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“genuineness of the transaction”

Cash Credits & Unexplained ItemsSection 68Section 685,938 judgments

The decision most relied on for genuineness of the transaction is Sumati Dayal v. CIT (214 ITR 801), cited in 1,967 judgments on BharatTax.

Leading authorities on genuineness of the transaction

Sumati Dayal v. CIT
214 ITR 801 · 1995 · Supreme Court
1,967
citing judgments

The Revenue is entitled to look behind the apparent form of a transaction to discover its true nature, applying the test of human probabilities and surrounding circumstances. If transactions defy logic or are unnatural, they can be treated as bogus, even if supported by some documentation, especially in cases of cash credits or unexplained investments.

CIT v. Durga Prasad More
82 ITR 540 · 1971 · Supreme Court
1,579
citing judgments

Tax authorities must judge evidence using the test of human probabilities and consider the apparent as real until there are reasons to believe it is not. They can rely on circumstantial evidence and the preponderance of probabilities to determine the genuineness of transactions.

CIT v. Orissa Corporation Pvt. Ltd.
159 ITR 78 · 1986 · Supreme Court
897
citing judgments

When an assessee provides the identity and address of a creditor or investor for a cash credit or share capital under Section 68, the burden shifts to the Department to establish lack of genuineness or creditworthiness, requiring it to conduct further inquiries; mere non-compliance by third parties to summons cannot be the sole basis for an adverse inference against the assessee.

CIT v. Lovely Exports (P) Ltd.
216 CTR 195 · 2008 · Supreme Court
854
citing judgments

If an assessee company receives share application money from alleged bogus shareholders and provides their details to the Assessing Officer, no addition can be made under Section 68 in the company's hands; the Department must proceed against the shareholders by reopening their individual assessments.

McDowell & Co. Ltd. v. CTO
154 ITR 148 · 1985 · Supreme Court
741
citing judgments

The Supreme Court held that while legitimate tax planning is permissible, transactions structured as a "colourable device" or "subterfuge" solely to avoid tax are impermissible. It mandates a judicial shift to look beyond the form to the substance of a transaction, allowing the lifting of the corporate veil in tax evasion arrangements.

(Central)-1 v. NRA Iron & Steel (P) Ltd.
103 Taxmann.com 48 · 2019 · Supreme Court
696
citing judgments

When assessing cash credits, share capital, or loans, the assessee bears the onus to prove the identity, creditworthiness, and genuineness of transactions. This burden is not discharged merely by documentary evidence if field inquiries reveal accommodation entries or dealings with paper/shell companies.

Kale Khan Mohammad Hanif v. CIT
50 ITR 1 · 1963 · Supreme Court
581
citing judgments

The assessee bears the onus of proving the source and nature of any sum of money or receipt found to have been received by them. If the assessee fails to satisfactorily explain the receipt, the Income-tax Officer is entitled to treat it as taxable income.

Umacharan Shaw & Bros. v. CIT
37 ITR 271 · 1959 · Supreme Court
567
citing judgments

An income tax assessment or addition cannot be sustained solely on the basis of suspicion, surmises, or conjectures, as strong suspicion does not amount to proof. The revenue authorities must rely on concrete evidence and material to frame an assessment.

Judgments citing genuineness of the transaction

Tr Pchamuthu Now Known As Tr Paarivendhar, Chennai vs. ACIT, Central Circle-1(3), Chennai

In the result, the appeal filed by the assessee is partly allowed

ITA 231/CHNY/2023[1998-99]Status: DisposedITAT Chennai23 Feb 2024AY 1998-99

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri. D. Anand, AdvocateFor Respondent: Shri. Nilay Baran Som, IRS, CIT
Section 143(3)Section 148Section 68Section 69

assessee can discharge his burden of proof by proving three things: Identity of the creditor, capacity of the creditor and the genuineness of the transaction in question. These three things were also not discharged by the assessee in this case. As the credit in the capital account

