DCIT, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. KAMLAPRABHA L/H OF LATE SHRI GOPAL LAL JI GOSWAMI, KOTA

In the result, the appeal of the revenue is dismissed and the Cross objection of the assessee is disposed off in terms of the observation made herein above

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

penalty imposable under Chapter XXI is to be initiated and completed within two years.  Action of the CIT u/s 263 of the Act is to be taken within two years from the end of the financial year in which the order sought to be revised was passed. 1.3Even where no limit is prescribed for taking an action under

SUNIL KUMAR AGARWAL,JAIPUR vs. ACIT, CEN. CIR-2, JAIPUR

In the result the appeal of the assessee in ITA no

Section 68 Case pertains to Asst. Year 1966-67 Decision in favour of: Assessee Cash credits—Addition under s. 68—ITO can make addition under s. 68 as income from undisclosed sources, simultaneously with addition to trading results— However, assessee can claim the addition under s. 68 as covered by intangible additions to trading results—In the present case

SUNIL KUMAR AGARWAL,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, \nvk;dj vihy la-@ITA Nos.513 & 519 to 521/JP/2025\nfu/k Zkj.k o\"kZ@Assessment Years : 2016-17 & 2018-19 to 2020-21\n\nSunil Kumar Agarwal\n395, Narnoli Mansion, Outside\nSanganeri Gate, Jaipur\ncuke\nVs.\nACIT,\nCentral Circle-2,\nJaipur\nLFkk;h y s[kk l a-@thvkb Zvkj la-@PAN/GIR No.: ABRPA9601M\nvihykFkhZ@Appellant i zR;Fkh Z@Respondent\n\nvk;dj vihy la-@ITSS No. 03/JP/2025\nfu/k Zkj.k o\"kZ@Assessment Year : 2015-16\

271 as under:-\n\"In estimating any escaped turnover, it is inevitable that there is some guesswork.\nThe assessing authority while making the best judgment assessment, no doubt,\nshould arrive at his conclusion without any bias and on a rational basis. That\nauthority should not be vindictive or capricious. If the estimate made by the\n\n22\nITA Nos.513