SHRI KALPESH VINODBHAI PATEL,RAJKOT vs. THE ACIT CIRCLE 2 (1) RAJKOT, RAJKOT

ITA 484/RJT/2025Status: DisposedITAT Rajkot24 August 2026AY 2018-195 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal set aside the assessment order and restored the matter to the Assessing Officer for fresh adjudication, directing them to examine all issues including the validity of reassessment proceedings. The revisionary order under Section 263 was also set aside as the underlying assessment order was nullified.

What were the facts?

The assessee's income was reassessed under Section 147, with additions made for alleged bogus sales due to cancelled GST registrations of purchasers and lack of invoices. The assessee's appeal to the CIT(A) was dismissed for non-compliance.

What were the issues?

The primary issues were the validity of the reassessment proceedings, the genuineness of sales transactions, and the propriety of the revisionary order under Section 263.

Which sections of the Income-tax Act were involved?

Section 147,Section 144B,Section 148A,Section 148,Section 142(1),Section 68,Section 263

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Rajkot Bench, Rajkot

Before: Dr. Arjun Lal Saini & Shri Sonjoy Sarma

For Appellant: Shri Bandish Soparkar, Ld. AR
For Respondent: Shri Ravinder Sindhu, Ld. Sr. CIT (DR)
Hearing: 13/08/2026Pronounced: 24/08/2026

Per, Shri Sonjoy Sarma, JM: These two appeals have been preferred by the same assessee. ITA No. 417/Rjt/2025 arises out of the order passed by the Ld. Principal Commissioner of Income Tax, Rajkot [hereinafter referred to as “Ld.PCIT"], dated 27.03.2025, which, in turn, arises from the assessment order passed under section 147 read with section 144B of the Income-tax Act, 1961 [hereinafter referred to as "the Act"], dated 29.03.2023. ITA No. 484/Rjt/2025 ar

The order continues below.

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