North Facing Real Tech Pvt Ltd, Bangalore vs. Income Tax Officer, Ward-5(1)(1), Bangalore

In the result, appeal of the assessee is allowed for statistical purposes

ITA 976/BANG/2023[2018-19]Status: DisposedITAT Bangalore23 Feb 2024AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahuassessment Year : 2018-19

For Appellant: Shri Snehal, C.AFor Respondent: Shri Subramanian S, JCIT (DR)
Section 115BSection 143(2)Section 56(2)(viib)Section 68

Learned ITO has erred in not relying the documents produced before him to prove the entire transaction in terms of Identity, Creditworthiness & Genuineness of the Transaction except one party . 3. The learned CIT (A) (NFAC) has erred upholding the aforesaid addition made ... submission. After observing the details submitted by the assessee the AO Page 4 of 9 noted that assessee failed to substantiate identity, genuineness of the transaction and creditworthiness of share subscribers with supporting documents/evidences of Rs.1,59,75,500/- received during the financial year 2017- 18. Since the assessee failed

DCIT Central Circle -2(2), Mumbai vs. Shri Viral Saraf Mittal, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 1843/MUM/2022[2018-19]Status: DisposedITAT Mumbai23 Feb 2024AY 2018-19

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bledcit – Central Circle – 2(2) V. Viral Saraf Mittal Room No. 806, 8Th Floor 901/902, Capri Heights Old Cgo Annex Building Palli Hill, Bandra (W) M.K. Road, Mumbai - 400020 Mumbai - 400050 Pan: Azbps0317C (Appellant) (Respondent) Assessee Represented By : Shri Sidharth Kothari Department Represented By : Ms. Kavitha Kaushik

Section 10(38)Section 143(2)Section 68

preceding paras clearly suggest that the revenue cannot take or accept such make-believe transactions, as presented by the assessee. Truth or genuineness of such transactions must prevail over the smoke screen, created by way of premeditated series of steps taken by the assessee with a view to imparting ... this, all that the Commissioner observed is that the Assessee transacted through brokers at Calcutta, which itself raises doubt about the genuineness of the transactions and the financial result and performance of the Company was not such as would justify the increase in the share prices. Therefore, he reached

ITO 28 (1)(1), Mumbai vs. Gahlot Construction, Mumbai

In the result, the appeal of the revenue & CO of the assessee is dismissed

ITA 2475/MUM/2021[2008-09]Status: DisposedITAT Mumbai23 Feb 2024AY 2008-09

Bench: Shri Br Baskaran, Am & Shri Aby T. Varkey, Jm आयकर अपील सं/ I.T. A. No. 2475/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2008-09) Ito-28(1)(1) बिधम/ M/S. Gahlot Construction Room No. 329, Tower No. Plot No-28A, Gahlot Vs. 6, 3Rd Floor, Vashi Railway Complex, Sector-10, Station, Navi Mumbai- Nerul, Navi Mumbai- 400703. 400703. Cross Objection No. 82/Mum/2023 Arising Out Of I.T.A. No.2475/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2008-09) M/S. Gahlot Construction बिधम/ Ito-28(1)(1) Plot No-28A, Gahlot Room No. 329, Tower Vs. No. 6, 3Rd Floor, Vashi Complex, Sector-10, Nerul, Navi Mumbai-400703. Railway Station, Navi Mumbai-400703. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaofm5698J (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Ms. Ritika Agarwal Revenue By: Shri Raj Singh Meel (Sr. Ar) सुनवाई की तारीख / Date Of Hearing: 30/01/2024 घोषणा की तारीख /Date Of Pronouncement: 23/02/2024 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Revenue; & The Assessee Has Filed A Cross Objection (Co) Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [Hereinafter Referred To As The “Cit(A)”] Dated 30.10.2021 For The Ay. 2008-09. 2. The Main Grievance Of The Revenue Is Against The Action Of The Ld. Cit(A) Deleting The Addition Of Rs.5 Cr Which Was Added By The

