SHRI MANDORANA VIVIDH KARYAKARI SAHAKARI MANDLI LIMITED ,VILLAGE-MANDORANA vs. INCOME TAX OFFICER , VERAVAL

In the result, grounds raised by the assessee in both the appeals are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini

144B of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’), dated 29.02.2024 and 29.03.2023. ITA Nos. 870 & 872/Rjt/2025 A.Ys. 19-20 & 18-19 Sh. Mandorana Vividh Karyakari Sahakari Mandli Ltd. 2. Since, the issue involved in both the appeals, are common and identical; therefore, both these appeals have been clubbed and heard together and a consolidated order

SHRI MANDORANA VIVIDH KARYAKARI SAHAKARI MANDLI LIMITED ,JND-VERAVAL vs. INCOME TAX OFFICER , VERAVAL

In the result, grounds raised by the assessee in both the appeals are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini

144B of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’), dated 29.02.2024 and 29.03.2023. ITA Nos. 870 & 872/Rjt/2025 A.Ys. 19-20 & 18-19 Sh. Mandorana Vividh Karyakari Sahakari Mandli Ltd. 2. Since, the issue involved in both the appeals, are common and identical; therefore, both these appeals have been clubbed and heard together and a consolidated order

BHAVESHBHAI HARIBHAI KANANI,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee is partially allowed in above terms

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.233/Rjt/2025 िनधा"रण वष"/Assessment Year : 2018-19 बनाम/ Bhaveshbhai Haribhai Kanani Income Tax Officer Plot No. E211, Gidc Phase-2, Vs Ward – 2(10), Jamnagar Dared, Jamnagar, Gujarat - 361008 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Acypk5085F (अपीलाथ"/Appellant) (""थ"/Respondent)

144B of the Act, on 20.04.2021. Bhaveshbhai Haribhai Kanani vs. ITO 2. The appeal filed by the assessee is barred by limitation by 70 days. The assessee moved a petition for condonation of delay, requesting the Bench to condone the delay. Learned Counsel for the assessee, referring to the contents of the petition for condonation of delay has submitted that

AMITKUMAR RAMKISHORBHAI SHARMA,MORBI vs. INCOME TAX OFFICER, WARD - 1, MORBI

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

Section 144B of the Income Tax Act, 1961. 2. Grounds of appeal raised by the assessee are as follows: 1. Order u/s. 147 r.w.s 144 r.w.s 144B of the Act is bad in law. 2. The Id. CIT(A) has erred in law as well as on facts in dismissing the appeal by not condoning the delay

KALPESH RAVJIBHAI SOJITRA,JASDAN vs. THE INCOME TAX OFFICER, WARD 2(1)(2), RAJKOT, RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrid Hearing) Kalpesh Ravjibhai Sojitra, Vs. The Ito, Prop. Sojitra Petrolium, Bypass Ward-2(1)(2), Circle Atkot Road, Jasdan, Rajkot 360050, Rajkot-( Guj) "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Bqmps8120G (/Appellant) (/Respondent)

condone the delay and didn’t admit the appeal. Aggrieved, the assessee is before us. 12. Since, the notice u/s.142(1) dated 28.07.2023 was issued pursuant to the reopening u/s.148 by the JAO dated 09.03.2023 which we have already quashed. As a sequitur the notice u/s.142(1) dated 27.08.2023 is null in the eyes of law and therefore

PRATIKKUMAR SHASHIKANTBHAI JAVIYA,RAJKOT vs. INCOME TAX OFFICER, RAJKOT

In the result, these three appeals of the assessee, are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita No.866, 867 & 868/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2013-14, 2014-15 & 2015-16 Pratikkumar Shashikantbhai Javiya Ito, Ward-1(1)(1) बनाम B-401, Cosmos Pride, Rajkot. Field Marshal Road Vs. Opp: Speed Well Party Plot Rajkot. Pan :Aiwpj 0996 Q (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रतीक"ओरसे/Assessee By : Shri R.D. Lanchandani, Ld.Ar राज"वक"ओरसे/Revenue By : Shri Abhimanyu Singh Yadav, Sr-Dr

section 250 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’), all dated 22.10.2024,which in turn arise PratikkumarShashikantbhaiJaviya ITA No.866 to 868/RJT/2024 (AY : 2013-14 to 2015-16) 2 out of separate assessment orders passed by the Assessing Officer u/s 147 r.w.s. 144B of the Act, all dated 17.9.2021. 2.Since the issue involved in all these

