DCIT, CENTRAL CIRCLE-1, UDIPUR vs. M/S. WAGAD CONSTRUTION COMPANY, UDAIPUR

In the result, appeals of the Revenue are dismissed

68 of the Act as the AO himself did not specify the section under which he intended to make the addition. The ld. A/R further relied on the judgment of Hon’ble Punjab & Haryana High Court in the case of G.P. International Ltd. 325 ITR 25 (P&H) wherein it is held that “ provisions of section 41 cannot

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

In the result, both appeals of the assessee are allowed

5,00,000) may not be treated as unexplained credits and may not be added to his total income as per Provisions of Section 68 of the Act. In response, the A.R. of the assessee vide his written submissions dated 22.03.2016 has submitted as under: - o"kZ ds nkSjku fy;k x;k Unsecured Loans

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

In the result, both appeals of the assessee are allowed

5,00,000) may not be treated as unexplained credits and may not be added to his total income as per Provisions of Section 68 of the Act. In response, the A.R. of the assessee vide his written submissions dated 22.03.2016 has submitted as under: - o"kZ ds nkSjku fy;k x;k Unsecured Loans

ACIT, CENTRAL CIRCLE, BIKANER vs. M/S. MANOJ KUMAR VIPIN KUMAR , BIKANER

In the result, this appeal of the Revenue is dismissed

Bench: Shri Sandeep Gosain & Shri Manoj Kumar Aggarwala.C.I.T. Vs. M/S Manoj Kumar Vipin Kumar, Central Circle, 118, New Dhan Mandi, Bikaner. Bikaner. Pan No. Aarfm 0027 E

5,86,612/- on this transaction which is accepted by the AO, then the AO again cannot consider the same as the own transaction of the assessee so as to presume hypothetical profit and make addition for the same. Considering the totality of facts and circumstances of the case and the decisions of the Hon’ble Courts

SITA DEVI CHOUDHARY,AHORE JALORE vs. INCOME TAX OFFICER, JALORE

In the result, stands allowed

Bench: The Cit(A) Challenging The Additions Made By The Ao. The Ld.Cit(A) Upheld Both The Additions Made By Observing-

68. (5) That the assessee had made available all the relevant documents as required by the assessing authority while replying to the adjudication proceedings under section 143(3) of the Income Tax Act 1961 and the same had been duly acknowledged by the assessing authority while passing order u/s 143(3) s under – (6) That it is further

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

In the result, appeal of the assessee is dismissed

10,190/-, with a difference/profit of Rs. 1,41,428/-. This is just\narbitrary, malafide and illegal calculation of profit made by the AO by taking purchase\nprice of whole purchase @ 15.93. There might be so many other purchase prices as well\nas sale prices of shares sold on different dates. Why the AO chose this particular price, is\nonly

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)

5. The core grievance of the assessee pertains to the legality of the reopening of the assessment and the additions made under section 68 and section 69C. The assessee’s principal argument is that the reasons recorded by the AO for initiating proceedings under section 147 were vague, mechanical, and based entirely on information received from

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)

5. The core grievance of the assessee pertains to the legality of the reopening of the assessment and the additions made under section 68 and section 69C. The assessee’s principal argument is that the reasons recorded by the AO for initiating proceedings under section 147 were vague, mechanical, and based entirely on information received from

MR. NEERAJ PALIWAL,RAJSAMAND vs. ITO, WARD-2, RAJSAMAND

In the result, all these appeals of the assessee are allowed

Bench: Shri Sandeep Gosain & Shri Vikram Singh Yadav

5 of the Limitation Act. Since the section is not a matter of right for the party who pleads the condonation, but it depends on the discretion of the court. The court must be satisfied that the delay is caused due to a genuine reason. It is sufficiency of the cause which counts, and not length of delay - Expression

MR. NEERAJ PALIWAL,RAJSAMAND vs. ITO, WARD-2, RAJSAMAND

In the result, all these appeals of the assessee are allowed

Bench: Shri Sandeep Gosain & Shri Vikram Singh Yadav

5 of the Limitation Act. Since the section is not a matter of right for the party who pleads the condonation, but it depends on the discretion of the court. The court must be satisfied that the delay is caused due to a genuine reason. It is sufficiency of the cause which counts, and not length of delay - Expression

