ITO, WARD-2, HANUMANGARH vs. SMT. LALITA SARAF , HANUMANGARH TOWN

In the result, the appeals of the Department are dismissed and the Cross objections of the assessees are allowed

Bench: Shri N.K. Sainithe Income Tax Officer, Vs Smt. Lalita Saraf, Ward-2, Hanumangarh C/O Mangi Lal Saraf, In Front Of Mandi Studio, Hanumangarh Town

4) of the Act. Cross objections below this monetary limit, already filed, should be pursued for dismissal as withdrawn/ not pressed. Filing of cross objections below the monetary limit may not be considered henceforth. Similarly, references to High Courts and SLPs/ appeals before Supreme Court below the monetary limit of Rs. 50 lakhs and Rs. 1 Crore respectively should

THAKUR BUILDCON (P) LTD. ,RAJSAMAND vs. ITO, WARD-1, RAJSAMAND

Appeal stands dismissed whereas the assessee’s ground stands partly allowed

Bench: Hon’Ble Shri Sandeep Gosain, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am (Hearing Through Video Conferencing Mode) आयकरअपील सं./ Ita No.345/Jodh/2019 ("नधा"रणवष" / Assessment Year: 2009-10) Thakur Buildcon (P) Ltd. Income Tax Officer-Ward-1 C/O. Rajendra Jain Advocate Rajsamand बनाम/ 106, Akshay Deep Complex, Rajasthan-313 324. Vs. 5Th B Road, Sardarpura Jodhpur, Rajasthan-342 001. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aacct-7930-M (अपीलाथ"/Appellant) (""यथ" / Respondent) : & आयकरअपील सं./ Ita No.346/Jodh/2019 ("नधा"रणवष" / Assessment Year: 2009-10) Income Tax Officer-Ward-1 Thakur Buildcon (P) Ltd. बनाम/ Rajsamand Thakurgarh N.H. 8 Rajasthan-313 324. Sevali, Rajsamand Vs. Rajasthan-313 324. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aacct-7930-M (अपीलाथ"/Appellant) (""यथ" / Respondent) :

Section 148 of the Income Tax Act, 1961. In the said assessment, the assessee was saddled with certain peak additions of Rs.216.77 Lacs on account of alleged bogus purchases and the same is the sole subject matter of cross- appeals before us since Ld. CIT(A) has granted partial relief to the assessee in the impugned order. 2. The effective

RAJ KUMAR GOLECHA,PALI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JODHPUR, AAYKAR BHAWAN, JODHPUR

Appeal of the assessee is allowed

purchased and sale equity shares of scripts Sun Asian. No incriminating documents found during the course of search proceedings. 4. That on the facts and circumstances of the case, both the AO and ld. CIT (A) erred have not brought on record any concrete material on record before holding the LTCG claimed

ACIT, CIRCLE, BHILWARA, BHILWARA vs. M/S. SAMARPAN SYNTHETICS PVT. LTD. , BHILWARA

In the result, this appeal of the Revenue is dismissed

Bench: Shri Sandeep Gosain & Shri Manoj Kumar Aggarwala.C.I.T. Vs. M/S Samarpan Synthetics Pvt. Circle, Ltd., Bhilwara 54, Bhilwara Textiles Market, Pur Road, Bhilwara-311001, Rahasthan. Pan No. Aahcs 4365 G

bogus entities and never produced complete details and books of accounts before the AO while deleting addition of Rs.7,82,95,551/-. Ld. DR also submitted that the ld. CIT(A) had also erred in accepting the verbal contention of the assessee that purchase of Rs.10,00,68,034/- were bifurcated in the name of seven parties to obtain loan

PUKHRAJ KUNDANMAL SHAH,JODHPUR vs. ACIT/DCIT, CIRCLE-1, JODHPUR

In the result, the appeal of the assessee is allowed

Bench: Dr. Mitha Lal Meena, Hon'Ble & Dr. S. Seethalakshmi, Hon'Ble

purchase bills were disregarded and ignored blindly and nothing contrary was brought on record. 4. That the addition was made & confirmed by lower authorities without properly considering the submissions and evidences filed before them. 5. That the learned Commissioner of Income Tax (Appeals) has erred in applying the theory "Human Probability Test and Preponderance of Probability in the facts

