DCIT, CIRCLE-1, MUZAFFARPUR vs. M/S R.P.RAI ESTATE PVT LTD, PATNA
In the result, the appeal of the revenue is dismissed
ITA 28/PAT/2021[2017-18]Status: DisposedITAT Patna03 Apr 2024AY 2017-18
Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Bleassessment Year: 2017-18 Dcit, Circle-1, Muzaffarpur M/S. R.P. Rai Estate Pvt. Ltd. Vs 19, Goharua, Patliputra Colony, Patliputra, Patna- 800013. Pan: Aaccr 4972 P (Appellant) (Respondent) Present For: Appellant By : Shri Sushil Kumar Mishra, Jcit, Dr Respondent By : Shri Devesh Poddar, Advocate Date Of Hearing : 19.03.2024 Date Of Pronouncement : 03.04.2024 O R D E R Per Sonjoy Sarma, Jm: This Appeal Of The Revenue For The Assessment Year 2017-18 Is Directed Against The Order Dated 29.06.2020 Passed By The Ld. Commissioner Of Income-Tax (Appeal), Patna [Hereinafter Referred To As ‘The Ld. Cit(A)’].
For Appellant: Shri Sushil Kumar Mishra, JCIT, DRFor Respondent: Shri Devesh Poddar, Advocate
Section 143(2)
26 ITR 775 (S.C) where in Apex
Court has held that AO cannot make any addition on the account of his guess work without having any material evidence on record. The relevant extracts of the said judgment is reproduced as under:
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M/s. R.P. Rai Estate Pvt. Ltd.
A.Y. 2017-18
"that in making the assessment under sub-section