AHLUWALIA ERECTORS & FABRICATORS PRIVATE LIMITED, KOTA,KOTA vs. DCIT/ACIT CIR-2, KOTA

In the result the appeal of\nthe assessee in ITA no 199/JP/2025 is allowed for statistical purposes

2 & 4 which are related to the one issue of disallowance u/s.\n43B of the Act.\nRecord reveals that the Id. AO CPC has disallowed the GST at Rs.\n1,30,43,384/- and Rs.64,83,823/- being the amount of service tax.\nSo far as regards the amount disallowable u/s.43B of the Act in the\nyear under consideration

AHLUWALIA ERECTORS & FABRICATORS PRIVATE LIMITED,KOTA vs. DCIT/ACIT CIR-2, KOTA

In the result the appeal of\nthe assessee in ITA no 199/JP/2025 is allowed for statistical purposes

2 & 4 which are related to the one issue of disallowance u/s.\n43B of the Act.\nRecord reveals that the Id. AO CPC has disallowed the GST at Rs.\n1,30,43,384/- and Rs.64,83,823/- being the amount of service tax.\nSo far as regards the amount disallowable u/s.43B of the Act in the\nyear under consideration

AHLUWALIA ERECTORS & FABRICATORS PRIVATE LIMITED, KOTA,KOTA vs. DCIT/ACIT CIR-2, KOTA, KOTA

In the result the appeal of\nthe assessee in ITA no 199/JP/2025 is allowed for statistical purposes

2 & 4 which are related to the one issue of disallowance u/s.\n43B of the Act.\nRecord reveals that the Id. AO CPC has disallowed the GST at Rs.\n1,30,43,384/- and Rs.64,83,823/- being the amount of service tax.\nSo far as regards the amount disallowable u/s.43B of the Act in the\nyear under consideration

M/S. AJMER ZILA DUGDH UTPADAK SAHAKARI SANGH LTD.,AJMER vs. PR.CIT, AJMER

In the result, the appeal of the assessee is partly allowed

disallow the same during the assessment proceedings which makes the assessment order erroneous in so far as it is prejudicial to the interest of the revenue. 3. Thus, the order passed by the A.O. on 07.12.2017 is considered erroneous in so far as it is prejudicial to the interest of the Revenue and a show-cause u/s 263 is hereby

CAREER POINT LIMITED,KOTA, RAJASTHAN vs. PRINCIPAL COMMISSIONER OF INCOME TAX, UDAIPUR, RAJASTHAN

In the result, the appeal of the assessee is allowed

Bench: HON’BLE SHRI SANDEEP GOSAIN, JM & HON’BLE SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

section 14A by inserting a non-obstante clause and Explanation will takeeffectfrom1-4-2022 and cannot be presumed to have retrospective effects. 2.11 Entire investments shall not be considered to make disallowances. Ld PCIT computed total disallowance which required to be made u/s 14A at Rs. 2,53,26,820/-. Whereas only those investments which shall earn exempt income shall

SHIVA CORPORATION (INDIA) LIMITED,JAIPUR vs. DY. CIT, CC-3, JAIPUR

In the result, appeal of the assessee stands allowed

71 TTJ 662\nIn view of the above, this contention of the appellant is accepted and\nthe data available in public domain is admitted subject to verification\nand examination.\nOn merits the appellant has referred to definition of \"agricultural land\"\nas per clause (i) of section 2(14) of the Income Tax Act and submitted\nthat as per section 2

WORSHIP INFRAPROJECTS PRIVATE LIMITED,JAIPUR vs. DCIT, CEIRCLE-2, JAIPUR

In the result of the appeal of the assessee is allowed

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

71,174 1,62,42,947 Difference in 3.22% 1.64% percentage Since the difference in between the Arm's length price and actual price is within the limit prescribed in the second proviso to section 92C(2) of Income Tax Act, the difference should be ignored. 4.2 No disallowance

DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR vs. M/S WORSHIP INFRAPROJECTS PVT LTD(PREVIOUSLY KNOWN AS OM METALS SPML INFRAPROJECTS PVT LTD), JAIPUR

In the result of the appeal of the assessee is allowed

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

71,174 1,62,42,947 Difference in 3.22% 1.64% percentage Since the difference in between the Arm's length price and actual price is within the limit prescribed in the second proviso to section 92C(2) of Income Tax Act, the difference should be ignored. 4.2 No disallowance

SHRI MADHOPUR KRAYA VIKRAYA SAHKARI SAMITI LIMITED,SHRIMADHOPUR vs. INCOME TAX OFFICER, NEEM KA THANA, NEEM KA THANA

In the result, all the three appeals of the assessee in ITA No

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

2. On the facts and circumstances of the case and in law also ld. A.O. grossly erred in disallowing deduction of Rs. 4,71,247/- under section

GIRNAR SOFTWARE PRIVATE LIMITED,6TH FLOOR, JAIPUR TEXTILE MARKET, B-2, NEAR MODEL TOWN, MALVIYA NAGAR, JAIPUR vs. PCIT – 2, JAIPUR, NEW CENTRAL REVENUE BUILDING

