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.

u/s 144 of the Income Tax Act. 4. The assessee reserves the right to add, alter or amend any ground of appeal as and when the need arises. 3. At the outset the Ld. AR for the Assessee has submitted that the appellant assessee case was reopened under Section 147 based on information that 51392 shares were issued

MEWAR HOSPITAL PVT. LTD. ,UDAIPUR vs. ACIT, CENTRAL CIRCLE-2, UDAIPUR

In the result the appeal of the assessee in ITA No

120/- made on account of discount allowed on this bills of patients for treatment. The Ld. CIT(A) ignored the principle of preponderance of human probability as laid down by Hon’ble SC in the case of Sumati Dayal v. CIT (1995) 214 ITR 801(SC) & CIT v. Durga Prasad More (1971) 82 ITR 540 (SC). 3. Whether

MEWAR HOSPITAL PVT. LTD. ,UDAIPUR vs. ACIT, CENTRAL CIRCLE-2, UDAIPUR

In the result the appeal of the assessee in ITA No

120/- made on account of discount allowed on this bills of patients for treatment. The Ld. CIT(A) ignored the principle of preponderance of human probability as laid down by Hon’ble SC in the case of Sumati Dayal v. CIT (1995) 214 ITR 801(SC) & CIT v. Durga Prasad More (1971) 82 ITR 540 (SC). 3. Whether

MEWAR HOSPITAL PVT. LTD. ,UDAIPUR vs. ACIT, CENTRAL CIRCLE-2, UDAIPUR

In the result the appeal of the assessee in ITA No

120/- made on account of discount allowed on this bills of patients for treatment. The Ld. CIT(A) ignored the principle of preponderance of human probability as laid down by Hon’ble SC in the case of Sumati Dayal v. CIT (1995) 214 ITR 801(SC) & CIT v. Durga Prasad More (1971) 82 ITR 540 (SC). 3. Whether

ACIT, CENTRAL CIRCLE-2, UDAIPUR, UDAIPUR vs. M/S MEWAR HOSPITAL PVT. LTD., UDAIPUR

In the result the appeal of the assessee in ITA No

120/- made on account of discount allowed on this bills of patients for treatment. The Ld. CIT(A) ignored the principle of preponderance of human probability as laid down by Hon’ble SC in the case of Sumati Dayal v. CIT (1995) 214 ITR 801(SC) & CIT v. Durga Prasad More (1971) 82 ITR 540 (SC). 3. Whether

ACIT, CENTRAL CIRCLE-2, UDAIPUR, UDAIPUR vs. M/S MEWAR HOSPITAL PVT. LTD., UDAIPUR

In the result the appeal of the assessee in ITA No

120/- made on account of discount allowed on this bills of patients for treatment. The Ld. CIT(A) ignored the principle of preponderance of human probability as laid down by Hon’ble SC in the case of Sumati Dayal v. CIT (1995) 214 ITR 801(SC) & CIT v. Durga Prasad More (1971) 82 ITR 540 (SC). 3. Whether

MEWAR HOSPITAL PVT. LTD. ,UDAIPUR vs. ACIT, CENTRAL CIRCLE-2, UDAIPUR

In the result the appeal of the assessee in ITA No

120/- made on account of discount allowed on this bills of patients for treatment. The Ld. CIT(A) ignored the principle of preponderance of human probability as laid down by Hon’ble SC in the case of Sumati Dayal v. CIT (1995) 214 ITR 801(SC) & CIT v. Durga Prasad More (1971) 82 ITR 540 (SC). 3. Whether

MEWAR HOSPITAL PVT. LTD. ,UDAIPUR vs. ACIT, CENTRAL CIRCLE-2, UDAIPUR

In the result the appeal of the assessee in ITA No

120/- made on account of discount allowed on this bills of patients for treatment. The Ld. CIT(A) ignored the principle of preponderance of human probability as laid down by Hon’ble SC in the case of Sumati Dayal v. CIT (1995) 214 ITR 801(SC) & CIT v. Durga Prasad More (1971) 82 ITR 540 (SC). 3. Whether

MEWAR HOSPITAL PVT. LTD. ,UDAIPUR vs. ACIT, CENTRAL CIRCLE-2, UDAIPUR

In the result the appeal of the assessee in ITA No

120/- made on account of discount allowed on this bills of patients for treatment. The Ld. CIT(A) ignored the principle of preponderance of human probability as laid down by Hon’ble SC in the case of Sumati Dayal v. CIT (1995) 214 ITR 801(SC) & CIT v. Durga Prasad More (1971) 82 ITR 540 (SC). 3. Whether

ACIT, CENTRAL CIRCLE-2, UDAIPUR, UDAIPUR vs. M/S MEWAR HOSPITAL PVT. LTD., UDAIPUR

In the result the appeal of the assessee in ITA No

120/- made on account of discount allowed on this bills of patients for treatment. The Ld. CIT(A) ignored the principle of preponderance of human probability as laid down by Hon’ble SC in the case of Sumati Dayal v. CIT (1995) 214 ITR 801(SC) & CIT v. Durga Prasad More (1971) 82 ITR 540 (SC). 3. Whether