M.G.B. GRAMIN BANK (THROUGH SUCCESSOR RAJASTHANMARUDHARA GRAMIN BANK),JODHPUR vs. ADDITIONAL CIT, PALI

Appeals are disposed off in the terms indicated as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

45,459/-.” Grounds of appeal in ITA No. 520/Jodh/2018: “1. That on the facts and in the circumstances of the case, the ld. CIT(A)1, Jodhpur erred in sustaining the assessment order framed in the name of MGB Gamin Bank without bringing the successor on record. Assessment order framed u/s 143(3) in the name MGB Gramin Bank

M.G.B. GRAMIN BANK (THROUGH SUCCESSOR RAJASTHANMARUDHARA GRAMIN BANK),JODHPUR vs. ACIT, PALI

Appeals are disposed off in the terms indicated as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

45,459/-.” Grounds of appeal in ITA No. 520/Jodh/2018: “1. That on the facts and in the circumstances of the case, the ld. CIT(A)1, Jodhpur erred in sustaining the assessment order framed in the name of MGB Gamin Bank without bringing the successor on record. Assessment order framed u/s 143(3) in the name MGB Gramin Bank

ACIT, CIRCLE, PALI. vs. M/S. RAJASTHAN MARUDHARA GRAMIN BANK, , JODHPUR

Appeals are disposed off in the terms indicated as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

45,459/-.” Grounds of appeal in ITA No. 520/Jodh/2018: “1. That on the facts and in the circumstances of the case, the ld. CIT(A)1, Jodhpur erred in sustaining the assessment order framed in the name of MGB Gamin Bank without bringing the successor on record. Assessment order framed u/s 143(3) in the name MGB Gramin Bank

M.G.B. GRAMIN BANK (THROUGH SUCCESSOR RAJASTHANMARUDHARA GRAMIN BANK),JODHPUR vs. ACIT, PALI

Appeals are disposed off in the terms indicated as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

45,459/-.” Grounds of appeal in ITA No. 520/Jodh/2018: “1. That on the facts and in the circumstances of the case, the ld. CIT(A)1, Jodhpur erred in sustaining the assessment order framed in the name of MGB Gamin Bank without bringing the successor on record. Assessment order framed u/s 143(3) in the name MGB Gramin Bank

M.G.B. GRAMIN BANK (THROUGH SUCCESSOR RAJASTHANMARUDHARA GRAMIN BANK),JODHPUR vs. ACIT, PALI

Appeals are disposed off in the terms indicated as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

45,459/-.” Grounds of appeal in ITA No. 520/Jodh/2018: “1. That on the facts and in the circumstances of the case, the ld. CIT(A)1, Jodhpur erred in sustaining the assessment order framed in the name of MGB Gamin Bank without bringing the successor on record. Assessment order framed u/s 143(3) in the name MGB Gramin Bank

NAHAR COLOURS AND COATINHGS PRIVATE LIMITED,UDAIPUR vs. PRINCIPAL COMMISSIONER OFINCOMETAX, UDAIPUR

In the result, appeal of the assessee is allowed

4 Copy of Audited Financial statements for AY 2018-19 21-40 5 Notice u/s 142(1) issued during the assessment 41-44 proceedings. 6 Submissions made before the ld. AO 45 7 Power Purchase agreement with JVVNL 46-60 8 Audit report in 10CCB for all the units 61-72 5.1 In addition the ld. AR of the assessee

INCOME TAX OFFICER, TDS, UDAIPUR vs. DEPUTY CONSERVATOR OF FOREST SOUTH, UDAIPUR

In the result, both the above appeals filed by the Revenue are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), DR. MITHA LAL MEENA (Accountant Member)

45,72,332/- under Section 201(1)/201(1A) of the Income Tax Act, 1961, for the Financial Year 2012-13. The Revenue contends that the CIT(A) erred in holding that payments made to Van Suraksha and Prabandh Samitis (VFPMCs) were not contract payments under Section 194C of the Income Tax Act, 1961. The Revenue argues that the VFPMCs

INCOME TAX OFFICER, TDS, UDAIPUR vs. DEPUTY CONSERVATOR OF FOREST (SOUTH), UDAIPUR

In the result, both the above appeals filed by the Revenue are dismissed

Bench: the Ld. CIT(A) who has deleted the said demand by stating that the VFPMCs are not contractors under Section 194C, as they are formed under the Rajasthan Forest Act, 1953, and function as self-help groups for forest conservation and development. The payments made to VFPMCs are not contract payments but are reimbursements for work done under the joint forest management policy of the State Government.

