SURENDRA PAL SINGH SAHNI,KOTA vs. ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA, KOTA

In the result, the appeal of the assessee is allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

167 ITR 0498 Statement which was not tested by cross examination is not good evidence It is further submitted that the learned AO has wrongly invoked provisions of section 69A which are not applicable. The provisions section 69A are quoted in below. Provisions of section 69A are not applicable It is submitted that the learned

GEETA DEVI AGARWAL,JAIPUR vs. INCOME TAX OFFICER, ITO WD 1(4), JPR, JAIPUR

In the result, the appeal of the assessee is allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं. / ITA No. 450/JP/2025 निर्धारण वर्ष / Assessment Year : 2017-18 Badri Lal Agarwal through Legal heir Smt. Geeta Devi G-5, Shyama Residency, Plot No. 7, Purander Ji Ka Bag Moti Doongri Road, Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: ALGPA5194C अपीलार्थी / Appellant निर्धारिती की ओर से / Assessee by: Sh. S. B. Natani, CA राजस्व की ओर से / Revenue by : Sh. Gautam Singh Choudhary, JCIT सुनवाई की तारीख /

167 ITR 0498 Statement which was not tested by cross examination is not good evidence It is further submitted that the learned AO has wrongly invoked provisions of section 69A which are not applicable. The provisions section 69A are quoted in below. Provisions of section 69A are not applicable It is submitted that the learned

RSD CONTAINERS PRIVATE LIMITED,JAIPUR vs. ITO, WARD 7(1), JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

68 r.w.s. 115BBE. Reject plea for peak credit, unabsorbed depreciation, and MAT credit set-off. The ld. DR vide submission dated 14.07.2025 further submitted as under : I. Limitation Period Under Section 149(1)(b) is Fully Alive The assessee has contended that the reassessment proceedings are barred by limitation. However, this contention is devoid of merit in view

ACIT, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. CHANDRA MOHAN BADAYA, JAIPUR

In the result the four appeals filed by the assessee stands

Bench: Him In The Case Of The Assessee For All These Four Assessment Year.

section 68 of the Act and the said amount have been treated as income from the unexplained source, the applicant was entitled to take up a plea of addition of the aforesaid peak credit as the entire deposits have been treated to be income of the applicant. The contention is wholly misconceived. For adjudicating upon the plea of peak

CHANDRA MOHAN BADAYA,JAIPUR vs. DCIT, CENTRAL CIRCLE-2, JAIPUR

In the result the four appeals filed by the assessee stands

Bench: Him In The Case Of The Assessee For All These Four Assessment Year.

section 68 of the Act and the said amount have been treated as income from the unexplained source, the applicant was entitled to take up a plea of addition of the aforesaid peak credit as the entire deposits have been treated to be income of the applicant. The contention is wholly misconceived. For adjudicating upon the plea of peak

ACIT, CC-2, JAIPUR, INCOME TAX DEPARTMENT vs. CHANDRA MOHAN BADAYA, JAIPUR

In the result the four appeals filed by the assessee stands

Bench: Him In The Case Of The Assessee For All These Four Assessment Year.

section 68 of the Act and the said amount have been treated as income from the unexplained source, the applicant was entitled to take up a plea of addition of the aforesaid peak credit as the entire deposits have been treated to be income of the applicant. The contention is wholly misconceived. For adjudicating upon the plea of peak

ACIT, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. CHANDRA MOHAN BADAYA, JAIPUR

In the result the four appeals filed by the assessee stands

Bench: Him In The Case Of The Assessee For All These Four Assessment Year.

section 68 of the Act and the said amount have been treated as income from the unexplained source, the applicant was entitled to take up a plea of addition of the aforesaid peak credit as the entire deposits have been treated to be income of the applicant. The contention is wholly misconceived. For adjudicating upon the plea of peak

ACIT, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. CHANDRA MOHAN BADAYA, JAIPUR

In the result the four appeals filed by the assessee stands

Bench: Him In The Case Of The Assessee For All These Four Assessment Year.

section 68 of the Act and the said amount have been treated as income from the unexplained source, the applicant was entitled to take up a plea of addition of the aforesaid peak credit as the entire deposits have been treated to be income of the applicant. The contention is wholly misconceived. For adjudicating upon the plea of peak

RAYS POWER EXPERTS PRIVATE LIMITED,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 2, JAIPUR

In the result, the appeal of the assesee is allowed for statistical purposes as indicated hereinabove

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

section 68 of Income Tax Act even though the amount was deposited in the bank account of the assessee before 15/12/2016 Le. the date on which the amended provisions of Sec. 115BBE got accent of the President. 11. The assessee craves his right to add, amend, delete or alter any ground before or at the time of hearing