In the result, the appeal of the assessee is allowed

Bench: HON’BLE SHRI SANDEEP GOSAIN, JM & HON’BLE SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

disallowance under section 14A of the Act. 3. Necessary cost be awarded to the assessee. Ground No. 1 & 2 raised by the assessee are inter-connected and inter- related against the order passed under section 263 of the IT Act, 1961 and thereby directing the AO to make addition of Rs. 66,30,268/- under section

RADHAKISHAN BENIWAL,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1, JAIPUR, JAIPUR

In the result, the appeal filed by the assessee in ITA no

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

section 260A ibid, would not again de novo hold yet another factual inquiry with a view to find out as to whether the explanation offered by the assessee and which found acceptance to the Tribunal is good or bad, or whether it was rightly accepted, or not. It is only when the factual finding recorded had been entirely de hors

RADHAKISHNA BENIWAL,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1, JAIPUR, JAIPUR

In the result, the appeal filed by the assessee in ITA no

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

section 260A ibid, would not again de novo hold yet another factual inquiry with a view to find out as to whether the explanation offered by the assessee and which found acceptance to the Tribunal is good or bad, or whether it was rightly accepted, or not. It is only when the factual finding recorded had been entirely de hors

LALITA KUMARI,ANTA DISTRICT BARAN vs. COMMISSIONER OF INCOME TAX (APPEALS), NFAC, DELHI

In the result, appeal of the assessee is allowed

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

section 2(41) as per which a son of brother-in-law is not a relative. 3.) The AO further observed that the assessee had given interest @ 18% P.A. to the person covered u/s 40A(2)(b) of the Income Tax Act, 1961, which is more higher than the prevailing market rate i.e. maximum 12% 6 Lalita Kumari

M/S RAJASTHAN STATE INDUSTRIAL DEVELOPMENT AND INVESTMENT CORPORATION LTD.,JAIPUR vs. DCIT, CIRCLE-6, JAIPUR, JAIPUR

In the result, both the appeals of the assessee are allowed as indicated hereinabove

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

2,00,00,000 Nil Nil Development of Stones (CDOS) Prior period expenses 36,73,140 Nil Nil CSR expenses 6,41,42,000 6,41,42,000 1,41,42,000 Deduction u/s 80IA 15,33,95,189 Nil Nil Disallowance u/s 14A 71,75,575 71,75,575 71,75,575 Service Tax Receivable

GILLETTE INDIA LIMITED,SPA-65A, INDUSTRIAL AREA, BHIWADI, DISTRICT- ALWAR vs. PCIT, JAIPUR-1, JAIPUR

In the result, the appeal of the assessee is partly allowed

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

section 2(24)(x) of the Act. However, the assessee has itself disallowed only Rs 42,14,588/- in its computation. Thus the remaining amount Rs 2,59,71

WHOLE SALE CLOTH MERCHANT ASSOCIATION ,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE KOTA , KOTA

In the result, the appeals of the assessee in ITA no

section 11 to 13 of the\nIncome-tax Act.\n4. That on the facts and circumstances of the case ld. Lower Authorities\ngrossly erred in making addition of Rs. 5,83,469/- to the income of the\nassessee appellant trust while disallowing the benefit of exemption under\nsection 11(2) and 11(1)(a) of the Act as claimed

SUNIL CHABLANI,AJMER, RAJASTHAN vs. CIRCLE (INTL TAX), JAIPUR, JAIPUR, RAJASTHAN

disallowed due to\nreason that assessee has failed to submit any documentary evidence in support\nof his claim. Therefore, the whole consideration of Rs. 69,90,000/- is considered\nas Long Term Capital Gain in the hands of the assessee. Penalty proceedings\nu/s 270A of the Act is initiated on this issue for underreporting of income.\nFurther, the assessee

ASSISTANT COMMISSIONER OF INCOME TAX,EXEMPTIONS,CIRCLE,JAIPUR, JAIPUR vs. GLOBAL INSTITUTE OF TECHNOLOGY SOCIETY, JAIPUR RAJASTHAN

In the results the appeal of the revenue stands dismissed

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

disallowing exemption u/s 11 of Income Tax Act on total taxable income of Rs. 2,77,71,470/- as AOP status. Aggrieved by the order of the learned AO the assessee preferred appeal before your honour. With this background the individual grounds of appeal of the revenue are discussed as under: - Ground No. 1:- Under the facts and circumstances

WHOLE SALE CLOTH MERCHANT ASSOCIATION ,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE KOTA , KOTA

section 11 to 13 of the\nIncome-tax Act.\n4. That on the facts and circumstances of the case ld. Lower Authorities\ngrossly erred in making addition of Rs.5,83,469/- to the income of the\nassessee appellant trust while disallowing the benefit of exemption under\nSection 11(2) and 11(1)(a) of the Act as claimed