ASSTT. COMMISSIONER OF INCOME TAX, PAOTA C ROAD vs. HRDK BULLION AND REFINERY PRIVATE LIMITED, JODHPUR

In the result, the appeal of the Revenue is dismissed

Bench: Dr. Mitha Lal Meena, Hon'Ble & Shri Udayan Das Gupta, Hon'Ble

PURCHASE-FINISHED GOODS/STOCK IN TRADE INDIRECT INCOME 5993701.0 50937010 5551520 PURCHAS 384444911 8856011 201611435 0 61 61 TO GROSS PROFIL 16198537 10404657 BCLOSING STOCK CRUSHER COOOS 22707686 22797686. 12775431 412319067 220098329 TOTAL 412319067 220098329 10 67 SON' 4. The assessing officer in its Assessment order has stated that "Futther, looking to the business trend of the assessee there is abnormal

MADAN LAL AND PARTY,HANUMANGARH vs. PR. CIT, BIKANER

The appeals stand allowed

Bench: Hon’Ble Shri Sandeep Gosain, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am (Hearing Through Video Conferencing Mode) 1. आयकरअपील सं./ I.T.A. No.233/Jodh/2018 ("नधा"रणवष" / Assessment Year: 2013-14) & 2. आयकरअपील सं./ I.T.A. No.234/Jodh/2018 ("नधा"रणवष" / Assessment Year: 2014-15) Madan Lal & Party Pr. Cit (Hanumangarh Town) Income Tax Office बनाम/ C/O Neeraj Chawla Ca Rani Bazaar, Bikaner Vs. 55, Adarsh Nagar, Sri Ganganagar Rajasthan. Rajasthan-335 001. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aacam-3229-Q (अपीलाथ"/Appellant) (""यथ" / Respondent) :

4. That the Ld. Pr. CIT Bikaner has erred in law and in fact in taking two actions at a time - one is passing order under section 263 and another is filing appeal before the H'ble Rajasthan High Court against the order of the H'ble ITAT Jodhpur. 2. We have carefully heard the rival submissions and perused relevant

SARDA DEVI CHECHANI,UDAIPUR vs. ITO TDS, UDAIPUR

In the result, the appeals of the assessee are allowed for statistical purposes

4,82,225/- 12 13 - 2012- 2013- 127/Jodh/2021 3273595/- 81840/- 70374/- 1,52,164/ 13 14 5. Against this assessee has filed appeal before the Honble CIT(A). The assessee has filed WS and details by stating that During the course of assessment proceedings, I have filed the Form 27C duly signed by the purchaser and which clearly mentions that

SARDA DEVI CHECHANI,UDAIPUR vs. ITO TDS, UDAIPUR

In the result, the appeals of the assessee are allowed for statistical purposes

4,82,225/- 12 13 - 2012- 2013- 127/Jodh/2021 3273595/- 81840/- 70374/- 1,52,164/ 13 14 5. Against this assessee has filed appeal before the Honble CIT(A). The assessee has filed WS and details by stating that During the course of assessment proceedings, I have filed the Form 27C duly signed by the purchaser and which clearly mentions that

SARDA DEVI CHECHANI,UDAIPUR vs. ITO TDS , UDAIPU

In the result, the appeals of the assessee are allowed for statistical purposes

4,82,225/- 12 13 - 2012- 2013- 127/Jodh/2021 3273595/- 81840/- 70374/- 1,52,164/ 13 14 5. Against this assessee has filed appeal before the Honble CIT(A). The assessee has filed WS and details by stating that During the course of assessment proceedings, I have filed the Form 27C duly signed by the purchaser and which clearly mentions that

LAKHPAT TRADING AND INDUSTRYS PVT. LTD.,JODHPUR vs. ACIT, CIRCLE-3, JODHPUR

In the result, the appeal of the assessee is allowed

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Blelakhpat Trading & Acit, Circle-3 Industryspvt. Ltd. Jodhpur G-72/73 79/80, 1St Phase, Boranada, Jodhpur - 342001 Pan No. Aaccl 5668 C Assessee By Shri Rajendra Jain, Advocate & Smt. Raksha Birla, Ca (Physical) Smt. Runi Pal, Cit-Dr (Virtual) Revenue By Date Of Hearing 29.01.2026. Date Of Pronouncement 26.02.2026. Order Dr. Mitha Lal Meena, A.M.: This Appeal Is Filed By Assessee Against The Order Of National Faceless Appeal Centre, Delhi [Hereinafter Referred To As Nfac/ Cit(A)] Dated 26.06.2025 With Respect To Assessment Year 2017-18 Challenging Therein The Rejection Of Its Books Of Accounts U/S 145(3), Estimation Of Income & Reducing Genuine Sales.

