M/S SHRI JEEN MATA BUILDCON PVT. LTD., JAIPUR v. INCOME TAX OFFICER, WARD-4-2, JAIPUR, Income Tax Appellate Tribunal, Judgment, Law, casemine.com

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Case Number

ITA 397/JPR/2019

Attorney(S)

Acts

u/s 143(1) of the Income Tax Act, 1961.

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Smart Summary

Factual and Procedural Background

This is an appeal (ITA No. 397/JP/2019) by the assessee M/s Shri Jeen Mata Buildcon Pvt. Ltd. against the order of the ld. CIT(A), Ajmer dated 24.01.2019 for Assessment Year 2013-14. The appeal was heard by the Income Tax Appellate Tribunal, Jaipur Bench ("SMC"), with hearing by video conference on 22/02/2022 and pronouncement on 08/03/2022. The panel comprised Dr. S. Seethalakshmi (Judicial Member) and Shri Rathod Kamlesh Jayantbhai (Accountant Member), and the order recorded by Rathod Kamlesh Jayantbhai, AM.

The assessee filed its return of income on 30.03.2015 declaring income of Rs. 5,21,007/-, which was processed under section 143(1). The case was selected for scrutiny via CASS because of differences between turnover as per Form 26AS and the books of account. In assessment, the Assessing Officer made additions on account of: (i) a difference of Rs. 18,78,750/- attributed to contract receipts from M/s Sidhi Vinayak Affordable Homes (26AS higher than books); (ii) a difference of Rs. 15,23,978/- in relation to M/s Bhairav Township Pvt. Ltd. derived from comparison of income offered and expenses booked across years; and (iii) an ad-hoc lump-sum disallowance of Rs. 2,00,000/- out of various expense heads (travelling, consumable, conveyance, diesel, staff welfare) on account of alleged self-made vouchers and suspected personal use. The ld. CIT(A) confirmed these additions/disallowance. The assessee appealed to the ITAT.

Legal Issues Presented

Whether the Assessing Officer could make upward additions to the assessee's income based on differences between Form 26AS and the books of account where the books were audited and not rejected under section 145(3) of the Income Tax Act?
Whether the lump-sum disallowance of Rs. 2,00,000/- from various expense heads was justified where vouchers and audited accounts were produced and no defects were recorded by the Assessing Officer?
Whether interest charged under sections 234A, 234B, 234C & 234D and withdrawal of interest under section 244A were correctly made (this ground was presented as consequential)?

Arguments of the Parties

Appellant's Arguments

The assessee maintained proper books of account audited under section 44AB; complete books, bills, vouchers, contract receipts and other registers were produced before the Assessing Officer during assessment proceedings (as admitted by the AO).
The books of account were not rejected under section 145(3); the settled position of law (as relied upon) is that if accounts are not rejected, no upward estimation of income is legally permissible. The assessee placed reliance on multiple decisions to support this proposition.
The difference between Form 26AS and books was explained and reconciled in a chart showing net variances across years and parties; the reconciliation showed that the amounts were matched over the period and the apparent year-to-year differences were explained by timing and accounting practices.
There was no material showing personal nature of the expenses or defects in vouchers to justify the lump-sum disallowance; comparative charts showed the contested expenses were not higher than in earlier years.

Respondent's (Revenue) Arguments

The Revenue relied on precedents (two principal decisions were mentioned) to support its position that adjustments based on 26AS or related enquiries could sustain additions; the ld. Departmental Representative urged sustaining the lump-sum disallowance as affirmed by AO and CIT(A).
The Revenue maintained that the AO's enquiries (including under section 133(6)) and the data in Form 26AS provided material for the additions made by the AO.