MR. NEERAJ PALIWAL,RAJSAMAND vs. ITO, WARD-2, RAJSAMAND

In the result, all these appeals of the assessee are allowed

Bench: Shri Sandeep Gosain & Shri Vikram Singh Yadav

5 of the Limitation Act. Since the section is not a matter of right for the party who pleads the condonation, but it depends on the discretion of the court. The court must be satisfied that the delay is caused due to a genuine reason. It is sufficiency of the cause which counts, and not length of delay - Expression

MR. NEERAJ PALIWAL,RAJSAMAND vs. ITO, WARD-2, RAJSAMAND

In the result, all these appeals of the assessee are allowed

Bench: Shri Sandeep Gosain & Shri Vikram Singh Yadav

5 of the Limitation Act. Since the section is not a matter of right for the party who pleads the condonation, but it depends on the discretion of the court. The court must be satisfied that the delay is caused due to a genuine reason. It is sufficiency of the cause which counts, and not length of delay - Expression

MR. NEERAJ PALIWAL,RAJSAMAND vs. ITO, WARD-2, RAJSAMAND

In the result, all these appeals of the assessee are allowed

Bench: Shri Sandeep Gosain & Shri Vikram Singh Yadav

5 of the Limitation Act. Since the section is not a matter of right for the party who pleads the condonation, but it depends on the discretion of the court. The court must be satisfied that the delay is caused due to a genuine reason. It is sufficiency of the cause which counts, and not length of delay - Expression

RANJEET SHARMA,RAWATSAR vs. ITO, WARD NOHAR,, HANUMANGARH

In the result, the appeal of the assessee is allowed

10. It is noted that during the year under consideration, the total income of the assessee was only Rs.1,44,430/- plus agricultural income of Rs.70,000/-. Therefore, the assessee had not filed the Income Tax Return. Subsequently, the AO issued notice u/s. 148 on 17-03-2016. In response to notice u/s. 148 of the Act, the assessee filed

BADAMI DEVI ,BARMER vs. ITO, WARD-1, BARMER

In the result, the appeal of the assessee is allowed

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Blebadami Devi Income Tax Officer, M/S Sbl & Co Llp Ward No. -1 Barmer. (Chartered Accountant) E-75, Kalpatru Shopping Center, Opp. Bioscope Cinemas, Shastri Nagar, Jodhpur, Rajasthan–342003. Pan No. Aaopd1969R Assessee By Shri Gautam Chand Baid, Ca (Physical) 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 Filed By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), Addl/Jcit (A) Panaji, [Hereinafter Referred To As The Jcit (A)] Dated 28.06.2024 With Respect To Assessment Year 2017-18. 2 2. The Appellant Assessee Has Taken Following Grounds Of Appeal:-

5 given by the Assessee was not acceptable and reliable by the AO, then he/she should give detailed reasoning not only in the Assessment order but communicate such reasoning with Assessee prior to framing the Assessment. In the present case this SOP is grossly violated by the AO which led the Assessment order void-ab-initio, being passed in violation

M/S BHAGIRATH DAIRY PRIVATE LIMITED,NAGAUR vs. ASSISTANT COMMISSIONER OF INCOME TAX,, NAGAUR

The appeal is allowed

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Ble

section 68 of the act and and added to the income of the assessee. In addition to the cash-credits, the AO has further made addition of Rs. 8,56,000/- u/s 69A of the by treating the deposit in the name of Sh. Mohan Ram Choudhary and Smt.Tulchi Devi of Rs. 5

MANOHAR SINGH,JODHPUR vs. ITO, WARD-1(3),, JODHPUR

In the result, the appeal of the assessee is partly allowed

Section 271(1)(b) and 271(1)(c) of the Act being premature at this stage, both the grounds are dismissed. 6. The ground No. 7 raised by the appellant is regarding charging of interest amounting to Rs. 24,49.836/- u/s 234B of the Act. This being consequential in nature, the AO is directed to allow relief

M/S. PRATIK METALS PVT. LTD.,JODHPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, JODHPUR

In the result, appeal of the assessee is allowed

Bench: Shri R.C.Sharma & Shri Sandeep Gosainm/S Prateek Metals Pvt. Ltd. Vs Pr. Commissioner Of Income E-74, Marudhar Ind. Area, Tax-1, Basni-Ii, Jodhpur. Jodhpur.

68 and Section 56(2)(viib) were applicable only from A.Y. 2013-14. Such a view cannot be said to be erroneous or prejudicial to the interest of Revenue. 5. The impugned order U/s 263 is illegal and most unjustified, as the same is not based on any valid material or legal evidence whatsoever on records, but the same