Shri Ambika Garments vs. ACIT 6.4 In CIT v. M/s. Rajasthan State Industrial Development and Investment Corporation Ltd.

Sanjay Kumar Karnani, Jaipur vs. ACIT, Central Circle-3, Jaipur

In the result, all appeals of the assessee are disposed off in terms of

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.

…ssible. The estimation must be based on credible material and should reflect a reasonable assessment rather than a random figure. Shri Ambika Garments vs. ACIT 6.4 In CIT vs. M/s. Rajasthan State Industrial Development and Investment Corporation Ltd. (2015) 373 ITR 292 (Raj): The Rajasthan High Court reaffirmed that the AO’s discretion to estimate income after rejecting accounts must be exercised judiciously. The estimation should be based on tangible evidence and not on speculative or arbitrary figures. 7.1 In the present scenario, the AO's estimation of ₹2,06,55,593/- based on an average gross profit rate of…

Sanjay Kumar Karnani, Jaipur vs. ACIT, Central Circle-3, Jaipur

In the result, all appeals of the assessee are disposed off in terms of

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

…ssible. The estimation must be based on credible material and should reflect a reasonable assessment rather than a random figure. Shri Ambika Garments vs. ACIT 6.4 In CIT vs. M/s. Rajasthan State Industrial Development and Investment Corporation Ltd. (2015) 373 ITR 292 (Raj): The Rajasthan High Court reaffirmed that the AO’s discretion to estimate income after rejecting accounts must be exercised judiciously. The estimation should be based on tangible evidence and not on speculative or arbitrary figures. 7.1 In the present scenario, the AO's estimation of ₹2,06,55,593/- based on an average gross profit rate of…

Shri Ambica Garments, Jodhpur vs. ACIT, Central Circle-3, Jaipur

In the result, all appeals of the assessee are disposed off in terms of

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

…ssible. The estimation must be based on credible material and should reflect a reasonable assessment rather than a random figure. Shri Ambika Garments vs. ACIT 6.4 In CIT vs. M/s. Rajasthan State Industrial Development and Investment Corporation Ltd. (2015) 373 ITR 292 (Raj): The Rajasthan High Court reaffirmed that the AO’s discretion to estimate income after rejecting accounts must be exercised judiciously. The estimation should be based on tangible evidence and not on speculative or arbitrary figures. 7.1 In the present scenario, the AO's estimation of ₹2,06,55,593/- based on an average gross profit rate of…

Shri Ambica Garments, Jodhpur vs. ACIT, Cental Circle-3, Jaipur, Jodhpur

In the result, all appeals of the assessee are disposed off in terms of

…ssible. The estimation must be based on credible material and should reflect a reasonable assessment rather than a random figure. Shri Ambika Garments vs. ACIT 6.4 In CIT vs. M/s. Rajasthan State Industrial Development and Investment Corporation Ltd. (2015) 373 ITR 292 (Raj): The Rajasthan High Court reaffirmed that the AO’s discretion to estimate income after rejecting accounts must be exercised judiciously. The estimation should be based on tangible evidence and not on speculative or arbitrary figures. 7.1 In the present scenario, the AO's estimation of ₹2,06,55,593/- based on an average gross profit rate of…

Shri Ambica Garments, Jodhpur vs. ACIT, Cental Circle-3, Jaipur

In the result, all appeals of the assessee are disposed off in terms of

…ssible. The estimation must be based on credible material and should reflect a reasonable assessment rather than a random figure. Shri Ambika Garments vs. ACIT 6.4 In CIT vs. M/s. Rajasthan State Industrial Development and Investment Corporation Ltd. (2015) 373 ITR 292 (Raj): The Rajasthan High Court reaffirmed that the AO’s discretion to estimate income after rejecting accounts must be exercised judiciously. The estimation should be based on tangible evidence and not on speculative or arbitrary figures. 7.1 In the present scenario, the AO's estimation of ₹2,06,55,593/- based on an average gross profit rate of…

Nitu Khadariya, Jaipur vs. ITO Ward 1(3), Ncrb Building

In the result, the appeal of the assessee is allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

…have to also substitute one phrase with another phrase in the said Section, which is clearly not permissible in law. Reliance in this regard is placed on the decision of the Hon'ble Apex Court in the case of CIT v. Sham L. Chellaram [2015] 54 taxmann.com 348/373 ITR 292 (Bom.). 29. It was submitted on behalf of Revenue that the period of limitation for the purposes of Section 149 of the Act has to be seen with respect to the original notice under section 148 of the Act, which was issued to petitioner on 8th April 2021 and as the said notice was issued within the period of six years from the end of the relevant a…