AJMER DEVELOPMENT AUTHORITY,AJMER vs. CIT(EXEMPTION)/ ITO (EXEMPTION), JAIPUR / JODHPUR

In the result, the stay application filed by the assessee is dismissed

Bench: Shri Kul Bharatshri Manish Borad

11 & 12 can be given as filing of return of income in time is a pre-condition for availing benefit under section 12AA of the Act as per section 12A(1)(b) of the I.T. Act 1961. As such, cash deposited of Rs. 16,79,12,657/ -in bank accounts, earned interest income of Rs. 20,07,054/ - and purchase

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

In the result, appeal of the assessee is allowed

11 Nahar Colours and Coatings Private Ltd 5.2.2 As regards the disallowance of Rs. 15,24,003/- in terms of section 36(1)(va) r.w.s. 2(24)(x) of the Act the issue was covered based on the jurisdictional high court decision and therefore, the issue was debatable and law does not permit the review of each every order after

SMT. JAYA MOGRA,UDAIPUR vs. DCIT, CENTRAL CIRCLE-2, UDAIPUR

In the result, appeal of the assessee in ITA No

11 Smt. Jaya Mogra CIT(A) is relevant to understand the issue and therefore, the same is reiterated here in below : “3.5 From the above fact it is clear beyond doubt that the source of deposit in bank is the sale consideration received through banking channel and not bash cash and has direct nexus with the sale of land

MANGILAL DATLA,BANSWARA vs. INCOME TAX OFFICER, WARD BANSWARA, BANSWARA

In the result, the appeal filed by the assessee is allowed, both on legal issue\nas well as on facts

11. In this context, we have noted that the reasons proceeded on two fundamental\ngrounds. One, that the property in question was sold for a sum of Rs. 1,18,95,000/- and\ntwo; that the assessee had not filed the return and that therefore his 1/3rd share out of the\nsale proceeds was not offered to tax. Both these

HEERA LAL KASARA,UDAIPUR vs. ITO, WARD-2(1), UDAIPUR

In the result, appeal of the assessee is allowed

Bench: Its Hearing Before Your Honours.”

reassessment proceedings initiated under section 147 of the Act. The objections of the assessee were duly disposed off by the AO vide his letter dated 15.12.2016.Thereafter, the AO issued show cause notice asking the assessee to show cause as to why the undisclosed GP of Rs. 47,79,046/- should not be treated as income from undisclosed sources vide letter

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

2. On perusal of assessment records it is also noticed that the assessee has earned income of Rs. 16,57,517/— which is claimed as exempted income. However no disallowance of expenses has been made by the AO u/s 14 A read with Rule 8 D. 3. The above income has not been dealt in assessment order

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

2. On perusal of assessment records it is also noticed that the assessee has earned income of Rs. 16,57,517/— which is claimed as exempted income. However no disallowance of expenses has been made by the AO u/s 14 A read with Rule 8 D. 3. The above income has not been dealt in assessment order

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

2. On perusal of assessment records it is also noticed that the assessee has earned income of Rs. 16,57,517/— which is claimed as exempted income. However no disallowance of expenses has been made by the AO u/s 14 A read with Rule 8 D. 3. The above income has not been dealt in assessment order

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

2. On perusal of assessment records it is also noticed that the assessee has earned income of Rs. 16,57,517/— which is claimed as exempted income. However no disallowance of expenses has been made by the AO u/s 14 A read with Rule 8 D. 3. The above income has not been dealt in assessment order

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

2. On perusal of assessment records it is also noticed that the assessee has earned income of Rs. 16,57,517/— which is claimed as exempted income. However no disallowance of expenses has been made by the AO u/s 14 A read with Rule 8 D. 3. The above income has not been dealt in assessment order

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

2. On perusal of assessment records it is also noticed that the assessee has earned income of Rs. 16,57,517/— which is claimed as exempted income. However no disallowance of expenses has been made by the AO u/s 14 A read with Rule 8 D. 3. The above income has not been dealt in assessment order

