VISHAL ENTERPRISE, ,JAMNAGAR vs. INCOME TAX OFFICER, TDS-3,, JAMNAGAR.

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediasr.

rectification or appeal. Thus from these observations of the Hon'ble High Court of Gujarat, it can be said that only order passed u/s. 200A is rectifiable under 154 and is also appealable under 246A and therefore, any separate order passed u/s. 234E of the Act levying the fee for late filing of quarterly statement in form 27EQ

RAKESH BASANTILAL LADDHA,,JAMNAGAR. vs. INCOME TAX OFFICER, TDS-3,, JAMNAGAR.

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediasr.

rectification or appeal. Thus from these observations of the Hon'ble High Court of Gujarat, it can be said that only order passed u/s. 200A is rectifiable under 154 and is also appealable under 246A and therefore, any separate order passed u/s. 234E of the Act levying the fee for late filing of quarterly statement in form 27EQ

SMT. CHANDRIKABEN THAKARSHIBHAI LANGHNOJA,RAJKOT vs. THE ITO, WARD- 2 (2) (3), RAJKOT

In the result, appeal filed by the Assessee is hereby allowed

rectification application u/s. 154 of the Act on 16.10.2018 requesting the A.O. to rectify mistake apparent from record and Revised the income of the assessee to Rs. 4,97,370/-. In support of her claim the assessee submitted in Form No. 16 showing the correct salary income and TDS

SMT. DINUMATIBEN DAMJIBHAI SHILU,RAJKOT vs. THE INCOME TAX OFFICER, WARD-2 (2) (5), RAJKOT

The appeal of the assessee is allowed

Bench: SMT.ANNAPURNA GUPTA (Accountant Member), SMT. MADHUMITA ROY, JUDICIAL MEMBER (Judicial Member)

rectification u/s 154 of the Act as sought by the assessee. The fact that income to the said extent of Rs.34,07,004/- being exempt is not disputed being accepted by the AO in remand proceedings. The facts on record reveal that the error was patent. 4 6. The income reflected in the return filed by the assessee

ANKUL CONSTRUCTION CO.,RAJKOT vs. THE ASSIT. DIRECTOR OF INCOME TAX , CPC BENGLURU/ITO WD-1(2)(1), RAJKOT

In the result, this appeal of the assessee is allowed for statistical purposes, in above terms

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपीलसं./Ita No. 484/Rjt/2024 Assessment Year: (2020-21) (Hybrid Hearing) Anukul Constriction Co. Vs. Asstt. Director Of Income 901, Aalap-B, Opp. Shastri Ground, Tax, Cpc Bangaluru / Ito Limda Chowk, Ward 1(2)(1), Rajkot – 360001 Aayakar Bhavan, Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aakfa2385E (Appellant) (Respondent) Appellant By : Shri Jay Kathrani, Ld. A.R. Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 04/02/2025 Date Of Pronouncement : 17/02/2025

rectification u/s. 154 of the Act, and the application was rejected by the Ld. ADIT/ CPC, Bengaluru. 5. That the assessee filed an appeal against the impugned order dated 22.08.2022 and rectified the order. “In view of the above, I find no infirmity in the disallowance made by the CPC u/s. 40a(ia) for non-compliance of TDS

M/S. HINDUSTAN MINMENT INC.,JAMNAGAR vs. THE INCOME TAX OFFICER, WARD-3(2),, JAMNAGAR

In the result, appeal filed by Assessee is allowed

Bench: Shri Mahavir Prasad & Shri Amarjit Singh) [Through Virtual Court]

u/s. 154 of the Income-tax Act, 1961 on the alleged ground that the appellant has neither claimed any credit in TDS of Rs.12,40,875/-in return of income nor filed revised return income by claiming credit of TDS. The rejection of rectification

GOPAL SNACKS PVT LTD ,RAJKOT vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAJKOT

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita Nos. 498 & 499/Rjt/2025 "नधा"रणवष"/ Assessment Years: 2015-16 & 2020-21 बनाम Gopal Snacks Pvt. Ltd. Asst. Commissioner Of Plot No.2322-2324, Gidc Metoda, Income Tax Vs. Lodhika, Rajkot, Gujarat-360021 Circle-1(1), Rajkot Pan : Aadcg6113A (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Prakash Jhunjhunwala & Shri K. K. Maloo, Ars. राज"व क" ओर से/Revenue By : Shri Shramdeep Sinha, Cit.Dr & Shri Abhimanyu Singh, Sr. Dr सुनवाई क" तार"ख /Date Of Hearing : 19/11/2025 घोषणा क" तार"ख /Date Of Pronouncement : 08/12/2025

Rectification order u/s.154, since such adjustments does not comprise of the mistake apparent on record. (vi)The Ld. CIT(A) erred in confirming the total income as processed by the CPC, on ignoring the fact that the notice for enhancing the income has not been served to the appellant u/s 154(3) of the Act. 3. The facts

GOPAL SNACKS PVT LTD ,RAJKOT vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAJKOT

Rectification order u/s.154, since such adjustments does not comprise of the\nmistake apparent on record.\n(vi)The Ld. CIT(A) erred in confirming the total income as processed by the CPC, on\nignoring the fact that the notice for enhancing the income has not been served to the\nappellant u/s 154(3) of the Act.\n3. The facts

PANKAJ CHIMANLAL LODHIYA,RAJKOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

rectification u/s 154 was carried out, vide order dated 28.02.2018 wherein addition of Rs.589,63,46,541/-, made on account of unexplained credit entries in unallocated gold/silver account of STCSH is reduced to Rs.9,01,43,236/-, as there was error in considering gold and silver rate and mistake in calculation thereof. Accordingly total income revised at Rs.61