Table of Precedents Cited

Precedent	Rule or Principle Cited For	Application by the Court
M/s Bansilal Abirchand Spg. & Wvg. Mills, 75 ITR 260 (Bom)	Relied upon by the assessee in support of the proposition that if accounts are not rejected under section 145(3), no upward estimation of income is legally possible.	The decision was cited among several authorities relied on by the assessee to support the general legal proposition adopted by the Tribunal in setting aside additions based on 26AS differences when books were audited and not rejected.
CIT vs. Maharaja Shree Umaid Mills Ltd., 192 ITR 565 (Raj.)	Relied upon by the assessee for the proposition regarding non-permissibility of estimation when accounts are not rejected.	Cited by the assessee; the Tribunal treated the cluster of cited authorities as supporting the assessee's position and deleted the additions on that basis.
DCIT vs. Mewar Textile Mills Ltd., 21 Tax World 821 (JP)	Relied upon by the assessee for the same proposition concerning estimation and non-rejection of accounts.	Part of the body of precedent invoked by the assessee; Tribunal accepted the proposition in reaching its decision to delete the additions.
Mohd. Umer vs. CIT, 101 ITR 525	Relied upon by the assessee in support of non-estimation if accounts are not rejected.	Cited and considered as part of the assessee's reliance; Tribunal applied the general principle favorably to the assessee.
Ajanta Constructions (P.) Ltd. vs. ACIT, XXII TW 606 (ITAT Jaipur)	Relied upon by the assessee for the settled position regarding accounts and estimation.	Included among the authorities relied on by the assessee; Tribunal's reasoning reflects acceptance of the underlying principle.
DCIT vs. Associated Stone Industries (Kotah) Ltd., XXII TW 155 (JP)	Relied upon by the assessee for the proposition on estimation vis-à-vis non-rejected accounts.	Cited by the assessee and treated as supportive of the assessee's position by the Tribunal.
Ghewarchand vs. ITO, XXI TW 571	Relied upon by the assessee.	Cited by the assessee; formed part of the cited body of decisions relied upon to challenge the additions.
Siddheshwari Cotton Mills P. Ltd. vs. CIT, 117 ITR 953 at 957 (Cal)	Relied upon by the assessee regarding the limits of estimation when books are not rejected.	Included among the cases relied upon; Tribunal's conclusion aligns with the principle invoked.
ACIT vs. M/s Mount Malt Bru Ltd, 34 TW 246 (JP)	Relied upon by the assessee.	Part of the package of authorities cited by the assessee; the Tribunal's ultimate decision reflects the weight given to these authorities.
CIT vs. President Industries, (2002) 258 ITR 654 (Guj.)	Relied upon by the assessee for the proposition challenging estimation where accounts remain acceptable.	Cited by the assessee and considered in the Tribunal's view of the settled law invoked by the assessee.
CIT vs. Abhishek Corporation, (2000) 158 CTR 374 (Guj.)	Relied upon by the assessee.	Cited by the assessee; formed part of the authorities relied upon by the assessee and acknowledged in the Tribunal's reasoning.
ITO vs. Star Consortium, 127 Taxman 681 (Kol) (2021)	Relied upon by the assessee (listed among authorities).	Cited by the assessee; the Tribunal's decision did not reject the use of these authorities as supporting precedent for the assessee's position.
Rah Jajharia E to E JV [2017] ITA No. 1848/Kol/2017 (ITAT Kolkata)	Relied upon by the Revenue (first of two principal cases relied upon by Revenue).	The Tribunal noted the case relied upon by Revenue but observed that it related to different facts (mobilization advance / TDS credit context) and treated it as distinguishable on facts from the present matter.
Surendra S. Gupta [2018] 93 taxmann.com 456 (Mumbai Trib.)	Relied upon by the Revenue (second principal case relied upon by Revenue).	The Tribunal observed that this precedent was on different facts and therefore considered it distinguishable for the present controversy.

Court's Reasoning and Analysis

The Tribunal reviewed the record and the sequence of proceedings: the return filed and processed u/s 143(1), selection for scrutiny because of mismatch between books and Form 26AS, the AO's enquiries (including under section 133(6)) and the specific additions/disallowance made by the AO which were confirmed by the ld. CIT(A).

On the first set of additions (Rs. 18,78,750/- relating to M/s Siddhi Vinayak and Rs. 15,23,978/- relating to M/s Bhairav Township), the Tribunal noted the assessee's submission that complete audited books, vouchers, bills and registers were produced and that the books were not rejected by the AO. The assessee furnished a reconciliation chart covering multiple assessment years showing how amounts reflected in 26AS and in the books reconcile over time, with the Tribunal reproducing that chart (showing net variances largely reconciled).

The Tribunal observed the legal position (as relied upon by the assessee) that data available to revenue (such as 26AS) cannot by itself be a legally sustainable basis for additions without proper inquiry and that reconciliation and audited books must be considered. Considering that:

the books were audited and produced;
the AO had not rejected the accounts;
the assessee provided reconciliation and explanations for year-to-year variances; and
the net reconciliation showed the parties' contract values matched over a period (the Tribunal reproduced the assessee's reconciliation chart and noted negligible net variance),

the Tribunal concluded that the AO's additions based solely or primarily on Form 26AS entries and the enquiries were not sustainable. Accordingly, the Tribunal deleted the additions totaling Rs. 34,02,728/- (the combined Rs. 18,78,750 and Rs. 15,23,978).

