M/S TARUN CONSTRUCTION COMPANY,WARD NO.24, NEAR BHAGAT SINGH CHOWK, SURATGARH vs. CPC, BANGALORE/ ITO, WARD-1, SRIGANGANAGAR , SRIGANGANAGAR

In the result, appeals are dismissed

Bench: Shri Saktijit Dey, Vice- & Dr. Brr Kumar

v. Dilip Kumar & Co2018 (9) SCC 1, has held that (iii) If the words are ambiguous and open to two interpretations, the benefit of interpretation is given to the subject and there is nothing unjust in a taxpayer escaping if the letter of the law fails to catch him on account of the legislature's failure to express itself clearly

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

In the result, appeals of the Revenue are dismissed

section 41(1) of the Act are not satisfied in the present case. In the instant case, the appellant has adduced sufficient evidences to prove that he made the payments in subsequent assessment years as detailed above. In view of the factual and legal position as discussed above, it is held that the AO's action in treating

LUBI GEL LLP,JODHPUR vs. ADIT CPC, BENGALURU

In the result, all the appeals of the assessees are allowed

68 & 69/Jodh/2021 Assessment Years : 2018-19 & 2019-20 Lubi GEL LLP Vs. The DCIT, CPC Jodhpur Bangluru PAN NO: AAGFL1843E Appellant Respondent Assessee by : Smt. Raksha Birla, CA Revenue by : Smt. Monisha, JCIT DR Date of Hearing : 27.09.2021 Date of Pronouncement : 27.09.2021 आदेश/Order PER N.K. SAINI, VICE PRESIDENT These four appeals by different assessees are directed against the separate

LUBI GEL LLP,JODHPUR vs. DCIT,CPC, BENGALURU

In the result, all the appeals of the assessees are allowed

68 & 69/Jodh/2021 Assessment Years : 2018-19 & 2019-20 Lubi GEL LLP Vs. The DCIT, CPC Jodhpur Bangluru PAN NO: AAGFL1843E Appellant Respondent Assessee by : Smt. Raksha Birla, CA Revenue by : Smt. Monisha, JCIT DR Date of Hearing : 27.09.2021 Date of Pronouncement : 27.09.2021 आदेश/Order PER N.K. SAINI, VICE PRESIDENT These four appeals by different assessees are directed against the separate

C G TECHNOSOFT PVT. LTD.,JODHPUR vs. ASST. DIRECTOR OF INCOME TAX, BENGALURU

In the result, all the appeals of the assessees are allowed

68 & 69/Jodh/2021 Assessment Years : 2018-19 & 2019-20 Lubi GEL LLP Vs. The DCIT, CPC Jodhpur Bangluru PAN NO: AAGFL1843E Appellant Respondent Assessee by : Smt. Raksha Birla, CA Revenue by : Smt. Monisha, JCIT DR Date of Hearing : 27.09.2021 Date of Pronouncement : 27.09.2021 आदेश/Order PER N.K. SAINI, VICE PRESIDENT These four appeals by different assessees are directed against the separate

C.G. TECHNOSOFT PVT. LTD. ,JODHPUR vs. ITO, WARD-3(1), , JODHPUR

In the result, all the appeals of the assessees are allowed

68 & 69/Jodh/2021 Assessment Years : 2018-19 & 2019-20 Lubi GEL LLP Vs. The DCIT, CPC Jodhpur Bangluru PAN NO: AAGFL1843E Appellant Respondent Assessee by : Smt. Raksha Birla, CA Revenue by : Smt. Monisha, JCIT DR Date of Hearing : 27.09.2021 Date of Pronouncement : 27.09.2021 आदेश/Order PER N.K. SAINI, VICE PRESIDENT These four appeals by different assessees are directed against the separate

ITO, WARD, PHALODI, PHALODI vs. M/S RAMA ALLURE LLP, JODHPUR

In the result, appeal of the revenue is dismissed

Bench: The Date, The Appeal Is Finally Heard.”

section 68 of the Act. We have reproduced relevant part of Para 7 of the judgement of Tribunal: 7......It has also proved the capacity of the creditors by showing that the amounts were received by the assessee by account payee cheques drawn from bank accounts of the creditors and the assessee is not expected to prove the genuineness

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

In the result, appeal of the assessee is dismissed

36,65,110/-.\nIf some shares were purchased @ 15.93 per share, some other shares may have been\npurchased on higher rate as well as some on lower rate. Some shares were sold at lower\nrate and some on higher rate. Shares were purchased and sold on different dates on\ndifferent rates. When the AO has total purchase and sale price

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-

36. That it is further for your kind consideration that out of total sales as mentioned above the cash sale for the period of demonetisation is Rs 1,62,35,737/- (HS Diesel) and Rs 25,74,870/- (MS Petrol) totaling to Rs 1,88,10,607/-. These details can be verified from the Annexure1 attached herewith. (ii) Verification