45,72,332/- under Section 201(1)/201(1A) of the Income Tax Act, 1961, for the Financial Year 2012-13. The Revenue contends that the CIT(A) erred in holding that payments made to Van Suraksha and Prabandh Samitis (VFPMCs) were not contract payments under Section 194C of the Income Tax Act, 1961. The Revenue argues that the VFPMCs

ROYAL SUITINGS PRIVATE LIMITED ,BHILWARA vs. ITO, WARD-1, BHILWARA

In the result, the appeal of the assessee is allowed

section 154 dated 31.08.2018. The grounds of appeal raised by the assessee are as under:- “1. That assessee company made addition in plant & machinery of Rs. 21, 45,124/- and claimed depreciation thereon. 2. That A.O. disallowed the depreciation on these additions and completed the assessment by stating that these are not plant & machinery but fails to allow as revenue

ACIT, PAOTA C ROAD vs. VARAHA INFRA LIMITED, PAOTA B ROAD

In the result, the appeal of the revenue is dismissed

Bench: Dr. S. Seethalakshmi & Shri Rathod Kamlesh Jayantbhaithe Acit Vs M/S. Vardha Infra Ltd. Room No. 215, Aayakar Bhawan 6 Jalam Vilas Scheme Paota C Road, Jodhpur Paota B Road, Jodhpur (Appellant) (Respondent) Pan No. Aaccv 7972 K

depreciation @ 10.32% subject to depreciation, except depreciation on fixed assets claimed to be added during the year under consideration (i.e. for AY 2016-2017). When revenue challenged that order of the ld. CIT(A) net profit rate of 10.32% was applied net of depreciation means no separate deduction of depreciation was allowable. So, applying that precedent ld. AO noted that

M/S. MOHTA CONSTRUCTION CO.,BIKANER vs. ACIT, BIKANER

In the result, the appeal of the assesee is allowed

Bench: Us. 2. The Assessee Has Raised The Following Grounds Of Appeal:- M/S Mohta Construction Co. “1. That The Assessment Completed By The Assessing Officer Is Against The Law & The Order Of Learned Cit(Appeals) Sustaining The Disallowances/Not Allowing The Deductions Claimed By The Appellant Is Bad At Law.

4. That the Ld. A.O. as well as Ld. CIT(A) were not justified in application of rate of profit @ 7%, which is not in accordance with the past history of the appellant's own case. The Ld. CIT(A) has erred in sustaining the rate of profit @7%, where in the immediately preceding year he himself directed

NAVKAR WOLLENS PRIVATE LIMITED,BIKANER vs. ACIT CIRCLE-3, BIKANER

In the result, the appeal of the assessee is allowed

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Blenavkar Woollens Private Ltd. Assistant Commissioner Of Rani Bazar, Bikaner, H.O. Income Tax, Circle – 3 Bikaner, Bikaner Bikaner - 334001 Pan No. Aabcn 9287 G Assessee By Shri Rajendra Jain, Advocate & Smt. Raksha Birla, Ca (Physical) Revenue By Smt. Runi Pal, Cit-Dr & Shri Lalit Kumar Bishnoi, Addl. Cit-Dr (Virtual) 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 30.07.2025 With Respect To Assessment Year 2014-15 Challenging Therein Sustaining The Addition Of Rs. 2,34,04,480/- On Account Of Difference Between The Fair Market Value & The Issue Price Of The Equity Shares By Questioning The Method Of Valuation.

Section 147 based on information that 51392 shares were issued at the premium of Rs. 120 each by over value assessed particularly in violation of Rule 11UA of Income Tax Rules. The AO alleged that while computing the fair market value (FMV) of shares the appellant took the market value of land at Rs. 2,45,50,000/- under

M/S TARUN CONSTRUCTION COMPANY,WARD NO.24, NEAR BHAGAT SINGH CHOWK, SURATGARH vs. CPC, BANGALORE/ ITO, WARD-1, SRIGANGANAGAR, SRIGANGANAGAR

In the result, appeals are dismissed

Bench: Shri Saktijit Dey, Vice- & Dr. Brr Kumar

4. From the aforesaid provisions, it is very clear that the said cl. (iv) would come into operation when the tax auditor had suggested for a disallowance of expense or increase in income, but the same had not been carried out by the assessee while filing the return of income. As stated supra, the tax auditor had not stated