On the lump-sum disallowance of Rs. 2,00,000/-, the Tribunal noted that the ld. CIT(A) simply confirmed the AO's ad-hoc disallowance without separately addressing the assesses' contention that vouchers and audited accounts were supplied and no defects were pointed out by the AO. The assessee also supplied comparative charts showing that the challenged expenses were not higher than earlier years. The Tribunal found no material in the record demonstrating personal nature of expenses or defects in vouchers and concluded that neither the AO nor the ld. CIT(A) had a proper basis for the lump-sum disallowance. Consequently the Tribunal deleted the disallowance of Rs. 2,00,000/-.

As to the interest issues raised in ground No. 3, the Tribunal treated them as consequential: the tax adjustments decided (deletion of additions/disallowance) will determine any interest liability or entitlement, which should be computed in accordance with law.

Holding and Implications

Holding: The appeal is allowed.

Direct consequences of the Tribunal's decision:

The Tribunal deleted the additions of Rs. 18,78,750/- and Rs. 15,23,978/- (total Rs. 34,02,728/-) that the AO had made on account of differences between Form 26AS and the assessee's books.
The Tribunal deleted the lump-sum disallowance of Rs. 2,00,000/- which was made by the AO and confirmed by the ld. CIT(A).
Ground No. 3 (relating to charging of interest under sections 234A, 234B, 234C & 234D and withdrawal under section 244A) was left as consequential: any interest consequences are to be determined in accordance with law after giving effect to the deletions made by the Tribunal.

The opinion does not state that a novel legal principle was created; the Tribunal applied established principles (as relied upon by the assessee) regarding the limits of making upward estimations where audited books are produced and not rejected, and distinguished Revenue-cited authorities as being on different facts. The direct effect is the relief granted to the assessee by deletion of the specified additions and disallowance; no new binding precedent was announced in the operative portion of the order.

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M/S SHRI JEEN MATA BUILDCON PVT. LTD., JAIPUR v. INCOME TAX OFFICER, WARD-4-2, JAIPUR

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IN THE INCOME TAX APPELLATE TRIBUNAL,

JAIPUR BENCHES,"SMC" JAIPUR Mk0 ,l- lhrky{eh] U;kf;d lnL; ,o a Jh jkBkMs dey's k t;UrHkkbZ] y[s kk lnL; d s le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy l-a@ITA No. 397/JP/2019 fu/kZkj.k o"kZ@Assessment Years : 2013-14

M/s Shri Jeen Mata Buildcon Pvt. cuke The ITO

Ltd. 97, Arya Nagar, Murlipura Vs. Ward 4(2)

Jaipur Jaipur LFkk;h y[s kk l-a @thvkbvZ kj l-a @PAN/GIR No.: AAQCS8904G vihykFkhZ@Appellant izR;FkhZ@Respondent

fu/kZkfjrh dh vksj l@s Assessee by : Mahendra Gargieya (Adv.) jktLo dh vksj l@s Revenue by : Runi Pal (Addl. CIT)

lquokbZ dh rkjh[k@ Date of Hearing : 22/02/2022 mn?kk"s k.kk dh rkjh[k@Date of Pronouncement: 08/03/2022 vkn's k@ ORDER

PER: RATHOD KAMLESH JAYANTBHAI, AM

This appeal is filed by the assessee is directed against the order of ld. CIT(A), Ajmer dated 24.01.2019 for the Assessment Year 2013-14.

2. The hearing of the matter was scheduled through Video Conferencing by both the parties in view of prevalent government guidelines on account of ongoing COVID-19 pandemic situation in the country.

3. The grounds of appeal raised by the assessee before us are as under:-

"1. The ld. CIT(A) erred in law as well as on the facts of the case in confirming the addition, so made, of Rs. 18,78,750/- & 15,23,978/- on account of difference between the amount reflected as per TDS Form 26AS and receipts recorded in books of accounts. The addition so made and confirmed by the CIT(A) being totally contrary to the provisions of law and facts of the case, kindly be deleted in full.

2. The ld. CIT(A) erred in law as well as on the facts of the case in confirming the lumpsum disallowance of Rs. 2,00,000/-. The disallowance so made and confirmed by the CIT(A) being totally contrary to the provisions of law and facts of the case, kindly be deleted in full.