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

11. As per the provisions of Section 153A, in case of a search under Section 132 or requisition under Section 132A, the AO gets the jurisdiction to assess or reassess the ‘total income’ in respect of each assessment year falling within six assessment years. However, it is required to be noted that as per the second proviso to Section 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

11. As per the provisions of Section 153A, in case of a search under Section 132 or requisition under Section 132A, the AO gets the jurisdiction to assess or reassess the ‘total income’ in respect of each assessment year falling within six assessment years. However, it is required to be noted that as per the second proviso to Section 153A

SUNIL PAGARIA,UDAIPUR vs. ITO, WARD-2(1), UDAIPUR

In the result, the appeal of the assessee is allowed

2. Smt. Hansabaisanghvi v/s ITO ; (2004) 89 ITD (Hyd) 239 Para 4.2.3 at he assesee utilized the sale proceeds on of Para 8,9, & No adverse pg 12 of the the sale of plot of land, for the purchase of a 11 of the inference order house bearing municipal No. 19-5-9/97(54B order at pg drawn

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

11,658\n2,50,000\n44,61,658/-\n3 BHK (Standard)\n2022\n2151/-\n43,49,322\n2,50,000\n45,99,322/-\n3 BHK (Standard)\n2040\n2151/-\n43,88,040\n2,50,000\n46,38,040/-\n3 BHK (Standard)\n2060\n2151/-\n44,31,060\n2,50,000\n46,81,060/-\n32\nITA Nos. 706 to 709/Jodh/2024\nAshiana Buildprop

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.

reassessment proceedings. 4. The Assessee being aggrieved with the assessment order preferred an appeal before the learned CIT(A) who has confirmed the finding of the AO by 3 Asst. Year: 2014-15 observing that the appellant’s claim that it has used a valuation method substantiated to the AO’s satisfaction was found unacceptable being in- consistent with Rule

INCOME TAX OFFICER, WARD-1, BARMER vs. PUSHP RAJ BOHRA, JALORE

The appeal of the revenue is allowed, in the manner discussed as above

Bench: Shri Rajpal Yadav, HonʼBle & Dr. Mitha Lal Meena, Hon'Bleito, Ward-1, Barmer. Vs. Pushp Raj Bohra, M-09, Shivaji Nagar, Jalore - 343001. Pan No. Aanpb4456C Assessee By Shri Goutam Chand Baid, C.A. Revenue By Smt. Runi Pal, Cit (D.R.) Date Of Hearing 29.04.2025. Date Of Pronouncement 01.03.2025. Order Per Dr. Mitha Lal Meena, A.M.: The Captioned Appeal Has Been Filed By The Revenue Against The Order Of The Id. National Faceless Appeal Centre [Nfac/Cit(A)], Delhi Dated 08.02.2024 In Respect Of Assessment Year: 2017-18 Where The Department Has Raised Following Grounds: 1. Whether The Id. Cit(A) Is Justified In Facts & Law In Directing To Treat The Income From The Sale Of Immovable Properties As Capital Gains Instead Of Business Income, By Ignoring The Fact That Assesse & His Business Concerns Are Engaged In The Business Of Property & Real Estate Development & Huge Expenses Of Rs. 8.72 Cr. Were Incurred By Assessee On Development Of Projects To Earn Profit. 2. Whether The Id. Cit(A) Has Erred In Law & Facts By Directing The Ao To Treat The Income From The Sale Of Immovable Properties As Income From Capital Gains Instead Of Business Income By Merely Following The Order Of Hon'Ble

11. Even for the sack of submission if it held that eligibility of exemption u/s 54F/54EC is the subject matter of appeal before the CIT(A), restoration of the issue before the assessing officer is not within the powers of the CIT(A). Section 251(1)(a) laid in very clear terms that in an appeal against an order

M/S. SUPER SHIV SHAKTI MINCHEM PVT. LTD.,JODHPUR vs. ITO, WARD-3, , BHILWARA

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

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

2. That on the facts and in the circumstances of the case, the Ld. CIT (A) erred in sustaining the addition made by Ld. AO for Rs. 78,60,000/-treating the amount received towards subscription of share capital as unexplained cash credit. The addition so sustained may kindly be deleted. 3. That on the facts and in the circumstances