SHIV EXTRUSION,JAMNAGAR vs. INCOME TAX OFFICER, JAMNAGAR

ITA 646/RJT/2025Status: DisposedITAT Rajkot12 March 2026AY 2016-17Bench: DR. ARJUN LAL SAINI, AM., Dr. DINESH MOHAN SINHA (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the reassessment notice dated 29.07.2022 was issued beyond the permissible limitation period, considering the extensions under TOLA and the Supreme Court's rulings in Ashish Agarwal and Rajeev Bansal. Therefore, the notice was quashed.

What were the facts?

The assessee firm's reassessment proceedings for AY 2016-17 were initiated based on information from the CGST department regarding clandestine sales. The Assessing Officer (AO) made an addition of Rs. 7,94,224/-. The assessee's appeal to the CIT(A) was dismissed.

What were the issues?

The primary issue was whether the reassessment notice was issued within the surviving limitation period after considering the impact of TOLA and Supreme Court judgments. Another issue was the validity of additions made under Section 69A and the charging of interest under Section 234B.

Which sections of the Income-tax Act were involved?

Section 149,Section 148,Section 148A,Section 69A,Section 234B,Section 271(1)(c)

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Income Tax Appellate Tribunal, RAJKOT BENCH, RAJKOT

Before: DR. ARJUN LAL SAINI, AM. & Dr. DINESH MOHAN SINHA, JM

For Appellant: Shri Ramesh M. Patel, Ld. AR
For Respondent: Shri Abhimanyu Singh Yadav Ld. Sr. DR
Hearing: 23/12/2025Pronounced: 12/03/2026

PER, Dr. DINESH MOHAN SINHA JM; Captioned appeals filed by the assesse firm, pertaining to Assessment Year 2016-17, is directed against order passed under section 250 of the Income Tax Act, 1961 by National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income Tax (Appeals), dated 30/09/2025, which in turn arises out of an order dated 17/05/2023 passed by the Assessing Officer u/s 147 read with section 144B of the I.T. Act.

Shiv Extrusion

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