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

147 of the\nIT Act was initiated in the current year for examining the escaped income of Rs. 19,94,80,684/-\n(Cash deposit of Rs. 19,77,80,000 + Business income of Rs. 16,77,283 + Receipt of Rs. 23,401\nu/s 194C). Accordingly, a notice under section 148 dated 08.03.2018 was issued in the name of\nnon

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

147 of the\nIT Act was initiated in the current year for examining the escaped income of Rs. 19,94,80,684/-\n(Cash deposit of Rs. 19,77,80,000 + Business income of Rs. 16,77,283 + Receipt of Rs. 23,401\nu/s 194C). Accordingly, a notice under section 148 dated 08.03.2018 was issued in the name of\nnon

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

147 of the\nIT Act was initiated in the current year for examining the escaped income of Rs. 19,94,80,684/-\n(Cash deposit of Rs. 19,77,80,000 + Business income of Rs. 16,77,283 + Receipt of Rs. 23,401\nu/s 194C). Accordingly, a notice under section 148 dated 08.03.2018 was issued in the name of\nnon

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

147 of the\nIT Act was initiated in the current year for examining the escaped income of Rs. 19,94,80,684/-\n(Cash deposit of Rs. 19,77,80,000 + Business income of Rs. 16,77,283 + Receipt of Rs. 23,401\nu/s 194C). Accordingly, a notice under section 148 dated 08.03.2018 was issued in the name of\nnon

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

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

80 ITR 467 — SC). The reopening should not be for investigations or finding out the probabilities of escaped income (79 ITR 603). In other words, the AO issued the notice u/s 148 only on suspicion. In other words, in the present case, the Ld. AO did not have any material, direct of circumstantial; to have any basis for his belief

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

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

In the result, both appeals of the assessee are allowed

80,350/- escaped assessment in terms of section 147 of the I.T. Act." d] Perusal of the reasons recorded it is reveals the ld AO wants to reopen the assessment only for verification of source of investment which was duly disclosed and recorded. The investment made by the appellant are duly recorded in the books of accounts and also reflected

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

In the result, both appeals of the assessee are allowed

80,350/- escaped assessment in terms of section 147 of the I.T. Act." d] Perusal of the reasons recorded it is reveals the ld AO wants to reopen the assessment only for verification of source of investment which was duly disclosed and recorded. The investment made by the appellant are duly recorded in the books of accounts and also reflected

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

80,02,865 23,54,759 2014-15 7,30,51,779 6,96,08,565 34,43,214 2015-16 10,40,76,946 7,59,08,853 2,81,68,093 6 622/Jodh/2024 & Others Assessment Years

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

80,02,865 23,54,759 2014-15 7,30,51,779 6,96,08,565 34,43,214 2015-16 10,40,76,946 7,59,08,853 2,81,68,093 6 622/Jodh/2024 & Others Assessment Years

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

80,02,865 23,54,759 2014-15 7,30,51,779 6,96,08,565 34,43,214 2015-16 10,40,76,946 7,59,08,853 2,81,68,093 6 622/Jodh/2024 & Others Assessment Years

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

80,02,865 23,54,759 2014-15 7,30,51,779 6,96,08,565 34,43,214 2015-16 10,40,76,946 7,59,08,853 2,81,68,093 6 622/Jodh/2024 & Others Assessment Years

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

80,02,865 23,54,759 2014-15 7,30,51,779 6,96,08,565 34,43,214 2015-16 10,40,76,946 7,59,08,853 2,81,68,093 6 622/Jodh/2024 & Others Assessment Years