DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA, KOTA vs. RISHIRAJ SINGH, JHALAWAR

In the result, the appeal of the revenue is dismissed

section 68 are applicable and it is for the\nassessee to prove satisfactorily the nature and source of the monies. ....”\n(Emphasis supplied)\nThus, as is evident from the record that the Id. AO has neither recorded any\nfinding that the liability of Rs.48,38,433

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S BARAN ROLLER FLOUR MILLS PVT. LTD., KOTA

section 68. [Para 16] In the instance case before me , the AO has not followed the due procedure of law u/s 68 of the Act. Therefore, requiring the Assessee to produce the directors of the lender company was not legally tenable in view of the judgment of Gujrat High Court (supra). 5.12 It is noted that no clinching evidences

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S BARAN ROLLER FLOUR MILLS PVT. LTD., KOTA

section 68. [Para 16] In the instance case before me , the AO has not followed the due procedure of law u/s 68 of the Act. Therefore, requiring the Assessee to produce the directors of the lender company was not legally tenable in view of the judgment of Gujrat High Court (supra). 5.12 It is noted that no clinching evidences

SHRI AMBICA GARMENTS, JODHPUR,JODHPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

section 68 of the Act are not satisfied. However the appellant / Id. AR has submitted ledger account of Kotak Bank loan and made arguments regarding Kotak Bank Loan and contended that bank loan cannot be treated as unexplained and that the substantial entries are matching in the ledger account in Jai Shree Ram and Ambika Garments. Accordingly the addition

SHRI AMBICA GARMENTS, JODHPUR,JODHPUR vs. ACIT, CENTAL CIRCLE-3, JAIPUR, JODHPUR

In the result, all appeals of the assessee are disposed off in terms of

section 68 of the Act are not satisfied. However the appellant / Id. AR has submitted ledger account of Kotak Bank loan and made arguments regarding Kotak Bank Loan and contended that bank loan cannot be treated as unexplained and that the substantial entries are matching in the ledger account in Jai Shree Ram and Ambika Garments. Accordingly the addition

SANJAY KUMAR KARNANI,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

section 68 of the Act are not satisfied. However the appellant / Id. AR has submitted ledger account of Kotak Bank loan and made arguments regarding Kotak Bank Loan and contended that bank loan cannot be treated as unexplained and that the substantial entries are matching in the ledger account in Jai Shree Ram and Ambika Garments. Accordingly the addition

SANJAY KUMAR KARNANI,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

Bench: AO on 12-04-2021 18. Reply filed before AO on 15-07-2021 19. Additional Written Submissions filed before CIT(A) for AY 2014-15 on 11-11-2024 20. Written Submissions filed before CIT(A) for AY 2014-15 21. Written Submissions filed before CIT(A) for AY 2015-16 on 10-10-2024 22. Written Submissions filed before CIT(A) for AY 2016-17 on 10-10-2024 23. Written Submissions filed before CIT(A) for AY 2017-18 on 15-10-2024 24. Written Submissions filed before CIT(A) for AY 2018-19 on 15-10-2024 25.

section 68 of the Act are not satisfied. However the appellant / Id. AR has submitted ledger account of Kotak Bank loan and made arguments regarding Kotak Bank Loan and contended that bank loan cannot be treated as unexplained and that the substantial entries are matching in the ledger account in Jai Shree Ram and Ambika Garments. Accordingly the addition

SHRI AMBICA GARMENTS, JODHPUR,JODHPUR vs. ACIT, CENTAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

section 68 of the Act are not satisfied. However the appellant / Id. AR has submitted ledger account of Kotak Bank loan and made arguments regarding Kotak Bank Loan and contended that bank loan cannot be treated as unexplained and that the substantial entries are matching in the ledger account in Jai Shree Ram and Ambika Garments. Accordingly the addition

ASHOK NARIYANI,JAIPUR vs. ACIT, CIRCLE-5, JAIPUR

In the result, the appeal of the assessee is allowed

section 133A of the Act, without any\nindependent corroborative evidence or material substantiating such addition, is legally\nunsustainable and devoid of merit. The settled position of law, consistently upheld by\nvarious judicial forums including the Hon'ble Supreme Court, High Courts, and\nIncome Tax Appellate Tribunals, categorically holds that statements obtained during\nsurvey operations lack evidentiary value and cannot

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S. AGRASEN AGRO INDUSTRIES PRIVATE LIMITED,, KOTA

section 143(3) in respect of the share applicant companies, details of which are as under :- Assessment u/s 143(3) : Name of Company Assessment Income Assessment year Assessed Order u/s 143(3) at PB pg M/s Teac 2005-06 13,980 451-453 Consultants Pvt. Ltd M/s Teac 2006-07 45,395 454-455 Consultants Pvt. Ltd M/s Teac

