HOLLIS VITRIFIED PRIVATE LIMITED,MORBI, GUJARAT, INDIA vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 1, RAJKOT, RAJKOT, GUJARAT, INDIA

In the result, appeal filed by the assessee, is dismissed

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 363/Rjt/2024 (Assessment Year: 2018-19) (Hybrid Hearing) Hollis Vitrified Pvt. Ltd. Vs. The Pr. Commissioner Of Income Revenue Survey No. 756/P1/P1/P1, Opp. Tax-1, Rajkot Antique Granito, Ghuntu,-Lakhdhirpur Road, Morbi (Gujarat)-363642 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacch5628Q (अपीलाथ"/Appellant) (""थ"/Respondent)

revised is erroneous: and (ii) it is prejudicial to the interests of the revenue, are satisfied. Accordingly, the impugned assessment order passed by the A.O. u/s 143(3) r.w.s. 143(3A) & 143(3B) of the Income-tax Act, 1961 on 01/04/2021 was set aside by ld. PCIT for fresh assessment only to the extent of the issues discussed (supra

MANSUKHBHAI KANJIBHAI SAKARIYA,RAJKOT vs. PRINCIPAL COMMISSIONER OF INCOME TAX, RAJKOT-1, RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita No.318/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2016-17 Mansukhbhai Kanjibhai Sakariya The Pr.Commissioner Of बनाम At Khajuri Gundala Income Tax-1, Rajkot. Post Station: Vavdi Vs. Amarnagar, Khajuri Gundala. Pan : Aslps 7027 E (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रतीक"ओरसे/Assessee By : Shri Rajendra Singhal, Ld.Ar राज"वक"ओरसे/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

u/s 263 of the Income-tax Act, 1961, was issued by ld.PCIT, on 29.02.2023 and duly served upon the assessee.The ld. PCIT stated in the notice that assessee case was reopened on the basis of information available with the Department that during the year under consideration, assessee has received interest on enhanced compensation on acquisition of agricultural land of Rs.1

GLOBAL EXTRUSIONS PVT. LTD. ,JAMNAGAR vs. THE PR. CIT, JAMNAGAR, JAMNAGAR

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.203/Rjt/2024 "नधा"रणवष" / Assessment Year: (2013-14) (Hybrid Hearing) Global Extrusions Private Limited. Vs. Pcit Jamnagar, Ca Govind Sonecha Taranjali Building, “S&A House”, Near Golden City, Jamnagar 361008 80Ft Road, Khodiyar Colony, B/H Saru Section Police Headquarters, Jamnagar 361006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabcm4319E (Appellant) (Respondent) Appellant By : Ms. Amoli Gusani, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. (Cit)Dr Date Of Hearing : 19/03 /2025 Date Of Pronouncement : 09/06/2025

revise the assessment order. 5. Being aggrieved by the above order of the Ld. PCIT u/s. 263 dated 09.02.2024 of the Act, the appellant has filed this appeal before us. Global extrusions pvt. Ltd. 6. During the course of hearing the Ld. AR has submitted that a notice issued on account bogus purchase/ accommodated entry however the case was reopened

PRAMUKH ARANYA DEVELOPERS,JUNAGADH vs. PR. CIT, RAJKOT-1, RAJKOT, RAJKOT

revision\norder under section 263 of the Act on page no. 2 to 3.\n6. In response to above notice, the assessee has filed its reply before learned\nPCIT stating that assessment order under consideration passed by the assessing\n3 Page\nM/s. Pramukh Aranya Developers v. PCIT\nITA No.372/Rjt/2024AY. 2018-19\nofficer is neither erroneous nor prejudicial to the interest

VALOUR AUTOPACK,GOR KHIJADIYA, MORBI GUJARAT vs. THE PR. CIT 1 RAJKOT, RAJKOT

In the result, appeal filed by the assessee is allowed

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

263 of the Act, on 01-01-2025, on the assessee, which is reproduced by Ld. PCIT in its order vide Page No. 3 to 4. 4. In response to the notice of the Ld. PCIT, the assessee has submitted its reply before ld.PCIT stating that assessee is a partnership firm engaged in the business of manufacturing across various industries

