CHAINARAM,JODHPUR vs. ITO, WARD-3(1), JODHPUR

In the result, the captioned appeals of the assesses in ITA Nos

Bench: Shri Laliet Kumar, Hon'Ble & Dr. Mitha Lal Meena, Hon'Ble

Natural Justice. He further submitted that the worthy CIT(A) has grossly erred in confirming the addition of Rs. 2,25,51,340/- without appreciating the facts on merits of the case that disputed addition has been made without any tangible material in possession of the AO, invoking the extended period of limitation under the provisions

CHAINARAM,JODHPUR. vs. ITO, WARD-3(1), JODHPUR

In the result, the captioned appeals of the assesses in ITA Nos

Bench: Shri Laliet Kumar, Hon'Ble & Dr. Mitha Lal Meena, Hon'Ble

Natural Justice. He further submitted that the worthy CIT(A) has grossly erred in confirming the addition of Rs. 2,25,51,340/- without appreciating the facts on merits of the case that disputed addition has been made without any tangible material in possession of the AO, invoking the extended period of limitation under the provisions

SMT. PUSHPA CHHAJER,JODHPUR vs. ACIT,CIRCLE-1, JODHPUR

In the result, appeal of the assessee is partly allowed

reassessment, if necessary, in accordance with law From the above the notice u/s 148 issued by the ld AO is bad in law and against the principle of natural justice

VINOD (RATAN) SUHALKA,UDAIPUR vs. ACIT, CENTRAL CIRCLE-1, UDAIPUR

In the result, the appeals of the assessee are allowed

Bench: Shri B. R. Baskaran & Shri Sandeep Gosain

natural justice is offended. On the basis of such proceedings, no penalty could be imposed to the assessee. (s) Taking up of penalty proceedings on one limb and finding the assessee guilty of another limb is bad in law. (t) The penalty proceedings are distinct from the assessment proceedings. The proceedings for imposition of penalty though emanate from proceedings

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

In the result, both appeals of the assessee are allowed

natural justice but also against the law settled by Hon'ble Courts in following cases: - i] In the case of ‘CIT Vs Smt Maniben Valji Shah’, 283 ITR 453 the Hon’ble Bombay High Court quashed assessment based on notice under section 148 of the Act where proceedings under section 147 was initiated to verify the source of Investment made

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

In the result, both appeals of the assessee are allowed

natural justice but also against the law settled by Hon'ble Courts in following cases: - i] In the case of ‘CIT Vs Smt Maniben Valji Shah’, 283 ITR 453 the Hon’ble Bombay High Court quashed assessment based on notice under section 148 of the Act where proceedings under section 147 was initiated to verify the source of Investment made

KANAK KUMAR JAIN L/H OF PARTNER OF M/S. KESARIYAJI FILLING STATION,UDAIPUR vs. DCIT, CIRCLE-1, UDAIPUR

In the result, appeals of the assessee are allowed

reassessment proceeding in gross violation of provisions of section\n189(3) of the Act and principle of natural justice.\n1.17

KANAK KUMAR JAIN L/H OF PARTNER OF M/S. KESARIYAJI FILLING STATION,UDAIPUR vs. DCIT, CIRCLE-1, UDAIPUR

In the result, appeals of the assessee are allowed

reassessment proceeding in gross violation of provisions of section\n189(3) of the Act and principle of natural justice.\n1.16

LAXMAN SINGH SOLANKI (FIRM),PALI vs. ITO, , PALI

In the result, the appeal of the assessee is allowed for statistical purposes

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

natural justice. 4 The appellant pray for suitable costs. 3. Briefly, the facts of the case are that the assessee, a partnership firm, filed its return of income for A.Y. 2014-15 on 26.11.2014 declaring total income of Rs.17,78,470/-. The assessment was originally completed under section 143(3) on 29.12.2016 at Rs.25,28,470/-. 3.1 Subsequently, the case

SHAHNAJ,NEAR BHERUDANJI WELL vs. INCOME TAX OFFICER, WARD-2, INCOME TAX OFFICE

In the result, the appeal of the assessee is allowed

Bench: Dr. S. Seethalakshmi & Dr Mitha Lal Meenasmt. Shanaj Vs The Ito W/O Shri Aslam Khan Ward-2, Churu, Near Bherudan Ji Well,Ward No. 22 Churu Sardarshahar,Churu – 331 403 (Appellant) (Respondent) Pan No. Fpmps 3570 D

natural justice and the assessment was not valid and liable to be quashed [PS Abdul Majid Vs. AGIT — STO — reported in 209 ITR 821]. Since in the assessment proceedings, procedure of law is not followed, therefore, the same should be held as null and void. (Ground No. 8) On the facts and circumstances of the case and law also Learned

KANAK KUMAR JAIN L/H OF PARTNER OF M/S. KESARIYAJI FILLING STATION,UDAIPUR vs. DCIT, CIRCLE-1, UDAIPUR

In the result, appeals of the assessee are allowed

reassessment proceeding in gross violation of provisions of section\n189(3) of the Act and principle of natural justice.\n1.17

KANAK KUMAR JAIN L/H OF PARTNER OF M/S. KESARIYAJI FILLING STATION,UDAIPUR vs. DCIT, CIRCLE-1, UDAIPUR

In the result, appeals of the assessee are allowed

reassessment proceeding in gross violation of provisions of section\n189(3) of the Act and principle of natural justice.\n1.16

KANAK KUMAR JAIN L/H OF PARTNER OF M/S. KESARIYAJI FILLING STATION,UDAIPUR vs. DCIT, CIRCLE-1, UDAIPUR

In the result, appeals of the assessee are allowed

reassessment proceeding in gross violation of provisions of section\n189(3) of the Act and principle of natural justice.\n1.17