3. The ld. AO further erred in law as well as on the facts of the case in charging interest u/s 234A, 234B, 234C & 234D of the Act and as also in withdrawing interest u/s 244A of the Act. The appellant totally denies its liability of charging and withdrawal of any such interest. The interest so charged/withdrawn, being contrary to the provisions of law and facts, kindly be deleted in full.

4. The appellant prays your honour indulgences to add, amend or alter of or any of the grounds of the appeal on or before the date of hearing."

4. The relevant facts, as culled out from the records is that, the assessee company is engaged in the business of labour contractor supplier with machinery under affordable housing policy for the year under consideration. The assessee company filed its return of income declaring income at Rs. 5,21,007/- on 30.03.2015 through e-filing portal and the same was processed u/s 143(1) of the Income Tax Act, 1961. Later on, the case was selected for scrutiny through CASS due to difference in turnover between 26AS and books of account. In the assessment proceedings, the Assessing Officer has observed that turnover

declared by the assessee for the year under consideration at Rs. 67,84,050/-. Whereas the turnover as reflected as per 26AS is Rs. 86,62,800/- the difference of Rs. 18,78,750/- is added back in case of the contract received from M/s Sidhi Vinayak Affordable Homes. Considering that the party has also booked that amount in their books as confirmed under enquiry made u/s 133(6) of the Act. In another case addition in respect of M/s Bhairav Township Pvt. Ltd, the Assessing Officer has observed that there is a difference between income offered and expenses booked. Therefore, he has derived the figure of addition at Rs. 15,23,978/- being the difference of the expenses booked and income offered, the same is derived as under:-

"A.Y Income Expenses

2011-12 37,80,000/- 6,04,000/- 2012-13 10,70,00,00/- 15,39,99,78/- 1,44,80,000/- 1,60,03,978/- A B B-A 15,23,978/-

(Short declared turnover)"

5. While dealing with the ground for these two additions, the ld. CIT(A) observed in his order at para 4.3 and has confirmed the addition by observing as under:- "4.3 I have gone through the assessment order, statement of facts, grounds of appeal and written submission carefully. It is seen that the addition has been made by the AO after verification of the information available in Form No. 26AS of the appellant and result of enquiries conducted u/s 133(6) with M/s Sidhi Vinayak and M/s Bhairav Township Pvt. Ltd. The appellant has not furnished any documentary evidence to substantiate the submission made by it. Therefore, In view of the facts

discussed by the AO in the assessment order, I am of the considered view that the AO has rightly made the addition of Rs. 18,78,750/- and Rs. 15,23,978/-. Accordingly, the addition of Rs. 34,02,728/- made by the AO is hereby confirmed."

6. The 3^rd addition made by the Assessing Officer is ad-hoc disallowance of Rs. 2,00,000/- out of Rs. 2,13,510/- on account of travelling expenses, Rs. 2,84,510/- on account of consumable expenses, Rs. 5,42,280/- on account of conveyance Expenses, Rs. 5,45,800/- on account of diesel expenses and Rs. 4,54,050/- on account of staff welfare expense. While making disallowance AO contended that the expenses incurred on self-made vouchers considering the nature of the expenses revenue leakage/personal use of the same and therefore, he has considered to disallow a lumpsum amount of Rs. 2,00,000/- out of the these expenses.

7. The ld. CIT(A) has also confirmed the finding of the AO in respect of the lumpsum addition of Rs. 2 lac without giving any separate findings.

8. Being aggrieved from the order of the ld. CIT(A), the assessee has moved an appeal before the Co-ordinate Bench wherein the contentions of appellant as appearing in paper book are as under:- "1. Accounts not rejected by the AO: At the outset it is submitted that the assessee has maintained proper books of account which are duly

audited u/s 44AB of the IT. Act. Complete books of accounts along with

purchase bills, contract receipts bills, vouchers and other registers

maintained by the assessee were produced before the AO in the course

of assessment proceedings as admitted by him at top of the Pg-2.

Moreover, the assessee consistently has not been showing Closing WIP since earlier years. The method and manner of maintenance of the books of accounts is the same as was in the past without any objection raised by the revenue. The accounts of the assessee were never rejected in the past nor the AO, in the current year has rejected the books of account directly or even remotely. He made the impugned addition merely and blindly relying upon the receipts as shown in Form 26AS, which were higher than the contract receipts shown by the assessee in its books. The law is well settled that if accounts are not rejected u/s 145(3) no upward estimation of income is legally possible. Reliance is placed on the following decisions:

• M/s Bansilal Abirchand Spg. & Wvg. Mills 75 ITR 260 (Bom)

• CIT vs. Maharaja Shree Umaid Mills Ltd. 192 ITR 565 (Raj.)

