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

68 r.w.s 263: 5.1 In the case of CIT v. Vijay Kumar Koganti [2020] 120 taxmann.com 430 (Mad) where it was held that: "Section

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)

263 is quashed. 8.3 In [2016] 76 taxmann.com 226 (SC) CIT v. Reliance Communication Ltd (DPB 17 ) Held: IT : SLP dismissed against High Court's ruling that where assessee raised funds by way of FCCBs and Assessing Officer made detailed enquiries about genuineness and creditworthiness of actual subscribers to such FCCBs in terms of section 68

CASTAMET WORKS PRIVATE LIMITED,KHARWA vs. PRINCIPLE COMMISSIONER OF INCOME TAX, UDAIPUR

Section 36(1)(va) of the Act 4. Under the facts and the circumstances of the case and in law, PCIT Udaipur has grossly erred in passing order u/s 263 of the Act in respect of issues for which reasonable and plausible view was taken by Ld. AO considering judicial precedents and sufficient material available on record. 5. Under

SHRI KALYAN BUILDMART PVT. LTD,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-2, JAIPUR, JAIPUR

Bench: The Date Of Hearing.”

68. [Russian Technology Center (P.) Ltd. 2013 Taxmann.com 400 (Delhi-Trib)] 2.8. Mere inadequacy of an enquiry or insufficiency of material on record can be a ground to invoke powers under Section 263

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

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

263 order.\nThereafter, in the Impugned Order, the Ld. CIT also directed the AO to\napply special tax rate as under:\n“(c) The tax shall have to be charged as per Section 115BBE of the Act\nfor the addition already made u/s 68

MAHESH KUMAR GUPTA,JAIPUR vs. ACIT ,CIRCLE-4, JAIPUR

In the result, appeal of the assessee is allowed

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

68 of the Act has held that the opinion of the assessing officer for not accepting the explanation offered by the assessees as not satisfactory is required to be based on proper appreciation of material and other attending circumstances available on record. The court further held that the opinion of the assessing officer is required to be formed objectively with

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

68-69) and thereafter passing impugned\norder u/s 148A(d) (PB 79-80) and also impugned notice u/s 148 both dt.30.03.2022\nwhereas, the correct and legally valid jurisdiction remained with the international charge\nCircle (INTL. TAX), Jaipur. Accordingly, objections were raised letters dt.27.04.2023 (PB\n3-12) and again vide another letter dt.23.07.2023 (PB 71-72). The same was disposed

ASSOCIATED SOAPSTONE DISTRIBUTING CO PRIVATE LIMITED,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX -2, JAIPUR, JAIPUR

263 and may not be treated as\nerroneous and prejudicial to the interest of the revenue.\n4. In response, the assessee filed replies on various dates i.e\n22.02.2023 & 28.03.2023 the gist of the reply is as under:\n(i) In regard para no.3.1 of show cause notice dated 15.02.2023 in\nrespect of disallowance u/s 14A the assessee contented that

SHRI BABU LAL DATA,ALWAR vs. DCIT, CENTRAL CIRCLE, ALWAR

In the result, appeal of the revenue is dismissed

68,00,000/-without appreciating the fact that the assessee has not maintained any books of accounts and also failed to provide name, PAN, address of the persons with whom the loans were said to be taken." 4. "On the facts and circumstances of the case and in law the Ld.CIT(A) has erred in deleting the addition made

ACIT, CENTRAL CIRCLE, ALWAR vs. SHRI BABU LAL DATA, 2015-16

In the result, appeal of the revenue is dismissed

68,00,000/-without appreciating the fact that the assessee has not maintained any books of accounts and also failed to provide name, PAN, address of the persons with whom the loans were said to be taken." 4. "On the facts and circumstances of the case and in law the Ld.CIT(A) has erred in deleting the addition made

ACIT, CENTRAL CIRCLE, ALWAR vs. SHRI BABU LAL DATA, 2015-16

In the result, appeal of the revenue is dismissed

68,00,000/-without appreciating the fact that the assessee has not maintained any books of accounts and also failed to provide name, PAN, address of the persons with whom the loans were said to be taken." 4. "On the facts and circumstances of the case and in law the Ld.CIT(A) has erred in deleting the addition made