M/S. AGRASEN AGRO INDUSTRIES PRIVATE LIMITED,,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

section 143(3) in respect of the share applicant companies, details of which are as under :- Assessment u/s 143(3) : Name of Company Assessment Income Assessment year Assessed Order u/s 143(3) at PB pg M/s Teac 2005-06 13,980 451-453 Consultants Pvt. Ltd M/s Teac 2006-07 45,395 454-455 Consultants Pvt. Ltd M/s Teac

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S. AGRASEN AGRO INDUSTRIES PRIVATE LIMITED,, KOTA

section 143(3) in respect of the share applicant companies, details of which are as under :- Assessment u/s 143(3) : Name of Company Assessment Income Assessment year Assessed Order u/s 143(3) at PB pg M/s Teac 2005-06 13,980 451-453 Consultants Pvt. Ltd M/s Teac 2006-07 45,395 454-455 Consultants Pvt. Ltd M/s Teac

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR vs. M/S KSHEER SAGAR DEVELOPERS PVT. LTD., JAIPUR

In the result, all these five appeals of the revenue are dismissed

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita Nos. 1158 To 1162/Jp/2019 Assessment Years: 2011-12 To 2015-16 Deputy Commissioner Of Cuke M/S Ksheer Sagar Developers Vs. Income Tax, Pvt. Ltd., Central Circle-2, Hotel Royal Orchid, Opp.- Bsnl Jaipur. Office, Near Durgapura Flyover, Tonk Road, Jaipur-302018. Pan No.: Aacck 3154 G Vihykfkhz@Appellant Izr;Fkhz@Respondent Jktlo Dh Vksj Ls@ Revenue By : Shri Rajendra Singh (Cit-Dr) Fu/Kzkfjrh Dh Vksj Ls@ Assessee By: Shri S.R. Sharma, (Ca) & Shri Rajnikant Bhatra (Ca) Lquokbz Dh Rkjh[K@ Date Of Hearing : 06/07/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 31/08/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. These Are The Appeals Filed By The Revenue Against The Two Separate Orders Of The Ld. Cit(A)-4, Jaipur All Dated 31/07/2019 For The A.Y. 2011- 12 To 2015-16 Respectively.

433 too the head note may be referred too. Same reads as under: Section 35AD of the Income-tax Act, 1961 - Specified business, deduction of expenditure in respect of (Hotel) - Assessment year 2012-13 - Whether for avoiding benefit of a three star hotel under section 35AD, what is not relevant is date of certification for classification

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR vs. M/S KSHEER SAGAR DEVELOPERS PVT. LTD., JAIPUR

In the result, all these five appeals of the revenue are dismissed

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita Nos. 1158 To 1162/Jp/2019 Assessment Years: 2011-12 To 2015-16 Deputy Commissioner Of Cuke M/S Ksheer Sagar Developers Vs. Income Tax, Pvt. Ltd., Central Circle-2, Hotel Royal Orchid, Opp.- Bsnl Jaipur. Office, Near Durgapura Flyover, Tonk Road, Jaipur-302018. Pan No.: Aacck 3154 G Vihykfkhz@Appellant Izr;Fkhz@Respondent Jktlo Dh Vksj Ls@ Revenue By : Shri Rajendra Singh (Cit-Dr) Fu/Kzkfjrh Dh Vksj Ls@ Assessee By: Shri S.R. Sharma, (Ca) & Shri Rajnikant Bhatra (Ca) Lquokbz Dh Rkjh[K@ Date Of Hearing : 06/07/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 31/08/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. These Are The Appeals Filed By The Revenue Against The Two Separate Orders Of The Ld. Cit(A)-4, Jaipur All Dated 31/07/2019 For The A.Y. 2011- 12 To 2015-16 Respectively.