M/S TARUN CONSTRUCTION COMPANY,WARD NO.24, NEAR BHAGAT SINGH CHOWK, SURATGARH vs. CPC, BANGALORE/ ITO, WARD-1, SRIGANGANAGAR , SRIGANGANAGAR

In the result, appeals are dismissed

Bench: Shri Saktijit Dey, Vice- & Dr. Brr Kumar

4. From the aforesaid provisions, it is very clear that the said cl. (iv) would come into operation when the tax auditor had suggested for a disallowance of expense or increase in income, but the same had not been carried out by the assessee while filing the return of income. As stated supra, the tax auditor had not stated

M/S. BHARAT CERA GLASS LIMITED,BHILWARA vs. ITO, WARD-3, BHILWARA

In the result, both the grounds of appeal raised by the assessee are dismissed

Bench: Shri Pavan Kumar Gadale & Dr. Dipak P. Ripoteassessment Year : 2013-14 M/S Bharat Cera Glass Limited, Income Tax Officer, 1-B-24, Shashtri Nagar, Vs Ward-3, Bhilwara Bhilwara Pan: Aaecb4366K Appellant / Assessee Respondent / Revenue

4,00,000 x (40 - 36.62)]. As the AO has made the addition of Rs. 14,63,000/-, therefore the addition of Rs. 13,52,000/- is confirmed and remaining addition of Rs. 1,11,000/- is hereby deleted.” 7. Thus, Ld. CIT(A) confirmed addition of Rs. 13,52,000/- instead of Rs. 14,63,000/- done

THE LAKE PALACE HOTELS & MOTELSPRIVATE LIMITED,UDAIPUR vs. PCIT,CIRCLE-2, UDAIPUR

In the result, appeal of the assessee is allowed

section 43(b) of The Income Tax Act for such disallowances are applicable from the Assessment Year 2021- 22 and onwards. 4. That on the facts and in the circumstances of the case the order passed u/s 263 of the IT Act is bad in law and, void ab-initio and deserves to be annulled as the same is based

M/S BHAGIRATH DAIRY PRIVATE LIMITED,NAGAUR vs. ASSISTANT COMMISSIONER OF INCOME TAX,, NAGAUR

The appeal is allowed

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Ble

section 68 of the act and and added to the income of the assessee. In addition to the cash-credits, the AO has further made addition of Rs. 8,56,000/- u/s 69A of the by treating the deposit in the name of Sh. Mohan Ram Choudhary and Smt.Tulchi Devi

JS ENGINEERING WORKS,SAWA, CHITTORGARH vs. DCIT, CENTRAL CIRCLE, CHITTORGARH

In the result, all these 6 appeals filed by the assessee are allowed

Bench: Dr. Mitha Lal Meena, Hon’Ble & Sudhir Pareek, Hon’Blestay Application No. 8 To 13/Jodh/2024 (Arising Out Of Ita Nos. 620, 621, 622, 624, 625 &628/Jodh/2024) (Assessment Year – 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 & 2017-18) Js Engineering Works Dcit, Central Circle, J-16, M/S. Sclj & Associates, Chittorgarh. Lal Kothi Yojana, Sahakar Marg, Jaipur – 302015. Pan No. Aaffj 9260 Q

45,91,610 2017-18 37,99,680 3.1 In these cases, the regular scrutiny assessments u/s 143(3) have been completed for the assessment years 2012-13 to 2015-16. The details of the same are as below: 4 622/Jodh/2024 & Others Assessment Years 2012-13 to 2017-18 AY Date of order Retuned Addition Remarks income made

JS ENGINEERING WORKS,SAWA CHITTORGARH vs. DCIT, CENTRAL CIRCLE, CHITTORGARH

In the result, all these 6 appeals filed by the assessee are allowed

Bench: Dr. Mitha Lal Meena, Hon’Ble & Sudhir Pareek, Hon’Blestay Application No. 8 To 13/Jodh/2024 (Arising Out Of Ita Nos. 620, 621, 622, 624, 625 &628/Jodh/2024) (Assessment Year – 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 & 2017-18) Js Engineering Works Dcit, Central Circle, J-16, M/S. Sclj & Associates, Chittorgarh. Lal Kothi Yojana, Sahakar Marg, Jaipur – 302015. Pan No. Aaffj 9260 Q

45,91,610 2017-18 37,99,680 3.1 In these cases, the regular scrutiny assessments u/s 143(3) have been completed for the assessment years 2012-13 to 2015-16. The details of the same are as below: 4 622/Jodh/2024 & Others Assessment Years 2012-13 to 2017-18 AY Date of order Retuned Addition Remarks income made