For Appellant: Ms. Ritika AgarwalFor Respondent: Shri Raj Singh Meel (Sr. AR)
Section 132Section 139Section 147Section 151Section 153CSection 68

source as held by the Bombay High Court in the case of Orient Trading Co, Ltd. v. CIT [1963] 49 TTR 723. The genuineness of the transaction is ITA. No.2475/M/21 CO. No.82/M/2023 A.Y No. 2008-09 Gehlot Construction proved by the fact that the payment to the assessee as well ... Income- tax Act will be that though apart from establishing the identity of the creditor, the assessee must establish the genuineness of the transaction as well as the creditworthiness of his creditor, the burden of the assessee to prove the genuineness of the transactions as well as the creditworthiness

M/S Tjr Properties Pvt. Ltd., Chandigarh vs. ACIT, CC-2, Chandigarh

In the result, the Appeal is partly allowed

ITA 738/CHANDI/2022[2016-17]Status: DisposedITAT Chandigarh22 Feb 2024AY 2016-17

Bench: Shri A.D. Jain & Shri Vikram Singh Yadav

For Appellant: Sh. Rohit Goyal, CA &For Respondent: Smt. Kusum, CIT-DR
Section 132Section 132(1)Section 143(3)Section 153Section 153ASection 153A(1)(b)Section 153DSection 68

said loans were repaid during the year itself through banking channels. Further, if the AO or CIT(A) were not satisfied with the genuineness of the transaction with the lender company, they could have initiated action under Sections 133(6) or 131 of the Act for further investigation. However ... Thus, it required to examine the identity and creditworthiness of the persons from who's amounts have been received and genuineness of the transactions on merit considering each credit separately. The AO has not discussed each and cred separately on merits in the assessment order before drawing the inference that

ACIT, CC-3(1), Hyderabad vs. Lepl Projects Limited, Vijayawada

The appeal of the Revenue is allowed for statistical purposes

ITA 345/HYD/2023[2017-18]Status: DisposedITAT Hyderabad22 Feb 2024AY 2017-18

Bench: Shri R.K. Panda & Shri Laliet Kumar

For Appellant: Shri K.C. Devdas, AdvocateFor Respondent: Dr.K.J. Rao, CIT-DR
Section 143(2)Section 143(3)Section 68

furnished. 4.2. As seen from the information filed by the assessee, though it appears to be the assessee proved the identity, creditworthiness and genuineness of the transaction, alternatively, the discussion made by the AO at the last para of Page No. 7 and first para of page No.8 ... u/s.69C of the IT Act may also be considered." The Assessing Officer has agreed that the appellant has proved the identity, creditworthiness and genuineness of the transactions with M/s MEIL. Since the Assessing Officer found the contention of the appellant that the addition of Rs.116,04,55,413/- cannot

Subhash Damodar Annamwar, Mumbai vs. Income Tax Officer 34(3)(4), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3227/MUM/2023[2011-12]Status: DisposedITAT Mumbai22 Feb 2024AY 2011-12

Bench: Shri Aby T Varkey, Jm & Ms Padmavathy S, Am

For Appellant: Shri Bhupendra ShahFor Respondent: Dr. Yogendra T. Wakare
Section 148Section 234Section 271Section 68Section 69C

confirmed the additions made by the AO stating that mere production of documents and contracts alone cannot prove the genuineness of the transaction and that no prudent investor would invest in a company which does not have any growth in their business. Accordingly, the CIT(A) confirmed the additions made ... establish that the assessee in any way is involved in rigging the price of the shares. The assessee in order to support the genuineness of the transaction has submitted all the relevant documents in the form of broker bill, contract summary, bank statement, etc. (page