M/S RAJENDRA AND URSULA JOSHI SKILL DEVELOPEMENT PVT. LTD. JAIPUR,JAIPUR vs. PCIT-2, JAIPUR

In the result ITA NO. ITA 57/JPR/2021 is also stands dismissed

167 ITR 471 (SC) has advocated for a very liberal approach while considering a case for condonation of delay. The following observations of the Hon'ble Court are notable: "The legislature has conferred the power to condone delay by enacting section 5 of the Limitation Act 1963 in order to enable the Courts to do substantial justice to parties

M/S RAJENDRA AND URSULA HOLDINGS PVT. LTD., JAIPUR,JAIPUR vs. PCIT-1, JAIPUR

In the result ITA NO. ITA 57/JPR/2021 is also stands dismissed

167 ITR 471 (SC) has advocated for a very liberal approach while considering a case for condonation of delay. The following observations of the Hon'ble Court are notable: "The legislature has conferred the power to condone delay by enacting section 5 of the Limitation Act 1963 in order to enable the Courts to do substantial justice to parties

KAILASH CHAND MAHESHWARI,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX , JAIPUR

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

section 57 (iii) of the Act. We thus decline to interfere with the action of the Assessing Officer and the First Appellate Authority." The onus is on the appellant to show one-to-one matching and prove that the interest expenditure for the borrowed funds have been used wholly and exclusively only for the purpose of making investments which

PAPPU JAISWAL,JAIPUR vs. INCOME TAX OFFICER WARD 2(2), JAIPUR

In the result, the appeal of the assessee is allowed

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

68 of Rs. 12,31,000/-, and under section 69 of Rs. 9,60,750/- 5. That in the facts and circumstances of the case and in law the learned CIT (A) has erred in confirming the order passed by the learned AO in making additions of Rs, 2,87,250/- applying N P rate of 15% on contract

M/S. GURU KRIPA CAREER INSTITUTE PVT. LTD.,SIKAR vs. PR.CIT-3, JAIPUR

In the result, appeal of the assessee is allowed

68 to 69D read with Section 115BBE of the Income Tax Act, 1961. Accordingly, the AO has not brought to tax the surrendered income as per applicable provisions of the Act. 14.The AO has not verified the amount of Rs.45,85,897/- under the head “Staff Payable”. 15.The AO has not at all verified all the issues enumerated from

INCOME TAX OFFICER, JAIPUR vs. POOJA KEDIA, JAIPUIR

In the result, the appeal of the revenue is dismissed

Section 68 merely on basis of statement of a person who was\ncontrolling and managing these companies without providing an opportunity for\nhis cross examination to assessee was unjustified.\n"26. The Principles of Natural Justice requires that the Department which seeks to\nrely on the statement of a witness (Shri Partik R. Shah) has to allow the adverse

PRAKASH CHAND VARINDANI,JAIPUR vs. ACIT CERTAL CIRLCE-3, JAIPUR

In the result, the appeal of the assessee is allowed

68 of the Income Tax Act:\nThat the books of accounts being was maintained by the accountant of the\nAssessee in a special software which is used by the traders throughout the\nSurajpole Mandi, and since the accountant was not present on the date of\nSurvey, the Survey team did not take the electronic books in their possession\nand only

SHIV VEGPRO PRIVATE LIMITED ,KOTA vs. PCIT-UDAIPUR , UDAIPUR

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

167 ITR 471 (SC) as the assessee was\nprevented by sufficient cause.\n4. The fact as culled out from the records is that M/s Shiv\nVegpro Pvt. Ltd. is a Company engaged in the manufacturing of\nvegetable oil, DOC, High Pro-DOC etc. Assessee filed its Return of\nIncome dated 06/11/2017 with acknowledgement number\n291801621061117 declaring taxable income at Rs.9

GAYATRI DEVI,JAIPUR vs. PCIT(CENTRAL), JAIPUR

In the result, this appeal of the assessee is allowed

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

Section 263 of the Act upon the assessee which deserves to be quashed for which the ld. AR of the assessee filed the detailed written submission as under:- ‘’The impugned order passed u/s 263 is completely beyond the scope of S. 263 of the Act on various grounds, as discussed herein below. 1. Legal Position on S. 263 Judicial

INCOME TAX OFFICER, JAIPUR vs. MOTISONS JEWELLERS LTDL, JAIPUR

Section 145 of the Income-tax Act, 1961 [Corresponding to section 13 of the Indian Income-Tax Act, 1922] - Method of accounting - Rejection of accounts - On assessee's inability to supply addresses of purchasers who purchased goods on cash, ITO rejected assessee's books of account showing result in respect of cash sale transactions, and made addition