DCIT, CENTRAL CIRCLE AJMER, AJMER vs. PUJA SYNTHETICS PRIVATE LIMITED, BHILWARA
In the result, the appeal of the Revenue is dismissed
ITA 87/JPR/2023[2009-10]Status: DisposedITAT Jaipur09 Nov 2023AY 2009-10
Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)
For Appellant: Shri Mukesh Soni (Adv.)For Respondent: Shri A.S. Nehra (Addl.CIT)
Section 115JSection 153ASection 263
…lso not disputed by the Revenue. Thus, relying on the decision of the CIT vs. Lovely Exports (P.) Ltd. 216 CTR 195 (SC) decided by the Hon’ble Apex Court and the decision of the Hon’ble Jurisdictional High Court in the case CIT vs. Morani Automatives (P.) Ltd 264 CTR 86 (Raj.). Based on these the ld. AR of the assessee submitted that the primary onus has been discharged the obligation casted upon it and the appeal of the revenue is not sustainable considering the binding judicial precedent.The ld. AR of the assessee thus stated that “if the share application money is received by the assessee company from alleged…