Savla Buildwell LLP, Mumbai vs. National Faceless Appeal Centre, Delhi

In the result, the appeal by the assessee is allowed for statistical purposes

ITA 2066/MUM/2022[2013-14]Status: DisposedITAT Mumbai22 Feb 2024AY 2013-14

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Shri Prateek JainFor Respondent: Shri Manoj Kumar Singh
Section 143(1)Section 143(3)Section 147Section 148Section 250Section 254(1)Section 68

that the transactions are true and genuine. Accordingly, the AO held that the assessee has failed to discharge its onus to prove the genuineness of the transaction and considered the loan of Rs. 75 lakh as unexplained cash credit under section 68 of the Act. 6. In the appeal before

Ravindrabhai Lakshmanrav Mane, Ahmedabad vs. ITO, Ward-5(3)(5), Ahmedabad

In the result the appeals filed by the assessee in IT[SS]A Nos

ITA 139/AHD/2020[2013-14]Status: DisposedITAT Ahmedabad21 Feb 2024AY 2013-14

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 153ASection 271(1)(c)

gift from his Paternal uncles. The assessee during the assessment proceedings clearly explained the source of gifts and also identity, creditworthiness and genuineness of the transaction. In the absence of any seized material and unabated assessments, the entire addition made by the AO is against the well settled principle

Ravindrabhai Lakshmanrav Mane, Ahmedabad vs. ITO, Ward-5(3)(5), Ahmedabad

In the result the appeals filed by the assessee in IT[SS]A Nos

ITA 138/AHD/2020[2010-11]Status: DisposedITAT Ahmedabad21 Feb 2024AY 2010-11

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 153ASection 271(1)(c)

gift from his Paternal uncles. The assessee during the assessment proceedings clearly explained the source of gifts and also identity, creditworthiness and genuineness of the transaction. In the absence of any seized material and unabated assessments, the entire addition made by the AO is against the well settled principle

Roselabs Polymers Limited, Ahmedabad vs. DCIT, Circle-3(1)(2), Ahmedabad

In the result, the appeal filed by the Assessee is dismissed in limine

ITA 425/AHD/2019[2012-13]Status: DisposedITAT Ahmedabad21 Feb 2024AY 2012-13

Bench: Ld. Cit(A) For The Assessment Year 2012-13 An Exparte Appellate Order Was Passed. For The Assessment Year 2012-13 One Shri Sagar Vasoya Appeared Before Ld. Cit(A), However The Assessee Appeal Was Dismissed By A Detailed Speaking Order.

Section 143(3)Section 68

Pvt.Ltd as well as appellant goes on to prove beyond doubt according to A.O. that appellant has failed to prove identity, creditworthiness and genuineness of the transactions with respect to all investments made by Mis Gopalka Motor Investo Pvt.Ltd., M/s Pushpadant Commotrade Pvt Ltd Shri Pawankumar Agarwal and Smt Zameer

Roselabs Polymers Limited, Ahmedabad vs. The Deputy Commissioner of Income Tax, Circle-3(1)(2), Ahmedabad

In the result, the appeal filed by the Assessee is dismissed in limine

ITA 28/AHD/2018[2013-14]Status: DisposedITAT Ahmedabad21 Feb 2024AY 2013-14

Bench: Ld. Cit(A) For The Assessment Year 2012-13 An Exparte Appellate Order Was Passed. For The Assessment Year 2012-13 One Shri Sagar Vasoya Appeared Before Ld. Cit(A), However The Assessee Appeal Was Dismissed By A Detailed Speaking Order.

Section 143(3)Section 68

Pvt.Ltd as well as appellant goes on to prove beyond doubt according to A.O. that appellant has failed to prove identity, creditworthiness and genuineness of the transactions with respect to all investments made by Mis Gopalka Motor Investo Pvt.Ltd., M/s Pushpadant Commotrade Pvt Ltd Shri Pawankumar Agarwal and Smt Zameer

M/S. Tabassum Dealers Pvt. Ltd., Kolkata vs. ITO, Ward-4(1), Kolkata.