433 too the head note may be referred too. Same reads as under: Section 35AD of the Income-tax Act, 1961 - Specified business, deduction of expenditure in respect of (Hotel) - Assessment year 2012-13 - Whether for avoiding benefit of a three star hotel under section 35AD, what is not relevant is date of certification for classification

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR vs. M/S KSHEER SAGAR DEVELOPERS PVT. LTD., JAIPUR

In the result, all these five appeals of the revenue are dismissed

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita Nos. 1158 To 1162/Jp/2019 Assessment Years: 2011-12 To 2015-16 Deputy Commissioner Of Cuke M/S Ksheer Sagar Developers Vs. Income Tax, Pvt. Ltd., Central Circle-2, Hotel Royal Orchid, Opp.- Bsnl Jaipur. Office, Near Durgapura Flyover, Tonk Road, Jaipur-302018. Pan No.: Aacck 3154 G Vihykfkhz@Appellant Izr;Fkhz@Respondent Jktlo Dh Vksj Ls@ Revenue By : Shri Rajendra Singh (Cit-Dr) Fu/Kzkfjrh Dh Vksj Ls@ Assessee By: Shri S.R. Sharma, (Ca) & Shri Rajnikant Bhatra (Ca) Lquokbz Dh Rkjh[K@ Date Of Hearing : 06/07/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 31/08/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. These Are The Appeals Filed By The Revenue Against The Two Separate Orders Of The Ld. Cit(A)-4, Jaipur All Dated 31/07/2019 For The A.Y. 2011- 12 To 2015-16 Respectively.

433 too the head note may be referred too. Same reads as under: Section 35AD of the Income-tax Act, 1961 - Specified business, deduction of expenditure in respect of (Hotel) - Assessment year 2012-13 - Whether for avoiding benefit of a three star hotel under section 35AD, what is not relevant is date of certification for classification

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR vs. M/S KSHEER SAGAR DEVELOPERS PVT. LTD., JAIPUR

In the result, all these five appeals of the revenue are dismissed

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita Nos. 1158 To 1162/Jp/2019 Assessment Years: 2011-12 To 2015-16 Deputy Commissioner Of Cuke M/S Ksheer Sagar Developers Vs. Income Tax, Pvt. Ltd., Central Circle-2, Hotel Royal Orchid, Opp.- Bsnl Jaipur. Office, Near Durgapura Flyover, Tonk Road, Jaipur-302018. Pan No.: Aacck 3154 G Vihykfkhz@Appellant Izr;Fkhz@Respondent Jktlo Dh Vksj Ls@ Revenue By : Shri Rajendra Singh (Cit-Dr) Fu/Kzkfjrh Dh Vksj Ls@ Assessee By: Shri S.R. Sharma, (Ca) & Shri Rajnikant Bhatra (Ca) Lquokbz Dh Rkjh[K@ Date Of Hearing : 06/07/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 31/08/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. These Are The Appeals Filed By The Revenue Against The Two Separate Orders Of The Ld. Cit(A)-4, Jaipur All Dated 31/07/2019 For The A.Y. 2011- 12 To 2015-16 Respectively.

433 too the head note may be referred too. Same reads as under: Section 35AD of the Income-tax Act, 1961 - Specified business, deduction of expenditure in respect of (Hotel) - Assessment year 2012-13 - Whether for avoiding benefit of a three star hotel under section 35AD, what is not relevant is date of certification for classification

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR vs. M/S KSHEER SAGAR DEVELOPERS PVT. LTD., JAIPUR

In the result, all these five appeals of the revenue are dismissed

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita Nos. 1158 To 1162/Jp/2019 Assessment Years: 2011-12 To 2015-16 Deputy Commissioner Of Cuke M/S Ksheer Sagar Developers Vs. Income Tax, Pvt. Ltd., Central Circle-2, Hotel Royal Orchid, Opp.- Bsnl Jaipur. Office, Near Durgapura Flyover, Tonk Road, Jaipur-302018. Pan No.: Aacck 3154 G Vihykfkhz@Appellant Izr;Fkhz@Respondent Jktlo Dh Vksj Ls@ Revenue By : Shri Rajendra Singh (Cit-Dr) Fu/Kzkfjrh Dh Vksj Ls@ Assessee By: Shri S.R. Sharma, (Ca) & Shri Rajnikant Bhatra (Ca) Lquokbz Dh Rkjh[K@ Date Of Hearing : 06/07/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 31/08/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. These Are The Appeals Filed By The Revenue Against The Two Separate Orders Of The Ld. Cit(A)-4, Jaipur All Dated 31/07/2019 For The A.Y. 2011- 12 To 2015-16 Respectively.

433 too the head note may be referred too. Same reads as under: Section 35AD of the Income-tax Act, 1961 - Specified business, deduction of expenditure in respect of (Hotel) - Assessment year 2012-13 - Whether for avoiding benefit of a three star hotel under section 35AD, what is not relevant is date of certification for classification

SHREE SIDDHI VINAYAK INDUCTIONS PVT. LTD.,JAIPUR vs. DCIT, CENTRAL CIRCLE-3, JAIPUR

In the result ITA NO. 01/JPR/2021 for A

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