RAJ KUMARI SINGHAL,MOUNT ABU vs. DCIT, CENTRAL CIRCLE-1, JODHPUR

In the result, the appeals of assessee bearing ITA Nos

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

68 of the Income-tax Act, 1961 without considering the fact that the admission of the assessee was based upon the seized documents and was obtained without any coercion whatsoever. Further, the retraction of surrender was made after elapse of six months and indicates to afterthought 5. The appellant craves leave or reserves right to amend, modify, alter

SANJAY SINGHAL,MOUNT ABU vs. DCIT, CENTRAL CIRCLE-1, JODHPUR

In the result, the appeals of assessee bearing ITA Nos

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

68 of the Income-tax Act, 1961 without considering the fact that the admission of the assessee was based upon the seized documents and was obtained without any coercion whatsoever. Further, the retraction of surrender was made after elapse of six months and indicates to afterthought 5. The appellant craves leave or reserves right to amend, modify, alter

DCIT, CENTRAL CICLE-1, JODHPUR vs. SANJAY SINGHAL, MOUNT ABU

In the result, the appeals of assessee bearing ITA Nos

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

68 of the Income-tax Act, 1961 without considering the fact that the admission of the assessee was based upon the seized documents and was obtained without any coercion whatsoever. Further, the retraction of surrender was made after elapse of six months and indicates to afterthought 5. The appellant craves leave or reserves right to amend, modify, alter

RAJKUMARI SINGHAL,MOUNT ABU vs. DCIT,. CENTRAL CIRCLE-1, JODHPUR

In the result, the appeals of assessee bearing ITA Nos

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

68 of the Income-tax Act, 1961 without considering the fact that the admission of the assessee was based upon the seized documents and was obtained without any coercion whatsoever. Further, the retraction of surrender was made after elapse of six months and indicates to afterthought 5. The appellant craves leave or reserves right to amend, modify, alter

SANJAY SINGHAL,MOUNT ABU vs. DCIT, CENTRAL CIRCLE-1, JODHPUR

In the result, the appeals of assessee bearing ITA Nos

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

68 of the Income-tax Act, 1961 without considering the fact that the admission of the assessee was based upon the seized documents and was obtained without any coercion whatsoever. Further, the retraction of surrender was made after elapse of six months and indicates to afterthought 5. The appellant craves leave or reserves right to amend, modify, alter

RAJKUMARI SINGHAL,MOUNT ABU vs. DCIT,. CENTRAL CIRCLE-1, JODHPUR

In the result, the appeals of assessee bearing ITA Nos

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

68 of the Income-tax Act, 1961 without considering the fact that the admission of the assessee was based upon the seized documents and was obtained without any coercion whatsoever. Further, the retraction of surrender was made after elapse of six months and indicates to afterthought 5. The appellant craves leave or reserves right to amend, modify, alter

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

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

68, Section 69A, Section 69B, Section 69C or any other provisions of the Act. It is not the case of the Revenue that the Petitioner has paid any cash to the so-called accommodation entry provider to obtain the accommodation entry to plough back own funds, hence, there is no ground/material to form reasonable belief

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

68, Section 69A, Section 69B, Section 69C or any other provisions of the Act. It is not the case of the Revenue that the Petitioner has paid any cash to the so-called accommodation entry provider to obtain the accommodation entry to plough back own funds, hence, there is no ground/material to form reasonable belief

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

68, Section\n69A, Section 69B, Section 69C or any other provisions of the Act. It is not the case of the\nRevenue that the Petitioner has paid any cash to the so-called accommodation entry\nprovider to obtain the accommodation entry to plough back own funds, hence, there is\nno ground/material to form reasonable belief

SHRI BHANWAR LAL,JODHPUR vs. DCIT, CENTRAL CIRCLE-1, JODHPUR

In the result the appeals of the assessee ITA Nos

Bench: Shri Mitha Lal Meena & Shri Anikesh Banerjee

68 of the Act. Similar support flows from Dr. Raj Dhariwal (supra) & Jagdish Narayan Ratan Kumar (supra), wherein the Tribunal held that a surrender under section 132

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

In the result, the appeal is dismissed

68 and 69C. 3. It is therefore, requested to quash the assessment order and /or delete the additions." 2. The brief facts of the case are that the assessee is an Individual, derives income from business and profession and other sources. During the year under consideration the assessee filed her return of income in ITR-4 declaring income from business

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

68, Section 69A, Section 69B, Section 69C or any other provisions of the Act. It is not the case of the Revenue that the Petitioner has paid any cash to the so-called accommodation entry provider to obtain the accommodation entry to plough back own funds, hence, there is no ground/material to form reasonable belief

TARUN MURADIA,UDAIPUR vs. DCIT CENTRAL CIRCLE-1 UDAIPUR, UDAIPUR

In the result, the appeal filed by the assessee is partly allowed

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

68 on account of increase in share capital which was upheld by CIT(A) was not justified 2.2In the case of PCIT v/s MeetaGutgutia Prop. Ferns Patel &Ors 395 ITR 526(Del) held Search and Seizure—New scheme of assessment in search cases—Validity of invocation of Section 153A—On basis of documents recovered during search and seizure

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

68 of the Act.” 3.4 Thus, in this case, since the assessee has failed to prove creditworthiness of Mr.Mangilal Gurjar and Mr.Naresh Trivedi, inter-alia failed to prove genuineness of the transaction respectfully following the Hon'ble Supreme Court (supra) we uphold the addition of Rs.4 lakhs. Accordingly, Ground No.2 of the assessee is dismissed. 4. Ground No.1

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

68 of the Act.” 3.4 Thus, in this case, since the assessee has failed to prove creditworthiness of Mr.Mangilal Gurjar and Mr.Naresh Trivedi, inter-alia failed to prove genuineness of the transaction respectfully following the Hon'ble Supreme Court (supra) we uphold the addition of Rs.4 lakhs. Accordingly, Ground No.2 of the assessee is dismissed. 4. Ground No.1

SMT. PUSHPA CHHAJER,JODHPUR vs. ACIT,CIRCLE-1, JODHPUR

In the result, appeal of the assessee is partly allowed

68, where any sum is found credited in the books of the assessee for any previous year, the same may be charged to income-tax as the income of the assessee of that previous year if the explanation offered by the assessee about the nature and source thereof is in the opinion of the Assessing Officer, not satisfactory. In such

BHOOP SINGH POONIA,NOHAR vs. ITO WARD, NOHAR, NOHAR

132(4) of\nthe Income-tax Act enables the authorised officer to examine a person on oath\nand any statement made by such person during such examination can also be\nused in evidence under the Income-tax Act. On the other hand, whatever\nstatement is recorded under section 133A of the Income-tax Act it is not given\nany

INDU BALA PORWAL,UDAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRE CIRCLE-1, UDAIPUR, UDAIPUR

In the result, ground no 5, 9 and 11 appeal is also allowed in favor as indicated above

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

132 taxmann.com 41 (Delhi - Trib.) Gambhir Silk Mills v. ACIT [2011] 45 SOT 20 (Ahmedabad-Trib.) of Senate v. Deputy Commissioner of Income Tax, CC - 1(3), Bangalore [2016] 68 taxmann.com 223 (Bangalore - Trib.) 36. The Ld. AR of the Assessee has also drawn our attention to the fact that no satisfaction u/s 153C of the Act was recorded