IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, “A” BENCH, JAIPUR BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER &

SHRI RATNESH NANDAN SAHAY, ACCOUNTANT MEMBER ITA Nos.1764 & 1765/JPR/2025 (Assessment Years:2013-14 & 2016-17)

ACIT Circle-4, Vs. Gopal Prasad Gupta Jaipur 301, Anukampa Mansion-

1, M.I. Road, Jaipur 302001 (cid:1)(cid:2)(cid:3)(cid:4)(cid:5)(cid:6)(cid:7)(cid:8)(cid:3)(cid:9)(cid:10)./ज(cid:5)आइआर(cid:9)(cid:10)./PAN/GIR No:ABBPG4023H Appellant .. Respondent Appellant by : Sh. Rajnikant Bhatra, CA Respondent by : Sh. Rajesh Ojha, CIT Date of Hearing 18.03.2026 Date of Pronouncement 23.03.2026 O R D E R Per Ratnesh Nandan Sahay, Accountant Member:

Both the present appeals have been preferred by revenue against the order of Ld. Commissioner of Income Tax Appeal (hereinafter referred to as “Ld. CIT(A)”) dated 08.09.2025 u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as “Act”).

2. The revenue has taken the following grounds of appeal:-

i)Whether the Learned CIT(A) erred in quashing the assessment proceedings based solely on the High Court judgment in DBCWP 18363/2019, without considering the unique facts and circumstances of the present case.

(ii) Whether on the fa