JITENDRASINH ZALA,JAMNAGAR vs. THE PR.COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, the appeal filed by the assessee, is allowed

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

revise in 263, with reference to 142(1) notices and assessee`s reply thereon. 8. However, the Ld. PCIT rejected the submissions of the assessee, and observed that in respect of the four issues raised in the notice under section 263 of the Act, the assessment order passed by the Assessing Officer u/s 143(3) rws 144B

SHREE SAMARTH ELECTRICALS PVT LTD,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

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

revision order will be passed, based on the details and materials available on record.” 14. The ld.Pr.CIT, again issued show -cause notice, under section 263 of the Act on 30.01.2024, which is reproduced by the ld.Pr.CIT, on page no.4 to 5 of his order, wherein, the ld. PCIT raised the issue, relating to excess stock, the relevant portion

SHREE SAMARTH SWITCHGEAR AND TRANSMISSION PVT LTD,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR, JAMNAGAR

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

revision order will be passed, based on the details and materials available on record.” 14. The ld.Pr.CIT, again issued show -cause notice, under section 263 of the Act on 30.01.2024, which is reproduced by the ld.Pr.CIT, on page no.4 to 5 of his order, wherein, the ld. PCIT raised the issue, relating to excess stock, the relevant portion

P P CORPORATION,RAJKOT vs. PRINCIPAL COMMISSIONER OF INCOME TAX, RAJKOT

In the result, the appeal of the assessee is allowed

u/s 263 of the\nIncome-tax Act, 1961, was issued on 07.02.2023 and duly served upon the\nassessee, which is reproduced by the ld. PCIT, in his order, vide page no.2 to 5\nof the revision order under section 263 of the Act.\n4. In response, the assessee submitted before the learned PCIT that during the\nassessment proceedings, the assessing

GOJIYA BHIKHUBHAI,JAMNAGAR vs. PRINCIPAL COMMISSIONEROF INCOME TAX, JAMNAGAR

u/s 263 of the Income-tax Act. You may submit your written\nsubmissions to this office either through e-proceedings module of your e-filing account on the\nwebsite https://www.incometax.gov.in or email to jamnagar.pcit@incometax.gov.in or by any\nother postal modes / personal appearance or through your authorized representative latest by\n28/11/2023 at 11:00 AM, failing which

JABIR AYOOB VAHEVARIA,JAMNAGAR vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR, JAMNAGAR

In the result, assessee’s appeal ITA No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita Nos.26/Rjt/2025 िनधा"रणवष"/Assessment Year : 2021-22 Jabir Ayoob Vahevaria Principal Commissioner Of बनाम Plot No.3452 Gidc 3, Dared Income-Tax, Jamnagar, Jamnagar-361 004 ( Gujarat) Vs. Room No.101, 1St Floor, Aaykar Bhavan, Nr. Shubhas Bridge, Jamnagar-361 001 /. /. Pan/Gir No.:Aeqpv3027C "थायीलेखासं जीआइआरसं (अपीलाथ"/Appellant) .. (""यथ"/Respondent) आयकरअपीलसं/.Ita Nos.27/Rjt/2025 िनधा"रणवष"/Assessment Year : 2021-22 Altaf Ayoobbhai Vehvaria, Principal Commissioner Of बनाम Prop. Of K A Enterprise, Ground Income-Tax, Floor, Near Alamin Park, Vs. Jamnagar, Room No.101, 1St Vehwaria Madresa, Jamnagar- 361 004 Floor, Aaykar Bhavan, Nr. Shubhas Bridge, Jamnagar-361 001 /. /. Pan/Gir No.: Aempv7317M "थायीलेखासं जीआइआरसं (अपीलाथ"/Appellant) .. (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Cit- Dr

revision order under section 263 of the Act, vide page Nos.2 to 5. ITA No.26-27/Rjt/2025 A.Y.21-22 Jabir A Vahevaria& Altaf A Vehvaria 4 7. In response to above show cause notice, the assessee submitted his reply before Ld. PCIT. From plain reading of contention of notice of u/s 263 of the Act, the assessee submitted its reply that main allegation