JIGNESH NARENDRABHAI MANDALIYA,RAJKOT vs. THE INCOME TAX OFFICER, WARD 2(1)(1), RAJKOT, RAJKOT

In the result, ground raised by the assessee is allowed for statistical purposes

Bench: Dr. Arjun Lal Saini

section 115BBE is bad in law &illegal needs cancellation.” 3. The appeal filed by the assessee, before the Tribunal, is barred by limitation by 104 days. The assessee moved a petition (an affidavit) for condonation of delay, requesting the Bench to condone the delay. The Learned Counsel for the assessee, explained the reasons for delay stating that Ld. Commissioner

CHINTAN DWARKADAS CHOTAI,JUNAGADH vs. DCIT/ACIT CIR 1(1), RKT, RAJKOT

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

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

144B of the Income Tax Act, 1961 (hereinafter referred to as “the Act”), vide order dated 27.12.2024. 2. Grounds of appeal raised by the assesse, are as follows: “1. In law and in the facts and circumstances of the appellant's case, the Learned Commissioner of Income Tax (Appeals) has failed to admit the appeal by refusing to condone

SHREE JAMNAGAR JILLA SAHAKARI KHARID VECHAN SANGH LIMITED,JAMNAGAR vs. DCIT-CIR-2(1), JAMNAGAR

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./ Ita No.223/Rjt/2025 "नधा"रण वष"/Assessment Year : 2018-19

section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income-tax (Appeals), dated 18.02.2025, which in turn arises out of an order passed by National e- Assessment Centre, Delhi/Assessing Officer u/s 144 r.w.s. 144B of the Act, on 17.04.2021. ITA NO. 223/Rjt/2025 A.Y 18-19 Sh.J.J.S.K.V.S.Ltd

POOJA OMPRAKASH NAWANI,ADIPUR vs. THE INCOME TAX OFFICER WARD 2, GANDHIDHAM, GANDHIDHAM

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.876/Rjt/2024 "नधा"रणवष" / Assessment Year: (2018-19) (Hybrid Hearing) Pooja Omprakash Nawani Vs. The Income-Tax Officer, Flat-5 Nirav Appartment, Plot-358 Ito Ward – 2, Ward-2B, Gandhidham - 370205 Adipur 370205 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acfpn4546H (Appellant) (Respondent) Appellant By : Shri Chetan Agarwal, Ld. Ar Respondent By : Shri K. L. Solanki, Ld. Sr. Dr Date Of Hearing : 24 / 04 /2025 Date Of Pronouncement : 08 / 07 /2025

144B of the Act on 16.03.2023 on assessed income of Rs. 1,19,10,999/-. However, penalty proceedings u/s 272A(1)(d) were initiated separately by issue of notice u/s 274 r.w.s 272A(1) (d) of the Act dated 15.03.2023 for non-compliance of aforementioned notices u/s 142(1) of the Act. "The assesses husband and son were both

SHREE MARU KANSARA SONI GNATI,ANJAR vs. ITO EXEMPTION WARD-1 RAJKOT, RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./Ita No. 789/Rjt/2025 धििाारण वर्ा/Assessment Year: (2017-18) Shree Maru Kansara Soni Gnati बनाम Income Tax Officer (Exemption), /Vs. C/O Rajesh K Soni, Shashtri Road, Ward- 1, Rajkot, Anjar, Kutch-360 001(Gujarat) It Office, New Aayakar Bhavan,Vatiaka, Rajkot-360 001 स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aarts 1920 N (Appellant) (Respondent)

144B of the Act, dated 30.03.2022. 2. Grounds of appeal raised by the assessee are as follows: 1. That, the Ld. AO has wrongly re-opened assessment u/s. 147 of 1 the I.T. Act, 1961. 2. That, the Ld. AO has failed to issue the statutory notice u/s 143(2) of the I.T. Act, 1961. ITA No. 789/RJT/2025

SHREE PINDARA SEVA SAHKARI MANDALI LIMITED,DEVBHUMI DWARKA vs. INCOME TAX OFFICER (W), DWARKA

In the result, the appeal of the assessee, is allowed for statical purpose

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.404/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2018-19 Shree Pindara Seva Sahkari Mandali Income Tax Officer, Wd-1, बनाम Ltd. At Pindara, Taluka Kalyanpur, Dwarka-361335 Devbhumi Dwarka (Guj) -361315 Vs. Pan No. : Aajas7145N (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Shreyash Sheth, Ld. Ar राज"व क" ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Ld.Sr.Dr सुनवाई क" तार"ख /Date Of Hearing : 17/11/2025 घोषणा क" तार"ख /Date Of Pronouncement : 16/01/2026 Order Per, Dr. Dinesh Mohan Sinha, Jm:

144B of the Income Tax Act, 1961 (hereinafter referred to as "the Act"), vide order dated 28.04.2021. 2. At the outset, Learned Counsel of the assessee submitted that there was delay in filing the appeal for 74 days, before Ld. CIT(A). The assessee filed the petition Sh. Pindara Seva Sahkari Mandali Ltd. for condonation of delay before

