SHRI SHITALBHAI RASIKLAL RAVANI,RAJKOT vs. THE ITO(TDS)-2, RAJKOT

Accordingly, in our considered view, the present appeal is not maintainable and hence the present appeal is being dismissed as non- maintainable

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

TDS officer for non-deduction of taxes at source towards purchase of property. However, it was submitted that as per Section 253 of the Act, there is no such sub-Section under which appeal could be filed before the Tribunal, and accordingly the present appeal is not maintainable in the first instance. 6. We have been perused the rival contentions

SHRI GANDHI MAULANA AZAD SHRAMJIVI ASHRA,KUTCH vs. INCOME TAX OFFICER, EXEMPTION WARD 1, RAJKOT, RAJKOT

In the result, appeals of the assessee, are allowed

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

147 of the Act and inapplicable till the issuance of notice under Section 148 of the Act. 6. The Scheme is clearly applicable for issuance of notice under section 148 of the Act and accordingly, it is only the FAO which can issue the notice under section 148 of the Act and not the JAO. 7. In this regards

SHRI GANDHI MAULANA AZAD SHRAMJIVI ASHRA,KUTCH vs. INCOME TAX OFFICER, EXEMPTION WARD 1, RAJKOT, RAJKOT

In the result, appeals of the assessee, are allowed

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

147 of the Act and inapplicable till the issuance of notice under Section 148 of the Act. 6. The Scheme is clearly applicable for issuance of notice under section 148 of the Act and accordingly, it is only the FAO which can issue the notice under section 148 of the Act and not the JAO. 7. In this regards

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

147/- (Rs. 21,03,18,355/- less Rs. 19,15,32,208/-) in income tax return (ITR). In support of this, the assessee has submitted before the assessing officer the copy of computation of income for assessment year (Α.Υ.) 2020-21. On these facts, no adverse inference was drawn by the assessing officer. The Company has made certain donations

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

147/- (Rs. 21,03,18,355/- less\nRs. 19,15,32,208/-) in income tax return (ITR). In support of this, the assessee\nhas submitted before the assessing officer the copy of computation of income\nfor assessment year (A.Y.) 2020-21. On these facts, no adverse inference was\ndrawn by the assessing officer. The Company has made certain donations,\nwhich

ALPHA HI-TECH FUEL LTD.,,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, SNR CIRCLE,, SURENDRANAGAR

In the result the appeal filed by the assessee is allowed

Bench: Shri Waseem Ahmed & Shri T.R. Senthil Kumarआयकरअपीलसं./I.T.A. No.68/Rjt/2009 (धििाधरणणवध/ Assessment Year 2005-06) Alpha Hi-Tech Fuel Limited, बिाम/ D.C.I.T, Station Road, Surendranagar Vs. Lakhtar, Dist. Surendranagar, Gujarat-382775 स्ायीलेखासं./जीआइआरसं./Pan/Gir No. : Aaaca4258P (अपीला््/Appellant) (प्य््/ Respondent) अपीला््थरसे/ Appellant By : Shri Kalpesh Doshi, A.R Shri B.D Gupta, Sr. D.R. प्य््करथरसे/Respondent By: सुिणाईकरतारीख/ Date Of Hearing 08/06/2023 घोवणाकरतारीख/Date Of Pronouncement 05/09/2023 आदेश/ O R D E R Per Waseem Ahmed:

147 of the Act for calculating the tax liability under the provisions of section 115JB of the Act. However, the assessee during the assessment proceedings has also made submissions regarding the admissibility of his claim under the provisions of section 80IA of the Act. The relevant fact from the assessment order is extracted below: The assessee has no submitted

SHREE SWAMINARAYAN MANDIR TRUST ,RAMPAR vs. THE ITO, EXEMPTION WARD - 1, RAJKOT

In the result, appeal filed by the assessee is allowed for statistical purpose, in above terms

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.340/Rjt/2024 ("नधा"रण वष" / Assessment Year: (2020-21)

TDS on such expenses. The assessee even has failed to explain the nature and bifurcation of such religious expenses claimed. All the above facts prove that the expense claimed by the assessee are non-genuine and without any documentary evidence which point to the fact that all the transactions shown by the assessee in its ITR are manipulated to adjust

PARSHWA PRINT PACK PVT. LTD.,,WADHWAN vs. THE ASSISTANT COMMR. INCOME TAX, SURENDRANAGAR CIRCLE,, SURENDRANAGAR

In the result, the appeal of the assessee is allowed for the statistical purposes

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmed

TDS deducted etc. As far as the issue of retraction of statements by impugned parties and their subsequent filing of sworn affidavits alleging coercion and duress is concerned, i! is seen that the appellant has attempted to introduce the impugned sworn affidavits as additional evidences Apropos, to the discussions made m the preceding paras, it has been held'that

PARSHWA PRINT PACK PVT. LTD.,,WADHWAN vs. THE ASSISTANT COMMR. INCOME TAX, SURENDRANAGAR CIRCLE,, SURENDRANAGAR

In the result, the appeal of the assessee is allowed for the statistical purposes

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmed

TDS deducted etc. As far as the issue of retraction of statements by impugned parties and their subsequent filing of sworn affidavits alleging coercion and duress is concerned, i! is seen that the appellant has attempted to introduce the impugned sworn affidavits as additional evidences Apropos, to the discussions made m the preceding paras, it has been held'that