ALTAF AYOOBBHAI VEHVARIA,JAMNAGAR vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR, JAMNAGAR

In the result, assessee’s appeal ITA No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita Nos.26/Rjt/2025 िनधा"रणवष"/Assessment Year : 2021-22 Jabir Ayoob Vahevaria Principal Commissioner Of बनाम Plot No.3452 Gidc 3, Dared Income-Tax, Jamnagar, Jamnagar-361 004 ( Gujarat) Vs. Room No.101, 1St Floor, Aaykar Bhavan, Nr. Shubhas Bridge, Jamnagar-361 001 /. /. Pan/Gir No.:Aeqpv3027C "थायीलेखासं जीआइआरसं (अपीलाथ"/Appellant) .. (""यथ"/Respondent) आयकरअपीलसं/.Ita Nos.27/Rjt/2025 िनधा"रणवष"/Assessment Year : 2021-22 Altaf Ayoobbhai Vehvaria, Principal Commissioner Of बनाम Prop. Of K A Enterprise, Ground Income-Tax, Floor, Near Alamin Park, Vs. Jamnagar, Room No.101, 1St Vehwaria Madresa, Jamnagar- 361 004 Floor, Aaykar Bhavan, Nr. Shubhas Bridge, Jamnagar-361 001 /. /. Pan/Gir No.: Aempv7317M "थायीलेखासं जीआइआरसं (अपीलाथ"/Appellant) .. (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Cit- Dr

revision order under section 263 of the Act, vide page Nos.2 to 5. ITA No.26-27/Rjt/2025 A.Y.21-22 Jabir A Vahevaria& Altaf A Vehvaria 4 7. In response to above show cause notice, the assessee submitted his reply before Ld. PCIT. From plain reading of contention of notice of u/s 263 of the Act, the assessee submitted its reply that main allegation

ACTIONWARE INDIA PRIVATE LIMITED ,RAJKOT vs. THE PCIT-1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.317/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2014-15 Actionware India Pvt. Ltd. The Pr.Cit-1 बनाम 316, Sagar Arcade Rajkot. Gandal Road Vs. Opp: Union Bank Of India Rajkot 360 002 (Gujarat) Pan : Aacck 3445 Q (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri D.M. Rindani, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

u/s 263 of the Act and pass a suitable order. Before passing such order, you are hereby given an opportunity of being heard in the matter. Please state as to why the order passed by the Assessing Officer in your case should not be revised after making necessary inquiry. In this connection you are requested to furnish your reply / submission

BAN LABS PRIVATE LIMITED,RAJKOT vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAJKOT, RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.202/Rjt/2024 ("नधा"रण वष" / Assessment Year: 2018-19) Ban Labs Pvt. Ltd., Vs. Principal Commissioner Of Ban House, Dr. Vikram Sarabhai Income Tax-1, Nagar, Gondal Road (South), Rajkot Rajkot-360004 (Gujarat) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaacb8999C (Appellant) (Respondent)

revision order, under section 263 of the Act, is that assessing officer has not conducted proper enquiry, in respect of exempt income of the assessee and did not make the disallowance under section 14A read with rule 8D of the Rules. Therefore, first of all, we should examine that what type of enquiry was conducted by the assessing officer, during

SHRI PRASHANTSINH AJITSINH CHAUHAN,RAJKOT vs. THE PR. CIT-1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

TDS and disallowance for such default. So, the Assessing Officer only verified the limited reason/scope for which the case was selected for scrutiny and scope of assessment cannot expanded in proceedings u/s. 263 of the Act. In support of its contention, the assessee relied on various judicial precedents that scope of limited scrutiny assessment cannot be expanded/enhanced during the course