FOTDI PASHUPALAN MANDAL,FOTDI vs. THE INCOME TAX OFFICER WARD 1, GANDHIDHAM, GANDHIDHAM

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

Bench: Dr.Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./I.T.A. No.64/Rjt/2024 ("नधा"रणवष" / Assessment Year: 2018-19) बनाम/ Fotdi Pashupalan Mandal The Income Tax Officer, Fotdi, B.O, Fotdi, Ward 1, Vs. Kachchh -370040 Income Tax Office, Plot No. 32, Sector – 3, Nr. Iffco Colony, Gandhidham Gujarat- 370201 "थायीलेखासं./जीआइआरसं./Pan/Gir No. :Aaaaf4643B (अपीलाथ"/Appellant) .. (""यथ" / Respondent) अपीलाथ"क" ओरसे/ Appellant By : Shri Jignesh Parikh, Ld. Ar ""यथ"क"ओरसे/Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr सुनवाईक"तार"ख/ Date Of Hearing 16/10/2024 घोषणाक"तार"ख /Date Of Pronouncement 06/01/2025 आदेश / O R D E R Per Shridinesh Monhan Sinha, Judicialmember : Captioned Appeal Filed By The Assessee Is Directed Against The Order Passed By The National Faceless Appeal Centre [(In Short “Nfac/Ld. Cit(A)”] Vide Order Dated 28/11/2023, Which In Turn Assessment Order Passed By Assessment Unit, Income Tax Department / Assessing Officer Under Section 147 R.W.S. 144 R.W.S. 144B Of The Income Tax Act, 1961 (In Short “The Act”).

section 147 r.w.s. 144 r.w.s. 144B of the Income Tax Act, 1961 (in short “the Act”). 2. The petitioner has filed an appeal before the Ld. CIT(A) on 26.05.2023, that the assessee has filed appeal before us. The Ld. CIT(A) has disposed of the appeal of the appellant by observing that appellant fail to furnish sufficiently and Fotdi

SATYENDRA KUMAR,GANDHIDHAM vs. THE INCOME TAX OFFICER WARD-1, GANDHIDHAM, GANDHIDHAM

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.909/Rjt/2024 "नधा"रणवष" / Assessment Year: (2020-21) (Hybrid Hearing) Satyendra Kumar Vs. Income-Tax Officer, Plot No-72 Ward-7B., Ito Ward – 1, Gandhidham, Kutch - 370201 Gandhidham - 370201 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aeapk7626J (Appellant) (Respondent) Appellant By : Shri Chetan Agarwal, Ld. Ar Respondent By : Shri K. L. Solanki, Ld. Sr. Dr Date Of Hearing : 24 / 04 /2025 Date Of Pronouncement : 04/ 07 /2025

section 144B of the Income Tax Act, 1961. Satyendrakumar vs. The I.T. Officer ward-1 2. GROUNDS OF APPEALS:- 1. Learned CIT(A) erred in law as well as on facts in dismissing appeal on ground of limitation without condoning delay

RAFIKBHAI AJIJBHAI VIRANI,JAMNAGAR vs. THE ASSESSEMENT UNIT NFAC INCOME TAX DEPARTMENT, DELHI

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 141/Rjt/2025 ("नधा"रण वष"/Assessment Year: (2017-18) Rafikbhai Ajijbhai Virani बनाम The Assessment Unit, National Steet No.2, Near Navnala, Faceless Assessment Center, Income /Vs. Gulabnagar Tari Hanuman Tax Department Road, Jamnagar-361007 "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Ascpv 1519 R (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Appellant By : Shri Sankar Bakshi, A.R. राज"व क" ओर से/Respondent By : Shri Abhimanyu Singh Yadav, Sr. D.R. सुनवाई क" तार"ख/ Date Of Hearing : 23/07/2025 घोषणा क" तार"ख/Date Of Pronouncement : 23/07/2025 आदेश / O R D E R Per Dr. Arjun Lal Saini: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Order (Ay) 2017-18, Is Directed Against The Order Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) Passed By The National Faceless Appeal Centre (Nfac), Delhi/Learned Commissioner Of Income Tax(Appeals) (In Short “Ld.Cit(A)”, Dated 18.06.2024, Which In Turn Arises Out Of An Assessment Order Passed By The Assessing Officer U/S 147 R.W.S. 144 R.W.S 144B Of The Act Dated 19.05.2023. The Assessee Has Raised The Following Grounds Of Appeal:- 2. “Reopening U/S 148A Of The Income Tax Act, 1961 (“The Act”) 1. The Learned The National Faceless Appeal Centre [“The Cit(A)”] & The Assessment Unti, Income Tax Department (“The Ao”) Erred In Fact & In Law In Initiating Proceedings U/S 148 Of The Act Without Issuing Notice U/S Ita No. 141/Rjt/2025 A.Y.17-18 Rafikbhai A Virani

section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) passed by the National Faceless Appeal Centre (NFAC), Delhi/Learned Commissioner of Income Tax(Appeals) (in short “Ld.CIT(A)”, dated 18.06.2024, which in turn arises out of an assessment order passed by the Assessing Officer u/s 147 r.w.s. 144 r.w.s 144B of the Act dated