SHRI BABU LAL DATA,ALWAR vs. DCIT, CENTRAL CIRCLE, ALWAR

In the result, appeal of the revenue is dismissed

68,00,000/-without appreciating the fact that the assessee has not maintained any books of accounts and also failed to provide name, PAN, address of the persons with whom the loans were said to be taken." 4. "On the facts and circumstances of the case and in law the Ld.CIT(A) has erred in deleting the addition made

MUJMMEEL ,KOTA vs. ACIT-CENTRAL CIRCLE , KOTA

In the result, appeal of the assessee is allowed

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

263, alleging that the ld. AO failed to tax Rs. 1,44,35,000/- as unexplained investment under section 69. The ld. PCIT further proposed invoking Section 115BBE to levy a higher tax rate on the alleged unexplained income. 8. That the ld. PCIT’s assertion was that the AO did not adequately verify the ownership and source

HARIRAM HOSPITAL,ALWAR vs. PCIT, ALWAR

In the result, the appeal of the assessee is allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं./ITA No. 1535/JPR/2024 निर्धारणवर्ष / Assessment Year: 2019-20 Hariram Hospital Bye Pass Road Hariram Hospital Bhiwadi, Alwar – 310 019 (Raj) बनाम Vs. The Pr.CIT (Central) Jaipur प्रत्यर्थी / Respondent स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: AAFFH 5746 M अपीलार्थी / Appellant निर्धारिती की ओरसे / Assesseeby : Shri Himanshu Goyal, CA राजस्व की ओरसे /Revenue by: Mrs. Alka Gautam, CIT-DR सुनवाई की तारीख / Da

263 and filed a detailed reply, explaining that the loans were received from close family members, were interest-free in nature and were supported by confirmations, PANs, ITRs and bank statements of the lenders thereby fully discharging the initial burden of proof laid down under Section 68

CHAMBAL FERTILISERS AND CHEMICALS LIMITED,KOTA GADEPAN vs. PRINCIPAL COMMISSIONER OF INCOME TAX, SAVINA-UDAIPUR

68-69\nd. DTAA\nGermany*\ne. TRC\nAdditional*\n71 of PCIT Order)\n(iii) Payment to KFW\nGermany Rs. 28.73\nLakh- By Article 11 of\nDTAA (ref. at page no.\n66 of PB¹)\n(iv) rest amount\nrepresent,\naccounting\nentries on account of\nforeign\nexchange\nfluctuation due to\nfinancial reporting and\nconversion.\nc. Clause (a)/(f) of Section\n194A

LAXMI NARAYAN SAINI,SIKANDRA vs. PCIT(CENTRAL), JAIPUR

section 263 of the Act.\nLd. AO has taken a plausible view of the surrender made by the\nassessee and further addition was not made under any of the specific\nprovisions of the Act u/s 68

ARUN PALAWAT,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, (CENTRAL),, JAIPUR

The appeal of the assessee is allowed

Bench: DR. MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

263 of the Act. The Hon’ble Supreme Court in the case of PCIT-2 vs. Shree Gayatri Associates (2019) 106 Taxmann.com 31 (SC) dated 01.03.2019 held that “Where Commissioner passed a revisional order making addition to assessee's income under section 69A in respect of on- M/s Zari Silk (India) Pvt. Ltd. & Arun Palawat, Jaipur. money receipts, however

ZARI SILK (INDIA) PRIVATE LIMITED,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), JAIPUR , JAIPUR

The appeal of the assessee is allowed

Bench: DR. MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

263 of the Act. The Hon’ble Supreme Court in the case of PCIT-2 vs. Shree Gayatri Associates (2019) 106 Taxmann.com 31 (SC) dated 01.03.2019 held that “Where Commissioner passed a revisional order making addition to assessee's income under section 69A in respect of on- M/s Zari Silk (India) Pvt. Ltd. & Arun Palawat, Jaipur. money receipts, however