SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result of the appeal of the assessee are disposed off as under

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आंकड़ुठरधारी आइटीएए सं.र@ITA Nos.493, 495 to 498, 500/JP/2025 निर्धारण वर्ष@Assessment Years : 2014-15 to 2016-17, 2018-19 to 2020-21 Mahendra Kumar Goyal चुके Vs. ACIT/DCIT Ward No. 2, Shahpura Road Neem Ka Thana, Sikar Central Circle-03, Jaipur लेखा संख्याल्लेय सं.जीआइआर सं.पान@PAN/GIR No.: ACFPG0306G अपीलार्थी@Appellant प्रत्यार्थी@Respondent निर्धारीती की आर से@ Assessee by : Shri P. C. Parwal, CA राजस्व की आर से@ R

reassessment for the assessment years 1968-69 to 1971-72 and for the year 1982-83 on the ground that the proposed reassessment for those assessment years had already become barred by time under section 149 of the Act, for which in the relevant periods maximum period of four years or seven years limitation was prescribed depending upon the quantum

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result of the appeal of the assessee are disposed off as under

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

reassessment for the assessment years 1968-69 to 1971-72 and for the year 1982-83 on the ground that the proposed reassessment for those assessment years had already become barred by time under section 149 of the Act, for which in the relevant periods maximum period of four years or seven years limitation was prescribed depending upon the quantum

JUHI BHANDARI, JAIPUR,JAIPUR vs. DCIT CIRCLE (INTL TAX), JAIPUR, JAIPUR

In the result, both appeals of the assessee are allowed

method.\n20. 9. That it is to be highlighted that even if allegation of payment of on-money is\ntaken on its face value (though not admitted), then even as per market\nparlance, the questioned transaction of payment of ‘on-money' would have\ntaken place either in A.Y. 2013-2014 (when the flat was booked and advance\nwas given

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

reassess six\npreceding years and the year of search.\n• For concluded assessments, additions can only be made based on\nincriminating material found during the search.\nCitation:\n• CIT v. Singhad Technical Education Society (2017) 397 ITR 344 (SC)\nThe AO acted same and addition was made on seized documents only, THE\nOWNER SHIP OF SEIZED DOCUMENT IS NOT DENIED