Oct 2025AY 2016-17
Bench: AO on 12-04-2021 18. Reply filed before AO on 15-07-2021 19. Additional Written Submissions filed before CIT(A) for AY 2014-15 on 11-11-2024 20. Written Submissions filed before CIT(A) for AY 2014-15 21. Written Submissions filed before CIT(A) for AY 2015-16 on 10-10-2024 22. Written Submissions filed before CIT(A) for AY 2016-17 on 10-10-2024 23. Written Submissions filed before CIT(A) for AY 2017-18 on 15-10-2024 24. Written Submissions filed before CIT(A) for AY 2018-19 on 15-10-2024 25.
For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68
…dence. 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: ITA Nos. 56 to 61/JP/2025 Shri Ambika Garments vs. ACIT Shri Ambika Garments vs. ACIT 3.1 It is submitted that the AO made an addition of ₹1,08,36,565/ 3.1 It is sub…