In the result, the appeal of the assessee is dismissed

ITA 914/KOL/2023[2012-13]Status: DisposedITAT Kolkata21 Feb 2024AY 2012-13

Bench: Shri Sanjay Garg & Shri Rajesh Kumar]

Section 143(3)Section 68

directions of the tribunal , the AO has granted sufficient opportunity to the assessee but the assessee could not prove the identity, creditworthiness and genuineness of the transactions. Accordingly the same was added to the income of the assessee and also confirmed by Ld. CIT(A). The appellate authority passed

Darpan Vinimay (P) Ltd., Kolkata vs. Dc/ACIT, Cir-1(1), Kolkata.

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 832/KOL/2023[2011-12]Status: DisposedITAT Kolkata21 Feb 2024AY 2011-12

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 148Section 68

provision of section 68 of the I.T. Act 1961 of Rs.35,00,000/-, as the appellant had provided with the identity, creditworthiness and genuineness of the transaction. 3 AY: 2011-12 Darpan Vinimay Private Limited 9.Because the demand so raised in the impugned assessment order of Rs.23

M/S. Brightstar Vincom Pvt.Ltd., 700007 vs. I.T.A, Ward-3(3), Kolkata

In the result, the appeal of the assessee stands allowed

ITA 176/KOL/2023[2012-13]Status: DisposedITAT Kolkata21 Feb 2024AY 2012-13

Bench: Shri Sanjay Garg & Shri Girish Agrawali.T.A. No.176/Kol/2023 Assessment Year: 2012-13 M/S Brightstar Vincom Pvt. Ltd…..…......................…...……………....Appellant 18/1, 4Th Floor, Room No.48, M.D. Road, Burrabazar, Kolkata-700007. [Pan: Aadcb2082R] Vs. Ito, Ward-3(3), Kolkata........…..........................................…..…..... Respondent Appearances By: Shri Miraj D. Shah, Ar, Appeared On Behalf Of The Appellant. Shri Abhijit Kundu, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 14, 2023 Date Of Pronouncing The Order : February 21, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 30.01.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In This Appeal Has Taken The Following Grounds Of Appeal:

Section 142(1)Section 234Section 250Section 68

mechanical manner. The assessee had duly furnished all the details relating to the identity and creditworthiness of the creditors and genuineness of the transaction. Further, the Assessing Officer, however, without examination any of the documents, did not point out any defect, discrepancy or infirmity in the evidences furnished ... and/or individual investors as the case may be for the purpose to primarily verify the identity and credit worthiness of the shareholders and genuineness of the transaction made by them in the assessee company, as well as analysis of various entries in bank statements, cash book, ledger etc. for ascertainment

Vish Realty Solutions Private Limited, Kolkata vs. I.T.O., Ward-5(3), Kolkata

In the result, appeal of the revenue is dismissed

ITA 250/KOL/2020[2012-13]Status: DisposedITAT Kolkata21 Feb 2024AY 2012-13

Bench: Shri Sanjay Garg, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. No. 250/Kol/2020 Assessment Year: 2012-13 Vish Realty Solutions Private Limited Income Tax Officer, Ward-5(3), 55, Ezra Street Vs Kolkata 2Nd Floor Kolkata - 700001 [Pan : Aadcv9938N] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri S. Jhajharia, A/R Revenue By : Shri Vineet Kumar, Addl. Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 16/01/2024 घोषणा क" तारीख /Date Of Pronouncement: 21/02/2024 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeal Is Directed At The Instance Of The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals) -10 (Hereinafter The “Ld. Cit(E)”) Dt. 02/12/2019, Passed U/S 263 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2012-13. 2. The Assessee Has Raised The Following Grounds Of Appeal:- “1. That The Learned Commissioner Of Income Tax (Appeals)-Io, Kolkata Erred In Passing An Order Dated 2Nd Of December, 2019 Under Section 143(3) Of The Income Tax Act, 1961 Dismissing The Appeal Of The Appellant Without Allowing Reasonable Opportunity Of Being Heard. 2. That The Learned Commissioner Of Income Tax (Appeals) - 10, Kolkata Erred In Confirming The Addition Of Share Application Money Ofrs. 5,86,00,000/- Made By The Assessing Officer Under Section 68 Of The Income Tax Act, 1961 On Irrelevant Considerations & Arbitrary Grounds.

