SAGAR JEWELLERS,PORBANDAR vs. DCIT, CIRCLE-2(1), JAMNAGAR
In the result, the appeal of the assessee is allowed
ITA 222/RJT/2024[2019-2020]Status: DisposedITAT Rajkot01 Jan 2025AY 2019-2020
Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.222/Rjt/2024 ("नधा"रण वष" / Assessment Year: (2019-20) (Hybrid Hearing) Sagar Jewellers Vs. Dcit Zaveri Bazar, Porbandar, Gujarat Circle-2(1), Jamnagar 360575 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Adbfs5410L (Assessee) (Respondent) Assessee By : Shri K. C. Thaker, Ar Respondent By : Shri Sanjay Punglia, Cit.Dr Date Of Hearing : 01/10/2024 Date Of Pronouncement : 01/01/2025 आदेश / O R D E R Per Dr. A. L. Saini, Am: By Way Of This Appeal, The Assessee Has Challenged The Correctness Of The Order Passed By The Learned Principal Commissioner Of Income Tax (In Short ‘The Pcit’), Under Section 263 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’), Dated 21.02.2024, For The Assessment Year (In Short ‘A.Y.’) 2019-20. 2. The Grievances Raised By The Assessee Are As Follows:
For Appellant: Shri K. C. Thaker, ARFor Respondent: Shri Sanjay Punglia, CIT.DR
Section 115BSection 133ASection 143(3)Section 263Section 69
Section 68 and 69D of the Act, are deeming provision, where no doubt, the source of investment is to be explained, however, there was no question before the assessing officer about the ‘source’, and rather the assessing officer did not raise this issue about the ‘source’ of investment.
12. We have heard both sides in detail and also perused