OCHHAB LAL JAIN,UDAIPUR vs. DCIT, CENTRAL CIRCLE-1, UDIAPUR, UDAIPUR

In the result, both the appeals of the assessee are allowed

153A\nr.w.s. 143(3).Your honor firstly we relying upon our WS for A.Y. 2019-20(PB22-35), and\ncomments on the remand report available in the paper book(PB57-71). Hence for the facts,\nfigures, submissions and legal position the same may kindly be considered as our WS before\nyour honor. As in both the appeals, the Grounds

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

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

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

B,C and D. The interest so charged is being totally contrary to the\nprovision of law and on facts of the case and hence same may kindly be deleted in full .\n“Revised Ground No.3: Rs.1,14,89,554/-:-The ld. CIT(A) has grossly erred in law as\nwell as on the facts of the case in confirming

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

In the result, appeals of the assessee are partly allowed

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

b) From the above, it cannot be said that there is no corelation of the entries\nreflected in the seized Document No. 2 of Exhibit 64 as alleged by the\nassessee's AR because it can be seen from the various narrations made\ntherein are corroborated with entries made in Document No. 9 of Exhibit 68\nand assessee has duly

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)

Section 69A unless ownership is first established. Accordingly, the addition made is without proper foundation and deserves to be deleted. In support of the above contentions the reliance is placed on the following judicial precedents:  Mangilal Agarwal v. Assistant Commissioner of Income-tax [2007] 163 Taxman 399 (Rajasthan)  Sukhdayal Rambilas v. CIT [1982] 136 ITR 414 (Bom).  Salek Chand

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

153A of the Act. 2. At the outset, both the assessee and the revenue had filed the cross appeals by challenging the order of the ld. CIT(A). All the issues are common for both the parties. Accordingly, All the appeals are taken together, heard together and disposed of together for the sake of convenience ITA No. 111/Jodh/2022

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

153A of the Act. 2. At the outset, both the assessee and the revenue had filed the cross appeals by challenging the order of the ld. CIT(A). All the issues are common for both the parties. Accordingly, All the appeals are taken together, heard together and disposed of together for the sake of convenience ITA No. 111/Jodh/2022

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

153A of the Act. 2. At the outset, both the assessee and the revenue had filed the cross appeals by challenging the order of the ld. CIT(A). All the issues are common for both the parties. Accordingly, All the appeals are taken together, heard together and disposed of together for the sake of convenience ITA No. 111/Jodh/2022

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

153A of the Act. 2. At the outset, both the assessee and the revenue had filed the cross appeals by challenging the order of the ld. CIT(A). All the issues are common for both the parties. Accordingly, All the appeals are taken together, heard together and disposed of together for the sake of convenience ITA No. 111/Jodh/2022

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

153A of the Act. 2. At the outset, both the assessee and the revenue had filed the cross appeals by challenging the order of the ld. CIT(A). All the issues are common for both the parties. Accordingly, All the appeals are taken together, heard together and disposed of together for the sake of convenience ITA No. 111/Jodh/2022

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

153A of the Act. 2. At the outset, both the assessee and the revenue had filed the cross appeals by challenging the order of the ld. CIT(A). All the issues are common for both the parties. Accordingly, All the appeals are taken together, heard together and disposed of together for the sake of convenience ITA No. 111/Jodh/2022

ANJANA CONSTRUCTION,NIMBAHERA vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, UDAIPUR, UDAIPUR

In the result, revenue’s appeal bearing ITA No

Bench: Dr. Mitha Lal Meena & Shri Anikesh Banerjee

b) Address of the place from where asset / Udai Niwas, Bhanwar Mata document was seized Road, Chhoti Sadari (c) Description of relevant asset / document See Point No.6 6. The brief reasons/evidence on the basis of which the AO reached to the conclusion that the relevant seized asset/document belongs to the person in whose case action u/s 153C is proposed. Search

ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, UDAIPUR, UDAIPUR vs. ANJANA CONSTRUCTION, CHITTORGARH

In the result, revenue’s appeal bearing ITA No

Bench: Dr. Mitha Lal Meena & Shri Anikesh Banerjee

b) Address of the place from where asset / Udai Niwas, Bhanwar Mata document was seized Road, Chhoti Sadari (c) Description of relevant asset / document See Point No.6 6. The brief reasons/evidence on the basis of which the AO reached to the conclusion that the relevant seized asset/document belongs to the person in whose case action u/s 153C is proposed. Search

ANJANA CONSTRUCTION,NIMBAHERA vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, UDAIPUR, UDAIPUR

In the result, revenue’s appeal bearing ITA No

Bench: Dr. Mitha Lal Meena & Shri Anikesh Banerjee

b) Address of the place from where asset / Udai Niwas, Bhanwar Mata document was seized Road, Chhoti Sadari (c) Description of relevant asset / document See Point No.6 6. The brief reasons/evidence on the basis of which the AO reached to the conclusion that the relevant seized asset/document belongs to the person in whose case action u/s 153C is proposed. Search

OM PRAKASH BISHU,KUCHAMAN CITY vs. DCIT, JODHPUR

In the result, appeal of the assessee is allowed

68,920/- 2018-19 Rs. 1,29,46,152/- Rs. 4,61,80,190/- 2019-20 Rs. 12,04,359/- Rs. 42,96,065/- Total Investment (In Rs.) Rs. 2,51,44,716/- Rs. 8,96,93,660/- 3.1 For the year under consideration the ld. DVO estimated the value at Rs. 4,61,80,190/- and in the books

VISHNU GOYAL,JODHPUR vs. PR. CIT, CENTRAL, JAIPUR

In the result, both the appeals filed by the assessee are allowed

Bench: Shri B. R. Baskaran & Shri Sandeep Gosain

153A of the Act on 20.12.2019. (In the assessment order, the AO has mentioned the section as 143(3) r.w.s 153B(1)(a) of the Act). The Ld PCIT, upon examination of assessment records both the years, took the view that the assessing officer has not conducted proper enquiries/verification while passing the assessment orders. Accordingly, he initiated revision proceedings

VISHNU GOYAL,JODHPUR vs. PR. CIT, CENTRAL, JAIPUR

In the result, both the appeals filed by the assessee are allowed

Bench: Shri B. R. Baskaran & Shri Sandeep Gosain

153A of the Act on 20.12.2019. (In the assessment order, the AO has mentioned the section as 143(3) r.w.s 153B(1)(a) of the Act). The Ld PCIT, upon examination of assessment records both the years, took the view that the assessing officer has not conducted proper enquiries/verification while passing the assessment orders. Accordingly, he initiated revision proceedings