VINAY INFRATECH PVT LTD,RAJKOT vs. THE PCIT, RAJKOT-1, RAJKOT, RAJKOT

In the result, the appeal filed by the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No. 101/Rjt/2022 िनधा"रण वष"/Asstt. Years: 2017-2018 M/S Vinay Infratech Pvt. Ltd., The Principal Commissioner Of 110-112, Silver Chamber, Vs. Income Tax, Tagore Road, Rajkot-1, Rajkot. Rajkot.

revision. There was simply no necessity to remand the proceedings to the Assessing Officer when no further inquiries were called for or directed” 9.7 From an analysis of the above judicial precedents, the principle which emerges is that the phrase 'prejudicial to the interests of the revenue' has to be read in conjunction with an erroneous order passed

SHIV GREEN ENERGY PRIVATE LIMITED,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, appeals filed by the assessees(ITA No

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 595/Rjt/2024 "नधा"रणवष" / Assessment Year: (2018-19) (Hybrid Hearing) Shiv Green Energy Pvt. Ltd. Vs. The Principal Commissioner Of Income Tax, 107, Divyam Park, Jamnagar 361001 Opp. H.O. Bhatt Bunglow, Nr. Sanjeevani Medical Store, Jamnagar - 361006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aascs8645J (Appellant) (Respondent)

revise the assessment order. 2. Learned PCIT Jamnagar erred in law as well facts by not giving effective opportunity of being heard, passed order is against the law and principle of natural justice. 3. Appellant craves leave to add, amend, alter or withdraw any ground of appeals.” 4. The appeal filed by the assessee in ITA No. 595/Rjt/2024 (Shiv Green

ASHOK GOPALDAS VITHLANI,JAMKHAMBHALIYA vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, appeals filed by the assessees(ITA No

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 595/Rjt/2024 "नधा"रणवष" / Assessment Year: (2018-19) (Hybrid Hearing) Shiv Green Energy Pvt. Ltd. Vs. The Principal Commissioner Of Income Tax, 107, Divyam Park, Jamnagar 361001 Opp. H.O. Bhatt Bunglow, Nr. Sanjeevani Medical Store, Jamnagar - 361006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aascs8645J (Appellant) (Respondent)

revise the assessment order. 2. Learned PCIT Jamnagar erred in law as well facts by not giving effective opportunity of being heard, passed order is against the law and principle of natural justice. 3. Appellant craves leave to add, amend, alter or withdraw any ground of appeals.” 4. The appeal filed by the assessee in ITA No. 595/Rjt/2024 (Shiv Green

DHIMANT RASIKLAL SHAH,JAMNAGAR vs. PR. CIT-1, JAMNAGAR, JAMNAGAR

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.354/Rjt/2024 ("नधा"रण वष" / Assessment Year: (2015-16) Shri Dhimant Rashiklal Shah Vs. The Pr.Cit-1, Home Maker, Opp. Sahvam Patrol Aayakar Bhavan, Taranjali Building, Pump, Saru Section Road, Jamnagar-361008 Jamnagar-361008 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afups2094H (Appellant) (Respondent) Appellant By : Shri Mehul Ranpura, Ld. Ar Respondent By : Smt. Pallavi, Ld. Cit(Dr) : 04/08/2025 Date Of Hearing Date Of Pronouncement : 03/11/2025 आदेश / O R D E R Per, Dinesh Mohan Sinha, Jm:

u/s 263 of the Income-tax Act. The assessee was ask to submitted written submissions to the office of the Ld.PCIT through e- proceedings module of e-filing account on the website https://www.incometax.gov.in or e-mail to jamnagar.pcit@incometax.gov.in or by any other postal modes / personal appearance or through authorized representative latest by 14/03/2024 at materials 11:15 am, falling