For Appellant: Shri S. Jhajharia, A/RFor Respondent: Shri Vineet Kumar, Addl. CIT, D/R
Section 143(2)Section 143(3)Section 14ASection 263Section 68

assessee was asked to furnish various details and documents in order to explain identity and creditworthiness of the share subscribers and genuineness of the transactions. Necessary details were filed by the assessee. However, personal appearance of the directions/share subscribers was not complied. Solely for this reason, the ld. Assessing Officer ... though accepted the fact that the assessee has filed various details to prove the identity, creditworthiness of the share applicants and genuineness of the transactions but without finding any defect in such details, referred to plethora of judgment wherein, the addition u/s 68 of the Act were confirmed when

Radhakrishna Akshar Vikas Nyas, Vidisha vs. The ACIT 3 (1), Bhopal

In the result, appeal of the assessee is partly allowed

ITA 398/IND/2022[2011-12]Status: DisposedITAT Indore21 Feb 2024AY 2011-12

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniradhakrishna Akshar Vikas Acit 3(1) Nyas Bhopal Vs. Braj Colony Sironj Vidisha (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaatr 8725M Assessee By S/Shri Sumit Nema, Sr. Adv. & Gagan Tiwari Adv. Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 29.01.2024 Date Of Pronouncement 21.02.2024

Section 11Section 115BSection 68

this issue that the assessee has failed to satisfy the conditions of proving identity and creditworthiness of the loan creditors as well as genuineness of the transactions. He has relied upon the orders of the authorities below. 12. We have considered rival submission as well as relevant material on record ... well as details and evidences to be produced by the assessee to satisfy the identity and creditworthiness of the creditors as well as genuineness of the transactions. Needless to say the assessee be given an appropriate opportunity of hearing before passing fresh order 13. In the result, appeal

ITO-41(3)(3), Mumbai vs. Ramanlal Agarwal (HUF), Mumbai

ITA 1492/MUM/2023[2015-16]Status: DisposedITAT Mumbai21 Feb 2024AY 2015-16

Bench: Shri Br Baskaran & Shri Pavan Kumar Gadale

For Appellant: Shri.P.D.Chougule.Sr.DR
Section 133(6)Section 68

credited in the books of accounts of the assessee, there is primary onus on him to establish the identity of the creditor, the genuineness of the transaction and the creditworthiness of the creditors. The onus is expected to be discharged by the assessee in a reasonable manner by leading prima

M/S. Dahisar Traders Pvt. Ltd., Kolkata vs. ITO-7(1), Kolkata.

In the result, ITA No. 1069/KOL/2023 is allowed for statistical purposes

ITA 1069/KOL/2023[2011-12]Status: DisposedITAT Kolkata20 Feb 2024AY 2011-12

Bench: Sri Rajesh Kumar & Sri Anikesh Banerjee

Section 133(6)Section 143(1)Section 143(3)Section 147Section 148Section 14ASection 250Section 68

compliance of the notice u/s 133(6) of the Act. Even no such evidence was submitted before the AO to prove the genuineness of the transactions. In case of legal issue, it is clearly evident that the issue is freshly agitated before the ITAT. Even before the AO the issue

Ram Dhan Yadav, Chomu Jaipur vs. Income Tax Officer, ITO 7(3), Jaipur

In the result, both the appeals of the assessee are allowed

ITA 369/JPR/2023[2008-09]Status: DisposedITAT Jaipur20 Feb 2024AY 2008-09

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

For Appellant: Shri Rajesh Soni (C.A.)For Respondent: Shri Anoop Singh (Addl.CIT)
Section 143(3)Section 144Section 147Section 148Section 69B

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR Mk0 ,l- lhrky{eh