PANKAJKUMAR CHIMANLAL LODHIYA,RAKJOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.76 To 80/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2008-09 To 2012-13 & आयकर अपीलसं/.Ita No. 81/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2014-15 Shri Pankaj Chimanlal Lodhiya 3Rd Floor, Parth, Diwanpara | बनाम Main Road, Rajkot-3600 001 Vs. Pan: Aampl 3903 F Assistant Commissioner Of Income-Tax, Central Circle-2 Rajkot, 2Nd Floor, Amruta Estate, M.G. Rad, Rajkot-360 001 (अपीलार्थी/Assessee) (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri Mehul Ranpura, Ar राजस्व की ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 05/03/2025 घोषणा की तारीख/Date Of Pronouncement : 30/04/2025 Order Per Bench, Captioned Six Appeals Filed By The Assessee, Pertaining To The Assessment Years (Ays) 2008-09 To 2012-13 & Ay 2014-15, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), (“Ld.Cit(A)” For Short) Under Section 250 Of The Income Tax Act, 1961 (“The Act" For Short), Which In Turn Arise Out Of Separate Penalty Orders, Passed By The Assessing Officer U/S 271(1)(C) & 271Aab(1)(C) Of The Act.

TDS. The penalty confirmed is totally unjustified on facts was also in law and may kindly be deleted. 5. The relevant material facts, as culled out from the material on record, are as follows. The assessee, before us, is an in individual and has originally filed return of income u/s 139(1) of the Act, on 30.09.2008, declaring total income

PANKAJKUMAR CHIMANLAL LODHIYA,RAJKOT vs. THE ACTIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.76 To 80/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2008-09 To 2012-13 & आयकर अपीलसं/.Ita No. 81/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2014-15 Shri Pankaj Chimanlal Lodhiya 3Rd Floor, Parth, Diwanpara Main Road, Rajkot-3600 001 Pan: Aampl 3903 F (अपीलार्थी/Assessee) निर्धारिती की ओर से/Assessee By : Shri Mehul Ranpura, Ar राजस्व की ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 05/03/2025 घोषणा की तारीख/Date Of Pronouncement : 30/04/2025 Order Per Bench, Captioned Six Appeals Filed By The Assessee, Pertaining To The Assessment Years (Ays) 2008-09 To 2012-13 & Ay 2014-15, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), (“Ld.Cit(A)” For Short) Under Section 250 Of The Income Tax Act, 1961 (“The Act" For Short), Which In Turn Arise Out Of Separate Penalty Orders, Passed By The Assessing Officer U/S 271(1)(C) & 271Aab(1)(C) Of The Act.

rectification u/s 154 was carried out, vide order dated 28.02.2018 wherein addition of Rs.589,63,46,541/-, made on account of unexplained credit entries in unallocated gold/silver account of STCSH is reduced to Rs.9,01,43,236/-, as there was error in considering gold and silver rate and mistake in calculation thereof. Accordingly total income revised at Rs.61

PANKAJKUMAR CHIMANLAL LODHIYA,RAJKOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.76 To 80/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2008-09 To 2012-13 & आयकर अपीलसं/.Ita No. 81/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2014-15 Shri Pankaj Chimanlal Lodhiya 3Rd Floor, Parth, Diwanpara Main Road, Rajkot-3600 001 Pan: Aampl 3903 F (अपीलार्थी/Assessee) बनाम Vs. Assistant Commissioner Of Income-Tax, Central Circle-2 Rajkot, 2Nd Floor, Amruta Estate, M.G. Rad, Rajkot-360 001 (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri Mehul Ranpura, Ar राजस्व की ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement : 05/03/2025 : 30/04/2025 Order Per Bench, Captioned Six Appeals Filed By The Assessee, Pertaining To The Assessment Years (Ays) 2008-09 To 2012-13 & Ay 2014-15, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), (“Ld.Cit(A)” For Short) Under Section 250 Of The Income Tax Act, 1961 (“The Act" For Short), Which In Turn Arise Out Of Separate Penalty Orders, Passed By The Assessing Officer U/S 271(1)(C) & 271Aab(1)(C) Of The Act.

rectification u/s 154 was carried out, vide order dated 28.02.2018 wherein addition of Rs.589,63,46,541/-, made on account of unexplained credit entries in unallocated gold/silver account of STCSH is reduced to Rs.9,01,43,236/-, as there was error in considering gold and silver rate and mistake in calculation thereof. Accordingly total income revised at Rs.61

PANKAJKUMAR CHIMANLAL LODHIYA,RAKJOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

rectification u/s 154 was carried out, vide order dated\n28.02.2018 wherein addition of Rs.589,63,46,541/-, made on account of\nunexplained credit entries in unallocated gold/silver account of STCSH is\nreduced to Rs.9,01,43,236/-, as there was error in considering gold and silver\nrate and mistake in calculation thereof. Accordingly total income revised at\nRs.61

M/S. MAGNUM CERAMICS PVT. LTD. ,MORBI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, MORBI CIRCLE, MORBI

In the result, appeal of assessee is allowed

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year :2012-13 M/S.Magnum Ceramic P.Ltd. The Acit, Morbi Circle Plot No.207/24, Gidc Estate Vs Morbi. 8-A, National Highway At. Refaleshwar Morbi 362 268 Pan : Aafcm 2216 G

154 of the Act was incorrect. Aggrieved by this order of the ld.CIT(A) the assessee is now before us , raising the above grounds. 4. Vis-à-vis the ground nos.1 & 4, they are general in nature and need no adjudication. Vis-à-vis ground no.2, that the ld.CIT(A) had dismissed the assessee’s appeal ex parte without considering