• DCIT vs. Mewar Textile Mills Ltd. 21 Tax World 821 (JP)

• Mohd. Umer vs. CIT 101 ITR 525

• Ajanta Constructions (P.) Ltd. vs. ACIT XXII TW 606 (ITAT Jaipur)

• DCIT vs. Associated Stone Industries (Kotah) Ltd. XXII TW 155 (JP)

• Ghewarchand vs. ITO- XXI TW 571

• Siddheshwari Cotton Mills P. Ltd. vs. CIT 117 ITR 953 at 957 (Call)

• ACIT vs. M/s Mount Malt Bru Ltd 34 TW 246 (JP)

• CIT vs. President Industries (2002) 258 ITR 654 (Guj.)

• CIT vs. Abhishek Corporation (2000) 158 CTR 374 (Guj.)

• ITO vs. Star Consortium 127 taxman 681 (Kol) (2021), (DPB?)

9. Before us, the Revenue has relied upon two case laws as under:-

• Rah Jajharia E to E JV [2017] ITA No. 1848/Kol/2017 of the ITAT, Kolkata dated 21.12.2017.

• Surendra S. Gupta [2018] 93 taxmann. com 456 (Mumbai Trib.) Wherein the 1^st case as relied is related to the TDS credit on account of mobilization advance and in another case the allowing of TDS credit to the assessee whereas in these case, there is no such observation made by the Assessing Officer is only in respect of income reflected in the books as compared 26AS in one case & other additions is made on different facts of comparision of expenses. Therefore, these decisions are on different facts and we have considered the same as relied upon by the ld. DR. As regards, the addition of Rs. 2,00,000/-, the ld. DR has relied upon and vehemently argued that the said disallowance of Rs. 2,00,000/- is required to be sustained as per the findings of AO & CIT(A).

10. We have considered the rival submissions. The ld. AR of the assessee argued that merely there is a difference in the 26AS and the books results, there cannot be an addition to returned income the books of account of the assessee duly audited. AO has not found any single defect in the books of accounts that has been produced before the Assessing Officer. The assessment completed u/s 143(3) of the Act. Even, the inquiry made u/s 133(6) has properly been explained by the AR of the assessee in the assessment proceedings and reply is reproduced in the assessment order. The main contentions is that the other party has booked the expenses, that cannot be the reason while making the assessment in the case of the assessee, when the contract receipt got reflected in the subsequent year as per regular method of accounting followed. Surprisingly one addition is based on 26AS amount and amount in books and another from the expenses booked by the assessee and income of two years comparison. This shows how the additions were made by followings choose & pick. It is only elementary that information as per data base of the Revenue

authorities cannot be, by itself, a legally sustainable basis for making addition to the income of the assessee and that such imports are based starting point for appropriate inquiry which in this case made and explained by the assessee & reconciliation to that want also made. There is nothing more than this information input which has been put against the assessee. We have noted that the audited books of accounts and reconciliation and the various entities contract amount offered for tax over a period & time. Only difference between the contract value of each party matches over a period of time irrespective of the year offered by the assessee and therefore, grievance of the Revenue that the assessee has not offered correct income is fully explained by the assessee by filing the chart at page No. 5 of the assessee's written submissions which is reproduced hereinbelow.

Reconciliation Chart as per Assessee

F.Y. Siddhi Vinayak Bhairav Township

As per Books As per 26AS Variance As per Books As per 26AS Variance 2011-12 38,00,000 10,00,000 28,00,000

2012-13 67,84,050 86,62,800 (18,78,750) 1,07,00,000 1,40,00,000 (33,00,000) 2013-14 59,99,625 59,99,625 - 15,00,000 10,00,000 5,00,000

2014-15 36,47,947 20,62,500 15,85,447 - -

2015-16 95,911 - 95,911 - -

Net

Variance 1,65,27,533 1,67,24,925 (197,392) 1,60,00,000 1,60,00,000 -

11. The income offered for both the parties, in respect of which the addition made almost reconciled and offered for in the regular books, AO has not rejected the book results. Therefore, it is not required to disturb the books result which has been audited by an independent auditor. Thus, the addition made for an

amount of Rs. 18,78,750/-, Rs. 15,23,978/- totaling to Rs. 34,02,728/- as per ground No. 1 are deleted on the basis of finding discussed herein above.

