SAMPAT LAL LODHA ,NATHDWARA vs. ITO, WARD-2, RAJSAMAND

In the result, both appeals of the assessee are allowed

282 (Delhi) “Income—Cash credit—Burden of proof—Assessee had raised unsecured loans from its directors and shareholders—Assessee filed copies of returns, statements of income, balance sheet, P&L a/c and bank statements, etc. of creditors—Affidavits of some creditors were also filed—Assessee had discharged initial onus placed on it—In the event the Revenue still

SATYA NARAYAN DHOOT,JODHPUR vs. PR. CIT-1, JODHPUR

In the result, the appeal of the assessee is allowed in respect of above said three issues

Bench: Shri B.R. Baskaran (Am) & Shri Sandeep Gosain (Jm) I.T.A. No. 49/Jodh/2022 (A.Y. 2017-18) Vs. Pcit-1 Satya Narayan Dhoot C/O Rajendra Jain Advocate Jodhpur 106, Akshay Deep Complex 5Th B Road, Sardarpura Jodhpur, Rajasthan-342 001. Pan : Aanpd4945L (Appellant) (Respondent) Assessee By Shri Rajendra Jain Department By Smt. Alka Rajvanshi Jain Date Of Hearing 03.11.2022 Date Of Pronouncement 17 .01.2023 O R D E R Per B.R.Baskaran (Am) :-

282.” The principles laid down by the courts are that the Learned CIT cannot invoke his powers of revision under section 263 if the Assessing Officer has conducted enquiries and applied his mind and has taken a possible view of the matter. If there was any enquiry and a possible view is taken, it would not give occasion