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

8. The Finance Act, 2021 had introduced the following amendment by bringing in Explanation 2 to section 36(1)(va) of the Act: “[Explanation 2.—For the removal of doubts, it is hereby clarified that the provisions of section 43B shall not apply and shall be deemed never to have been applied for the purposes of determining

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

8. The Finance Act, 2021 had introduced the following amendment by bringing in Explanation 2 to section 36(1)(va) of the Act: “[Explanation 2.—For the removal of doubts, it is hereby clarified that the provisions of section 43B shall not apply and shall be deemed never to have been applied for the purposes of determining

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

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

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

In the result, both appeals of the assessee are allowed

2,00,000/- 5 M/s Bhanwar Lal Lakhara, HUF, Nathdwara Rs. 4,00,000/- 6 Smt. Anita Devi Khandelwal, Nathdwara Rs. 1,50,000/- 7 Smt. Veena Devi Khandelwal, Nathdwara Rs. 5,00,000/- 8 Shri Natwar Lal Khandelwal, Nathdwara Rs. 1,50,000/- Total Rs. 22,00,000/- 4.3 During the course of statements of the above persons

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

In the result, both appeals of the assessee are allowed

2,00,000/- 5 M/s Bhanwar Lal Lakhara, HUF, Nathdwara Rs. 4,00,000/- 6 Smt. Anita Devi Khandelwal, Nathdwara Rs. 1,50,000/- 7 Smt. Veena Devi Khandelwal, Nathdwara Rs. 5,00,000/- 8 Shri Natwar Lal Khandelwal, Nathdwara Rs. 1,50,000/- Total Rs. 22,00,000/- 4.3 During the course of statements of the above persons

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

In the result, appeals of the Revenue are dismissed

2. The brief facts of the case are that the assessee is engaged in the business of excavation, transport and civil contract business, Ready Mix Concrete Manufacturing and allied activities. The assessee filed return of income on 23.11.2014 declaring total income of Rs. 29,02,210/-. The return of income was processed under section 143(1) of the Income

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

M/S. HANUMANGARH KENDRIYA SAHAKARI BANK LTD.,HANUMANGARH vs. ACIT, CIRCLE-2, BIKANER

In the result, the appeals filed by the appellant are allowed andthe order(s) of the Kerala High Court and other authorities to thecontrary are set aside

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

2(u) of theNABARD Act, 1981, it is clear that only a state co-operative bank wouldbe within the scope and meaning of a banking company under Section2(c) of the BR Act, 1949 on obtaining licence under Section 22 of thesaid Act. Conclusion: In the instant case, although the appellant society is an apex cooperative society within

M/S. HANUMANGARH KENDRIYA SAHAKARI BANK LTD.,HANUMANGARH vs. ACIT, CIRCLE-2, BIKANER

In the result, the appeals filed by the appellant are allowed andthe order(s) of the Kerala High Court and other authorities to thecontrary are set aside

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

2(u) of theNABARD Act, 1981, it is clear that only a state co-operative bank wouldbe within the scope and meaning of a banking company under Section2(c) of the BR Act, 1949 on obtaining licence under Section 22 of thesaid Act. Conclusion: In the instant case, although the appellant society is an apex cooperative society within

M/S. HANUMANGARH KENDRIYA SAHAKARI BANK LTD.,HANUMANGARH vs. ACIT, CIRCLE-2, BIKANER

In the result, the appeals filed by the appellant are allowed andthe order(s) of the Kerala High Court and other authorities to thecontrary are set aside

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

2(u) of theNABARD Act, 1981, it is clear that only a state co-operative bank wouldbe within the scope and meaning of a banking company under Section2(c) of the BR Act, 1949 on obtaining licence under Section 22 of thesaid Act. Conclusion: In the instant case, although the appellant society is an apex cooperative society within

M/S. HANUMANGARH KENDRIYA SAHAKARI BANK LTD.,HANUMANGARH vs. ACIT, CIRCLE-2, BIKANER

In the result, the appeals filed by the appellant are allowed andthe order(s) of the Kerala High Court and other authorities to thecontrary are set aside

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

2(u) of theNABARD Act, 1981, it is clear that only a state co-operative bank wouldbe within the scope and meaning of a banking company under Section2(c) of the BR Act, 1949 on obtaining licence under Section 22 of thesaid Act. Conclusion: In the instant case, although the appellant society is an apex cooperative society within

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

2,96,50,000/- by applying the provisions of Section 68. 3.Under the facts and circumstances of the case, the Learned CIT(A) has erred in confirming the action of the Learned Assessing Officer in making addition of Rs. 8

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)

2. That on the facts and in the circumstances of the case, the Ld. CIT (A) erred in sustaining the addition made by Ld. AO for Rs. 78,60,000/-treating the amount received towards subscription of share capital as unexplained cash credit. The addition so sustained may kindly be deleted. 3. That on the facts and in the circumstances

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)

2. That on the facts and in the circumstances of the case, the Ld. CIT (A) erred in sustaining the addition made by Ld. AO for Rs. 78,60,000/-treating the amount received towards subscription of share capital as unexplained cash credit. The addition so sustained may kindly be deleted. 3. That on the facts and in the circumstances

BANSI LAL KUMHAR,UDAIPUR vs. ACIT CIRCLE-2, UDAIPUR

68 on account of cash deposited in\nthe bank account during the year as unexplained money which has been\nconfirmed by the Ld. NFAC/CIT (A). The Ld. AO and CIT(A) both have not\nconsidered the vital facts and material available on record in true perspective\nand sense and thus, the addition so made by the Id. AO and confirmed

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:-

2. The appellant crave liberty to add, amend, alter, modify or delete any of the ground of appeal on or before its hearing before your honour. 3. The appellant prayed for the justice. 3. The soul issue challenged by the Assessee in this appeal is regarding upholding the addition of Rs. 19,00,000/- under Section 68 without appreciating

SUKHDEV CHAYAL,BIKANER vs. PCIT-1,, JODHPUR

In the result, this appeal of the assessee is allowed

Bench: Shri Sandeep Gosain & Shri Vikram Singh Yadavassessment Year: 2016-17 Sukhdev Chayal, Vs. Pr.Cit-1, Near Ratan Sagar Well, Jodhpur. Bikaner. Pan No. Afjpc 9250 J

8. 2,22,202 9. Land at Nokha 1... 85,038 10. Land & Building at Ratansagar Well 2,30,535 Land in JNV Colony (6A-38, 1/2 portion) 11. 17 ITA 26/Jodh/2021 Sukhdev Chayal Vs PCIT 5,777 Plot at Ganganagar 1 (1800 Sq. Ft) 12. 5,777 Piot at Ganganagar 2