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Documents citing Pramukh Realty, Junagadh vs The Pcit, Rajkot-1, Rajkot, Rajkot on 30 June, 2022

Junagadh District Cricket Association ... vs Pr. Cit (Exemption), Ahmedabad, ... on 4 July, 2024

In view of the above facts, looking into the submissions made by A.R. of the assessee that because of non-receipt of the notice for I.T.A No. 161/Rjt/2023 A.Y. 2023-24 4 Junagadh District Cricket Association Junagadh vs. PCIT hearing the assessee trust could not reply to notice. The prayer of the Ld. A.R. for an opportunity may kindly be granted to explain the case before Ld. CIT(E). All documents relating to registration of trust have been submitted on website of the Department. Therefore, we set-aside the order of the ld. CIT(E) remit the matter back to the file of ld. CIT(E) for fresh adjudication on merits, after affording opportunity of being heard to the assessee. We direct the assessee to submit relevant details/documents/evidences, if any, as required by the Ld. CIT(E) for disposal of the appeal.
Income Tax Appellate Tribunal - Rajkot Cites 5 - Cited by 0 - Full Document

M/S Jila Sahakari Kendriya Bank, , ... vs Acit-2, Indore on 5 June, 2024

CIT 2 SOT 705. He has relied upon the decision of Hon'ble Bombay High Court in the case of CIT V/s Nirav Modi 71 Taxman.com 272. Ld. AR has then referred to the computation of income placed at page No.8 of the synopsis and submitted that the assessee has made suo-moto disallowance in respect of LAN networking and electrical expenses of Rs.27,19,000/- and therefore, there cannot be a question of allowability of the same by the Ld. A.O and consequently the order of the Ld. AO cannot be held as erroneous on this issue. Ld. AR then relied upon the decision of Rajkot Bench dated 30.06.2022 in ITANo.496/Ind/2018 Jila Sahakari Kendriya Bank Mydt 6 the case of M/s Pramukh Realty Vs PCIT as well as the decision of Delhi Benches dated 01.09.2019 in the case of Dwarikadish Buildwell Pvt. Ltd v/s CIT in ITA No.3097/Del/2014 and submitted that the Tribunal has held that if the CIT is of the view that the A.O did not undertake any enquiry, it becomes incumbent on the part of PCIT to conduct such enquiry. If PCIT does not conduct such basic exercise then the PCIT is not justified in setting aside the order u/s 263 of the Income Tax Act. Thus Ld. AR has submitted that case of the assessee does not fall in the category of complete lack of enquiry when the Ld. A.O has passed the order after conducting a due enquiry and satisfaction of the claim of the assessee then the same cannot be held as erroneous and prejudicial to the interest of revenue. The Ld. A.O after considering the reply as well as judicial precedence on the allowability of various statutory provisions provided u/s 43 and 43A of M.P Co- operative Act allowed all provisions of the assessee bank. Hence, the Ld. AR has submitted that when the Ld. A.O has taken a possible view the Ld. PCIT is not permitted to invoke the provisions of Section 263 of the Income Tax Act merely because he does not agree with the view of the Ld. A.O. Accordingly he has pleaded that the impugned order of Ld. PCIT is not sustainable and the same is liable to be set aside/quashed.
Income Tax Appellate Tribunal - Indore Cites 15 - Cited by 0 - Full Document
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