4. Briefly the facts are that the assessee is a Private limited Company engaged in the business of manufacturing, processing and trading of groundnut, soyabean and other oilseeds. The Ld. AR for the appellant assessee has contended that the assessee has furnished before the AO, all the details regarding transactions with respect to sales, purchase and manufacturing which are duly

SHRI JITENDRA OJHA ,SIROHI vs. ITO,, SIROHI

In the result appeal of assessee is allowed in terms indicated hereinabove

Bench: Shri R.C.Sharma, Accountant Mrmber Shri Jiterndra Ojha Vs The Ito, S/O Sh. Mangi Lal Ojha , Sirohi. Chhoti Brahmpuri, Sirohi.

section, where the Assessing Officer is satisfied that " ............... Since the ld. AO had not proceeded as per the mandatory provision of law, hence the ld. CIT(A) erred in maintaining the impugned asst. order. The same may kindly be cancelled and quashed. Such action and decision ought to have been sue-moto taken

ASHIANA BUILDPROP PRIVATE LIMITED,UDAIPUR vs. DCIT, CENTRAL CIRCLE-1 UDAIPUR, UDAIPUR

4. Regarding the objection of the appellant against the common warrant of authorisation, in addition to the finding in the order of the Ld. CIT(A), it is submitted that the same is expressly covered by the section 292CC of the Act as inserted by the Finance Act 2012 with retrospective effect from 01.04.1976. 5. Judgments of Honble Supreme Court

ASHIANA BUILDPROP PRIVATE LIMITED,UDAIPUR vs. DCIT- CENTRAL CIRCLE-1 UDIAPUR, UDAIPUE

4. Regarding the objection of the appellant against the common warrant of authorisation, in addition to the finding in the order of the Ld. CIT(A), it is submitted that the same is expressly covered by the section 292CC of the Act as inserted by the Finance Act 2012 with retrospective effect from 01.04.1976. 5. Judgments of Honble Supreme Court

ASHIANA BUILDPROP PRIVATE LIMITED,UDAIPUR vs. DCIT, CENTRAL CIRCLE-1, UDIAPUR, UDAIPUR

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

4. Regarding the objection of the appellant against the common warrant of authorisation, in addition to the finding in the order of the Ld. CIT(A), it is submitted that the same is expressly covered by the section 292CC of the Act as inserted by the Finance Act 2012 with retrospective effect from 01.04.1976. 5. Judgments of Honble Supreme Court

MAHENDRA KUMAR MUTHA,JODHPUR vs. DCIT, CIRCLE-3, JODHPUR

In the result, the appeal of the assessee is allowed

Bench: Shri Sandeep Gosain & Shri Manoj Kumar Aggarwalmahendra Kumar Mutha, Vs. Deputy Commissioner Of M/S R.B. Mutha & Co. Income Tax, B-11/A, Mandore Mandi, Circle-3, Jodhpur. Jodhpur. Pan No. Abmpm 02466 M Assessee By Shri Ajay Moondra Revenue By Shri A.S. Yadav, Jcit-Dr Date Of Hearing 04.11.2020 Date Of Pronouncement 29/01/2021

4 ITA 248/Jodh/2018 Mahendra Kumar Mutha Vs ACIT gross profit was due to various factors such as increased turnover, tough competition in market, fluctuation in rate of commodity etc. I find some force in the appellant’s arguments. It is seen that the turnover of the appellant has increased from Rs. 37,37,13,018/- last year

ITO, WARD, PHALODI, PHALODI vs. M/S RAMA ALLURE LLP, JODHPUR

In the result, appeal of the revenue is dismissed

Bench: The Date, The Appeal Is Finally Heard.”

purchase vouchers of goods transferred from OME has been explained by the assessee and a detailed note in the form of explanation has been filed—Likewise partner N has filed his returns year after year—His statement of account shows that he was having capital balance of Rs. 4,02,217 as on 31st March, 2006 which far exceeds

ASST COMMISSIONER OF INCOME TAX, BIKANER vs. MUKESH SHAH, SRIGANGANAGAR

In the result, the appeal of the revenue is dismissed

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

Section 2(13) of the IT Act which reads as under: "Business" includes any trading, commerce or manufacture or any adventure or concern in the nature of trade, commerce or manufacture." The above definition has used the words 'trade' 'commerce' or 'manufacture' or "any adventure or concern in the nature of trade, commerce or manufacture". The Hon'ble Gujarat High