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

In the result, both appeals of the assessee are allowed

56 DTR 0212 the Hon’ble Gujarat High Court held that: “Where the reasons recorded reflect that the matter requires detailed investigation and further verification, the AO has reason to suspect and not reason to believe that income chargeable to tax has escaped assessment and therefore, the assumption of jurisdiction by the AO is invalid and as such, the impugned

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

56 i.e.\nother sources. It may be worthwhile to mention that when in the Act for every\nadditions, the provisions or section has been provided by the legislature,\notherwise there shall be no meaning of the Act. Hence the addition is wrongly\nmade against the Act . (vide page 21-22 of the order).”\nThe same has also been held

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

In the result, appeals of the assessee are partly allowed

56 i.e.\nother sources. It may be worthwhile to mention that when in the Act for every\nadditions, the provisions or section has been provided by the legislature,\notherwise there shall be no meaning of the Act. Hence the addition is wrongly\nmade against the Act . (vide page 21-22 of the order).”\nThe same has also been held

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

56 i.e.\nother sources. It may be worthwhile to mention that when in the Act for every\nadditions, the provisions or section has been provided by the legislature,\notherwise there shall be no meaning of the Act. Hence the addition is wrongly\nmade against the Act . (vide page 21-22 of the order).”\nThe same has also been held

ACIT, PAOTA C ROAD vs. VARAHA INFRA LIMITED, PAOTA B ROAD

In the result, the appeal of the revenue is dismissed

Bench: Dr. S. Seethalakshmi & Shri Rathod Kamlesh Jayantbhaithe Acit Vs M/S. Vardha Infra Ltd. Room No. 215, Aayakar Bhawan 6 Jalam Vilas Scheme Paota C Road, Jodhpur Paota B Road, Jodhpur (Appellant) (Respondent) Pan No. Aaccv 7972 K

sections is mandatory but consequential to Income. The A O is directed to allow consequential relief to the assessee while giving effect to this appeal order. 9 The fifth ground of appeal is as under "The Ld. AO has erred in initiating penalty proceedings uis 274 and 271(1)(C) 9.1 The initiation of penalty is not appealable

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

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

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

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

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

56. In the light of the above said Apex court Decisions and the Panchanama provided herein, it is deemed appropriate to conclude that the notice provided under section 153C is bad in law.” 5. The Ld. DR supported and relied upon the orders of the revenue authorities. However, he was unable to rebut the judicial precedent cited and relied

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

56. In the light of the above said Apex court Decisions and the Panchanama provided herein, it is deemed appropriate to conclude that the notice provided under section 153C is bad in law.” 5. The Ld. DR supported and relied upon the orders of the revenue authorities. However, he was unable to rebut the judicial precedent cited and relied

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

56. In the light of the above said Apex court Decisions and the Panchanama provided herein, it is deemed appropriate to conclude that the notice provided under section 153C is bad in law.” 5. The Ld. DR supported and relied upon the orders of the revenue authorities. However, he was unable to rebut the judicial precedent cited and relied