M/S. RASIK PRIYA RESORTS PVT. LTD. ,UDAIPUR vs. DCIT, CENTRAL CIRCLE-2, UDAIPUR

In the result, appeal of the assessee in ITA

Bench: Shri Pavan Kumar Gadale & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.199 & 200/Jodh/2018 िनधा"रण वष" / Assessment Years : 2012-13 & 2013-14 M/S.Rasik Priya Resorts Pvt. The Deputy Commissioner Ltd., V Of Income Tax, 11, Mangal Complex, S. Central Circle-2, Udaipur. Saifan Choraha, Bedla Road, Udaipur. Pan: Aafcr 5546 N Appellant/ Assessee Respondent/ Revenue Assessee By Shri Rakesh Lodha – Ca Revenue By Smt. Alka Rajvanshi Jain – Cit(Dr) Date Of Hearing 10/08/2023 Date Of Pronouncement 30/10/2023

natural justice 4.1 The ld.CIT(A) has at length discussed the issue. The ld.CIT(A) has given proper opportunity to the assessee, therefore, we do not find any merit in Ground No.1 and hence, Ground No.1 is dismissed. 5. Ground No.3 : 3 The Ld. CIT(A-2) also erred in rejecting the ground challenging issue of notice u/s 153A

M/S. RASIK PRIYA RESORTS PVT. LTD. ,UDAIPUR vs. DCIT, CENTRAL CIRCLE-2, UDAIPUR

In the result, appeal of the assessee in ITA

Bench: Shri Pavan Kumar Gadale & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.199 & 200/Jodh/2018 िनधा"रण वष" / Assessment Years : 2012-13 & 2013-14 M/S.Rasik Priya Resorts Pvt. The Deputy Commissioner Ltd., V Of Income Tax, 11, Mangal Complex, S. Central Circle-2, Udaipur. Saifan Choraha, Bedla Road, Udaipur. Pan: Aafcr 5546 N Appellant/ Assessee Respondent/ Revenue Assessee By Shri Rakesh Lodha – Ca Revenue By Smt. Alka Rajvanshi Jain – Cit(Dr) Date Of Hearing 10/08/2023 Date Of Pronouncement 30/10/2023

natural justice 4.1 The ld.CIT(A) has at length discussed the issue. The ld.CIT(A) has given proper opportunity to the assessee, therefore, we do not find any merit in Ground No.1 and hence, Ground No.1 is dismissed. 5. Ground No.3 : 3 The Ld. CIT(A-2) also erred in rejecting the ground challenging issue of notice u/s 153A

PREETI SINGHVI L/H SHRI AJAY SINGHVI,JODHPUR vs. ACIT, CIRCLE-3, JODHPUR

In the result, the appeal of the assessee is dismissed

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

reassessment order passed by the AO as AO’s order was totally illegal, parvas, without jurisdiction, arbitrary and in violation of principles of natural justice

SHRI NAVEEN GOYAL,BIKANER vs. ITO, WARD-1(1), BIKANER

In the result, the appeal of the assessee is allowed

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Blenaveen Goyal Prop. Vs. Ito Ward 1(1) Naveen Trading Company S-4, Bikaner Anaz Mandi, Bikaner - 334001 Pan No. Babpg 8637 D Assessee By Shri Virendra Jain, Advocate (Virtual) Revenue By Shri Lalit Kumar Bishnoi, Addl. Cit-Dr (Virtual) Date Of Hearing 28.01.2026. 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 [Hereinafter Referred To As Nfac] Delhi Dated 21.06.2024 With Respect To Assessment Year 2018-19. 2. Grounds Of Appeal Are As Under: 1. The Ld. Cit(A) Has Erred In Sustaining The Order Passed By Ld. Assessing Officer Which Is Bad In Law & Bad On Facts & Is Contrary To The Principles Of Natural Justice. The Proceedings U/S 144 Are Bad In Law & Bad On Facts. 2. The Ld. Cit(A) Has Erred In Sustaining The Addition Made By Assessing Officer By Assuming Deemed Income Of Commission @ 4% On The Loan Taken Amount 17,50,00,000/- Taxed It At As An Income From Other Source. Both The Authorities Have Totally Ignored Whole Relevant Facts & Documents Submitted By The Appellant. So The Addition So Made Is Arbitrary & Unwarranted. The Unsecured Asst. Year: 2018-19 2 Loan Taken Rs. 17,50,00,000/- During The Year Is Genuine & Fare So The Addition May Kindly Be Quashed. 3. The Ld. Cit(A) Has Erred In Sustaining Interest Charged U/S 234A, 234B & 234C Of The Act. 4. The Appellant Prays For Justice & Relief. 3. The Sole & Common Issue Challenged In The Grounds Of Appeal Pertains To An Addition Rs. 70 Lakh By Treating 4% Deemed Commission On Allegedly Routing Money Of A Director Of The Company By Way Of Treating Shares Of 17.50 Cr As Against Unsecured Loan Of Rs. 17.00 Crore Taken From M/S Vikas Granaries Ltd.

natural justice without appreciating the facts of the case.The AR contended that due to technical glitches in the faceless/virtual proceedings, the assessee could not made its submissions effectively. He prayed that the addition may be deleted. The Ld. DR supported the impugned order and argued that it was the fault in the system of the assessee

RACHNA GOYAL,JODHPUR vs. ITO, WARD-1(2), JODHPUR

In the result, appeal of the assessee is dismissed

justice, the AO disposed off the objection of the assessee vide his\nspeaking order dated 21.02.2022.\nThereafter, the AO issued a show cause notice dated 15.03.2022 to the\nassessee for not furnishing the details as required vide notice under section 142(1)\nof the Act. In response, the assessee filed reply dated 17.03.2022 through faceless\nproceedings. The reply