DAWOODI BOHRA JAMAT,UDAIPUR vs. ITO WARD EXEMPTION UDAIPUR, UDAIPUR

In the result, appeal of the assessee is allowed

Bench: DR. MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

section 147 and 151 and accordingly notice u/s 148 was issued to assessee— Proceedings u/s 147/148 were initiated after recording reasons on basis of information received from Investigation Wing of Department on basis of search and seizure operation. During course of assessment proceedings, assessee was specifically asked to explain and justify transaction with G received as share application money/share capital

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

reassessment proceeding was valid, it has only to be seen by the AO, whether there is prima facie some material on the basis of which the AO could re-open the case. Thus, the sufficiency of the correctness of the material is nothing to be considered as to this stage of the recording reasons for the reopening of the assessment

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

reassessment proceeding was valid, it has only to be seen by the AO, whether there is prima facie some material on the basis of which the AO could re-open the case. Thus, the sufficiency of the correctness of the material is nothing to be considered as to this stage of the recording reasons for the reopening of the assessment

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

reassessment proceeding was valid, it has only to be seen by the AO, whether there is prima facie some material on the basis of which the AO could re-open the case. Thus, the sufficiency of the correctness of the material is nothing to be considered as to this stage of the recording reasons for the reopening of the assessment

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

reassessment proceeding was valid, it has only to be seen by the AO, whether there is prima facie some material on the basis of which the AO could re-open the case. Thus, the sufficiency of the correctness of the material is nothing to be considered as to this stage of the recording reasons for the reopening of the assessment

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

reassessment proceeding was valid, it has only to be seen by the AO, whether there is prima facie some material on the basis of which the AO could re-open the case. Thus, the sufficiency of the correctness of the material is nothing to be considered as to this stage of the recording reasons for the reopening of the assessment

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

reassessment proceeding was valid, it has only to be seen by the AO, whether there is prima facie some material on the basis of which the AO could re-open the case. Thus, the sufficiency of the correctness of the material is nothing to be considered as to this stage of the recording reasons for the reopening of the assessment

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)

u/s 147 may kindly be declared as erroneous and void ab initio. 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

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)

u/s 147 may kindly be declared as erroneous and void ab initio. 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

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

In the result, both appeals of the assessee are allowed

reassessment proceedings an invalid........” iv] On the identical facts the Hon’ble ITAT Agar Bench in the case of Shri. Raj Singh Vs ITO (ITAT Agra) ITA No. 408/Agra/2018 Date of Order : 22/03/2019 "29. The text of the reasons recorded do proves that virtually there has been no application of mind by the learned Assessing officer so as to form

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

In the result, both appeals of the assessee are allowed

reassessment proceedings an invalid........” iv] On the identical facts the Hon’ble ITAT Agar Bench in the case of Shri. Raj Singh Vs ITO (ITAT Agra) ITA No. 408/Agra/2018 Date of Order : 22/03/2019 "29. The text of the reasons recorded do proves that virtually there has been no application of mind by the learned Assessing officer so as to form

M.P. POONIA,JODHPUR vs. ITO, BIKANER

In the result, the appeal of the assessee is allowed

21 and 22 of the appeal order dated 27.9.2018 and in para 2 (5) at page 3 and 4 of the appeal order dated 22.10.2019, has accepted/not disputed that against the estimated house hold expenditure of Rs. 3,60,000/- by the AO, the assessee has declared withdrawals of Rs. 3,91,585/- for house hold expenditure.” 3. Brief facts

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

21,000/-, Workman and staff welfare expenses of Rs. 1,23,000/- and interest on service tax of Rs. 15,586/-. The ld. CIT(A) has partially allowed the appeal. 5 622/Jodh/2024 & Others Assessment Years 2012-13 to 2017-18 2014-15 28.12.2016 53,48,580/- 5,20,280 Wages discussed in assessment order. The ld. AO made lump

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

21,000/-, Workman and staff welfare expenses of Rs. 1,23,000/- and interest on service tax of Rs. 15,586/-. The ld. CIT(A) has partially allowed the appeal. 5 622/Jodh/2024 & Others Assessment Years 2012-13 to 2017-18 2014-15 28.12.2016 53,48,580/- 5,20,280 Wages discussed in assessment order. The ld. AO made lump

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

21,000/-, Workman and staff welfare expenses of Rs. 1,23,000/- and interest on service tax of Rs. 15,586/-. The ld. CIT(A) has partially allowed the appeal. 5 622/Jodh/2024 & Others Assessment Years 2012-13 to 2017-18 2014-15 28.12.2016 53,48,580/- 5,20,280 Wages discussed in assessment order. The ld. AO made lump

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

21,000/-, Workman and staff welfare expenses of Rs. 1,23,000/- and interest on service tax of Rs. 15,586/-. The ld. CIT(A) has partially allowed the appeal. 5 622/Jodh/2024 & Others Assessment Years 2012-13 to 2017-18 2014-15 28.12.2016 53,48,580/- 5,20,280 Wages discussed in assessment order. The ld. AO made lump

JS ENGINEERING WORKS,SAWA, CHITTORGARH vs. DCIT, 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

21,000/-, Workman and staff welfare expenses of Rs. 1,23,000/- and interest on service tax of Rs. 15,586/-. The ld. CIT(A) has partially allowed the appeal. 5 622/Jodh/2024 & Others Assessment Years 2012-13 to 2017-18 2014-15 28.12.2016 53,48,580/- 5,20,280 Wages discussed in assessment order. The ld. AO made lump

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

21,000/-, Workman and staff welfare expenses of Rs. 1,23,000/- and interest on service tax of Rs. 15,586/-. The ld. CIT(A) has partially allowed the appeal. 5 622/Jodh/2024 & Others Assessment Years 2012-13 to 2017-18 2014-15 28.12.2016 53,48,580/- 5,20,280 Wages discussed in assessment order. The ld. AO made lump