PARSHWA PRINTPACK PVT. LTD.,,SURENDRANAGAR vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE,, SURENDRANAGAR

In the result, the appeal of the assessee is allowed for the statistical purposes

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmed

TDS deducted etc. As far as the issue of retraction of statements by impugned parties and their subsequent filing of sworn affidavits alleging coercion and duress is concerned, i! is seen that the appellant has attempted to introduce the impugned sworn affidavits as additional evidences Apropos, to the discussions made m the preceding paras, it has been held'that

DREAM INFRASTRUCTURE,RAJKOT vs. THE INCOME TAX OFFICER, WARD - 1(1)(1), RAJKOT, RAJKOT

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

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./Ita No. 220/Rjt/2025 ("नधा"रण वष" / Assessment Year: 2011-12) Dream Infrastructure, Vs. Income Tax Officer, Mavdi Survey No. 358, B/H. Mavdi Ward-1(1)(1), Village, Kankot Road, Mavdi, Rajkot Rajkot-360004(Guj) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahfd2565L (Assessee) (Respondent) Assessee By : Shri D.M. Rindani, Ar Respondent By : Shri Abhimanyu Singh Yadav, Sr. Dr Date Of Hearing : 22/09/2025 Date Of Pronouncement : 04/12/2025

section 147 of the Act, if the Assessing Officer has a reasonable belief that income has escaped assessment. In assessee`s case, the Assessing Officer acted upon specific information received from the DCIT Central Circle-1, Rajkot. which led to the reopening of the ITA No.220/RJT/2025/AY.2011-12 Dream Infrastructure assessment. The fact that there were discrepancies in the accounting records

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

147 read with section 144B of the Income tax Act, 1961, on 28th March 2022, accepting returned income of Rs.10,26,350/- 3. Later on, Learned Principal Commissioner of Income-tax (in short “Ld PCIT”) has exercised his jurisdiction under section 263 of the Income-tax Act, 1961. The MansukhbhaiKanjibhai Sakariya Vs. Pr.CIT 3 learned PCIT, on perusal of case

M/S SHREEJI CONSTRUCTION CO.,,RAJKOT vs. THE INCOME TAX OFFICER, WARD-2(1) (1), RAJKOT

In the result, the case is being restored to the file of the Ld

TDS. The ld. CIT(A) has erred in law as well as on facts in confirming disallowance of Rs. 8,06,835/-. The appellant craves leave add, alter, amend, delete or withdraw one or more grounds of appeal.” 3. Briefly stated the relevant facts are that the assessee’s case was reopened under section 147

THE DY. COMMR. OF INCOME TAX, CIR.-1(2), RAJKOT-GUJARAT vs. M/S DML EXIM PVT. LTD.,, RAJKOT-GUJARAT

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

Section 143(3) & 143(3) r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred as to “the Act”) for the Assessment Year (A.Y.) 2014-15 & 2011-12 respectively. ITA No. 229/Rjt/2017 (A.Y. 2014-15):- 2. Grounds of appeal raised by the Revenue are as under: “1. The learned CIT(Appeal) has erred in law and on facts in deleting

THE DCIT, CIRCLE-1(2), RAJKOT vs. M/S. DRB COMMODITIES PVT. LTD., RAJKOT

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

Section 143(3) & 143(3) r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred as to “the Act”) for the Assessment Year (A.Y.) 2014-15 & 2011-12 respectively. ITA No. 229/Rjt/2017 (A.Y. 2014-15):- 2. Grounds of appeal raised by the Revenue are as under: “1. The learned CIT(Appeal) has erred in law and on facts in deleting

THE DCIT, CIRCLE-1 (2), RAJKOT vs. SHRI NARENDRA NANJIBHAI DAVDA, RAJKOT

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

Section 143(3) & 143(3) r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred as to “the Act”) for the Assessment Year (A.Y.) 2014-15 & 2011-12 respectively. ITA No. 229/Rjt/2017 (A.Y. 2014-15):- 2. Grounds of appeal raised by the Revenue are as under: “1. The learned CIT(Appeal) has erred in law and on facts in deleting

THE DCIT, CIRCLE-1(2), RAJKOT vs. M/S. D.M.L. WORLD TRADE PVT. LTD., RAJKOT

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

Section 143(3) & 143(3) r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred as to “the Act”) for the Assessment Year (A.Y.) 2014-15 & 2011-12 respectively. ITA No. 229/Rjt/2017 (A.Y. 2014-15):- 2. Grounds of appeal raised by the Revenue are as under: “1. The learned CIT(Appeal) has erred in law and on facts in deleting

THE DCIT, CIRCLE 2(1), RAJKOT-GUJARAT vs. SMT MEENABEN H LAKHANI, RAJKOT-GUJARAT

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

Section 143(3) & 143(3) r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred as to “the Act”) for the Assessment Year (A.Y.) 2014-15 & 2011-12 respectively. ITA No. 229/Rjt/2017 (A.Y. 2014-15):- 2. Grounds of appeal raised by the Revenue are as under: “1. The learned CIT(Appeal) has erred in law and on facts in deleting