DCIT, CIRCLE, BHILWARA vs. SHRI PRAHALAD RAI RATHI, BHILWARA

In the result, the appeal of the Revenue is dismissed

Bench: Shri B. R. Baskaran & Dr. S. Seethalakshmithe Dcit Vs Shri Prahalad Rai Rathi Circle Prop: M/S.Kedar Mal Radhey Shyam, Bhiwlara Sadar Bazar, Gulabpura, Bhilwara (Appellant) (Respondent) Pan No. Adxpr 0949 R

v. India Tyre House 72 TTJ 316 (Gau), CIT vs. Heerala Chaganlal 257 ITR 281 (Raj.), CIT vs Ajay Kumar Sharma 259 ITR 240 (Raj.) and Jhalani Timbers v/s CIT (1997) 223 ITR 11 (Gau). Hence the ld CIT(A) rightly deleted the addition of Rs. 1,47,01,596/- u/s 68.’’ 11 DCIT-CIRCLE, BHILWARA VS SHRI PRAHALAD

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

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

MANGILAL DATLA,BANSWARA vs. INCOME TAX OFFICER, WARD BANSWARA, BANSWARA

In the result, the appeal filed by the assessee is allowed, both on legal issue\nas well as on facts

68—CIT(A) confirmed reassessment and addition made by AO of share capital\nand unexplained cash credit—Held, notice u/s 148 could be quashed if ‘belief' was not bona fide\nor one based on vague, irrelevant and non-specific information—Basis of belief should be\ndiscernible from material on record which was available with AO when he recorded reasons—\nThere

LAKHPAT TRADING AND INDUSTRYS PVT. LTD.,JODHPUR vs. ACIT, CIRCLE-3, JODHPUR

In the result, the appeal of the assessee is allowed

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Blelakhpat Trading & Acit, Circle-3 Industryspvt. Ltd. Jodhpur G-72/73 79/80, 1St Phase, Boranada, Jodhpur - 342001 Pan No. Aaccl 5668 C Assessee By Shri Rajendra Jain, Advocate & Smt. Raksha Birla, Ca (Physical) Smt. Runi Pal, Cit-Dr (Virtual) Revenue By Date Of Hearing 29.01.2026. Date Of Pronouncement 26.02.2026. Order Dr. Mitha Lal Meena, A.M.: This Appeal Is Filed By Assessee Against The Order Of National Faceless Appeal Centre, Delhi [Hereinafter Referred To As Nfac/ Cit(A)] Dated 26.06.2025 With Respect To Assessment Year 2017-18 Challenging Therein The Rejection Of Its Books Of Accounts U/S 145(3), Estimation Of Income & Reducing Genuine Sales.

68 of Rs. 1,11,60,612/- and further addition u/s 69C of Rs. 3,34,818/- to the return of income of the assessee. 5. The assessee being aggrieved with the assessment order preferred an appeal before the Ld CIT(A) who has confirmed the finding of the AO by observing as under: “From the contents of the assessment

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

36) against the order of CIT(Appeals)-1 Udaipur. (1) I, Neeraj Paliwal Prop of M/s Paliwal Departmental Store aged about 52 years, son of Mr. Basanti Lalji Paliwal identified by PAN ADXPP3119P at present residing at Address Plot No.2 Kishore Nagar Extn. Scheme, Near LIC Office, Kankroli, Rajsamand do solemnly affirm and state on oath as under: (2) That

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

36) against the order of CIT(Appeals)-1 Udaipur. (1) I, Neeraj Paliwal Prop of M/s Paliwal Departmental Store aged about 52 years, son of Mr. Basanti Lalji Paliwal identified by PAN ADXPP3119P at present residing at Address Plot No.2 Kishore Nagar Extn. Scheme, Near LIC Office, Kankroli, Rajsamand do solemnly affirm and state on oath as under: (2) That

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

36) against the order of CIT(Appeals)-1 Udaipur. (1) I, Neeraj Paliwal Prop of M/s Paliwal Departmental Store aged about 52 years, son of Mr. Basanti Lalji Paliwal identified by PAN ADXPP3119P at present residing at Address Plot No.2 Kishore Nagar Extn. Scheme, Near LIC Office, Kankroli, Rajsamand do solemnly affirm and state on oath as under: (2) That

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

36) against the order of CIT(Appeals)-1 Udaipur. (1) I, Neeraj Paliwal Prop of M/s Paliwal Departmental Store aged about 52 years, son of Mr. Basanti Lalji Paliwal identified by PAN ADXPP3119P at present residing at Address Plot No.2 Kishore Nagar Extn. Scheme, Near LIC Office, Kankroli, Rajsamand do solemnly affirm and state on oath as under: (2) That

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

36) against the order of CIT(Appeals)-1 Udaipur. (1) I, Neeraj Paliwal Prop of M/s Paliwal Departmental Store aged about 52 years, son of Mr. Basanti Lalji Paliwal identified by PAN ADXPP3119P at present residing at Address Plot No.2 Kishore Nagar Extn. Scheme, Near LIC Office, Kankroli, Rajsamand do solemnly affirm and state on oath as under: (2) That