VIRJIBHAI JERAMBHAI PATEL ,RAJKOT vs. ITO WARD 1(2)(2), RAJKOT, RAJKOT

ITA 405/RJT/2026Status: DisposedITAT Rajkot25 September 2026AY 2012-136 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the assessees were not provided with adequate opportunities before the AO and that the principles of natural justice were violated. Therefore, the appeals were set aside and remitted back to the AO for fresh adjudication.

What were the facts?

The assessees sought to submit additional documents and evidence before the Assessing Officer (AO) to prove their claims, arguing they were denied proper opportunities and cross-examination. The AO had initiated proceedings under Section 147 based on information from the Investigation Wing regarding angadiya transactions.

What were the issues?

Whether the assessees were denied a proper opportunity to present their case and evidence before the Assessing Officer, and whether the principles of natural justice were violated.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 143(2),Section 133(6),Section 250,Section 254

AI-generated summary — verify with the full judgment below

Heard together (2 matters)

ITA No. 403/RJT/2026
ITA No. 405/RJT/2026

Read from the judgment's own cause title. This page is filed under one of them.

आयकर अपीलीय अिधकरण, राजकोट "यायपीठ, राजकोट । In The Income Tax Appellate Tribunal, “SMC” Rajkot Bench, Rajkot Before Dr. Arjun Lal Saini, Accountant Member आयकर अपील सं./ITA No. 403/RJT/2026 [ िनधा"रण वष" /Assessment Year: 2013-14 ] N J Gears, ITO Ward 3(1)(1) Rajkot 1 Vaidwadi, Near Shivam Aayakar Bhawan, Race बनाम/ Gujarat-360004 Rajkot, Gujarat-360001 "ायीलेखासं./जीआइआरसं./PAN/GIR No.: AAHFN1972F (Appellant) (Respondent)

आयकर अपील सं./ITA No. 948, 949 & 950/RJT/2025 [ िनधा"रण वष" /Assessment Year: 2013-14, 2014-15 & 2015-16 ] Mahavir Engineering Works, ITO Ward 1(1)(1) Rajkot, 11, Mavdi Plot, Aayakar Bhawan, Race Course बनाम Rajkot, Gujarat 360004 Ring Road, Rajkot, /Vs. Gujarat, 360001 "ायीलेखासं./जीआइआरसं./PAN/GIR No.: AADFM3701D (Appellant) (Respondent)

आयकर अपील सं./ITA No. 405/RJT/2026 [ िनधा"रण वष" /Assessment Year: 2013-14 ] Virjibhai Jerambhai Patel, ITO Ward 1(2)(2) Rajkot, Prop. Vijay Marshal Ind. G.L.D.C., Aayakar Bhawan, Race बनाम/ Rajkot, Gujarat-360001 "ायीलेखासं./जीआइआरसं./PAN/GIR No.: ACGPP8238D (Appellant) (Respondent) िनधा"रती की ओर से/Appella

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