12. As regards the lumpsum disallowance of Rs. 2,00,000/- , the observe of the ld. CIT(A) at para 5.3 is as under:-

"5.3 I have gone through the assessment order, statement of facts, grounds of appeal and written submission carefully. In view of the facts discussed by the AO in the assessment order, I am of the considered view that the AO has been most reasonable in making disallowance of Rs. 2 lac only out of the expenses debited under the head "travelling expenses (Rs. 2,13,510), consumable expenses (Rs. 2,84,510/-), conveyance expenses (Rs. 5,42,280) diesel expenses (Rs. 5,45,800) and staff welfare expenses (Rs. 4,54,050)". Therefore, the disallowance of Rs. 2 lac made by the AO is hereby confirmed."

13. It is apparent that on the best the reason known ld. CIT(A), he has not considered the contentions of the assessee that the books of accounts are being audited and no single defects found in the bills vouchers etc. produced before the Assessing Officer. Assessment proceedings no expenses so personal nature of the expenses brought on record. No defect in any of the voucher in nature and expended is placed on record and in absence of any such observations, the ld. Assessing Officer as well as ld. CIT(A) has erred in law as well as on facts in making /confirming disallowance of Rs. 2,00,000/-.

14. The AR of the assessee argued that there is an absolutely no basis to make lumpsum disallowance of Rs. 2,00,000/- and he has presented a chart

before us comparing the expenditure with that of the earlier years and the same is reproduced herein below.

Particular	AY 2013-14	%	AY 2012-13	%
Turnover Staff Welfare Expenses Conveyance Expenses Travelling Expenses Consumable Expenses	1,79,89,050/- 4,54,050 5,45,800 2,84,510 5,42,280	3% 3% 2% 3%	39, 30,000/- 1,71,998 2,45,800 84,880 2,38,500	4% 6% 2% 6%

Looking to these factual position that even on comparative the expenses are on

lower side with that of last year.

15. The ld. DR has not placed anything contrary to this and vehemently

contended the observation of the AO. In the light of these observation that there are no defects in the books, bills and voucher no addition can be made. Not only that which expenses to what extent can be considered as private as assessee being an artificial person is not spelt out from the order of lower authorities. The chart suggest that the same are at reduced figure compared to last year. Considering the material evidences and facts placed before us, we delete the lumpsum addition of Rs. 2,00,000/- and thus the ground No. 2 is allowed.

16. Thus, Ground Nos. 1 and 2 are allowed and assessee get relief accordingly and ground No. 3 is consequential for levy of interest if any in accordance with law.

In the result, the appeal of the assessee is allowed.

Order pronounced in the open court on 08/03/2022. Sd/- Sd/- ¼ Mk0 ,l- lhrky{eh ½ ¼ jkBkMs dey's k t;UrHkkbZ ½ (Dr. S. Seethalakshmi) (Rathod Kamlesh Jayantbhai) U;kf;d lnL;@Judicial Member y[s kk lnL;@Accountant Member Tk;iqj@Jaipur fnukda @Dated:- 08/03/2022

*Ganesh Kumar

vkn's k dh ifz rfyfi vxfzs 'kr@Copy of the order forwarded to:

1. The Appellant- M/s Shri Jeen Mata Buildcon Pvt. Ltd.,

2. iRz ;Fkh@Z The Respondent- The ITO,Ward- 4(2), Jaipur.

3. vk;dj vk;Dq r@ The ld CIT

4. vk;dj vk;Dq r¼vihy½@The ld CIT(A)

5. foHkkxh; ifz rfuf/k] vk;dj vihyh; vf/kdj.k] t;iqj@DR, ITAT, Jaipur

6. xkM Z QkbyZ @ Guard File (ITA No. 397/JP/2019) vkn's kkuqlkj@ By order,

lgk;d ita hdkj@Asst. Registrar

M/S SHRI JEEN MATA BUILDCON PVT. LTD., JAIPUR v. INCOME TAX OFFICER, WARD-4-2, JAIPUR

Factual and Procedural Background

Legal Issues Presented

Arguments of the Parties

Appellant's Arguments

Respondent's (Revenue) Arguments

Table of Precedents Cited

Court's Reasoning and Analysis

Holding and Implications

M/S SHRI JEEN MATA BUILDCON PVT. LTD., JAIPUR v. INCOME TAX OFFICER, WARD-4-2, JAIPUR

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