VINOD LALJIBHAI VADSOLA,TIMBADI vs. ITO, WARD-1, MORBI

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 939/Rjt/2024 ("नधा"रण वष"/Assessment Year: (2017-18) Vinod Laljibhai Vadsola Income Tax Officer, Ward-1, Vill. Timbadi, Tal: Morbi- Morbi-363 641 Vs. 363 641 "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Alnpv 3995 K (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Appellant By : Shri Rajendra Singhal, A.R. राज"व क" ओर से/Respondent By : Shri Abhimanyu Singh Yadav, Sr. D.R. सुनवाई क" तार"ख/ Date Of Hearing : 05/05/2025 घोषणा क" तार"ख/Date Of Pronouncement : 07/05/2025 आदेश / O R D E R Per Dr. Arjun Lal Saini: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Order (Ay) 2017-18, Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax(Appeals) / National Faceless Appeal Centre, Delhi (In Short “Cit(A)”, Dated 09.08.2024, Which In Turn Arises Out Assessment Order Passed By The Assessing Officer U/S 147 R.W.S. 144B Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act” Dated 25.05.2023. The Assessee Has Raised The Following Grounds Of Appeal:- 2. “The Grounds Of Appeal Mentioned Hereunder Are Without Prejudice To One Another. 1. The Ld.Cit(Appeals) Has Erred In Law & On The Facts In Holding Assessment Proceedings As Valid Through: A. The Notice U/S 148 Of The Act Has Been Issued By The Ito, Ward-1, Morbi In Violation Of The Provisions Of Sec. 151A Of Act & The Ita No. 939/Rjt/2024 A.Y.17-18 Vinod L. Vadsola

144B of the Income Tax Act, 1961 (hereinafter referred to as “the Act” dated 25.05.2023. The assessee has raised the following grounds of appeal:- 2. “The grounds of appeal mentioned hereunder are without prejudice to one another. 1. The ld.CIT(Appeals) has erred in law and on the facts in holding assessment proceedings as valid through: a. The notice

SHRI PRAKASH BHIKHABHAI THAKKAR,RAJKOT vs. THE ITO, NFAC DELHI, DELHI

In the result, appeal filed by the assessee, is partly allowed, to the extent indicated above

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No.412/Rjt/2025 "नधा"रणवष" / Assessment Year: (2019-20) (Hybrid Hearing) Prakash Bhikhabhai Thakkar Vs. Income Tax Department, C/O. "Krushna House", 3Rd National Faceless Floor, Assessment B/H. Alishan Flats, Centre, Near Raiya Telephone Delhi 110001 Exchange, Rajkot 360005 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afjpt6621C (Appellant) (Respondent)

section 144B of the Income Tax Act, 1961. Prakash Bhikhabhai Thakkar, 2. Grounds of appeal raised by the assessee are as follows: “(1) Assessment Order passed u/s. 143(3) r.w.s. 144B of the 1. T. Act, 1961 is bad in law. (2) The Learned AO has erred in law as well as fact in disallowing the expense

SHRI NARENDRA DHARAMDAS GIDWANI,ANJAR KUTCH vs. THE ADDL. CIT, NFAC, , NEW DELHI

In the result, the appeal of the assessee is partly allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 220/Rjt/2023 ("नधा"रणवष" / Assessment Year: (2015-16) (Hybrid Hearing) Narendra Dharamdas Gidwani, The Commissioner Of Income Vs. Plot No. 29, Survey No. 193/1, Maitru Tax(Appeals), Residency Meghpar Borichi, Anjar, National Faceless Appeal Centre Kutch, (Nfac), Delhi, Income Tax Gujarat - 370110 Department, Ministry Of Finance, Government Of India "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Akmpg6386M (Appellant) (Respondent) Appellant By : Shri Chiranjeev Tandon, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 26/03/2025 Date Of Pronouncement : 09/06/2025 आदेश / O R D E R Per D. M. Sinha, Jm:

144B of the Act, on 02.03.2022. Narendra D. Gidwani 2. Grounds of appeal raised by the assessee are as follows: 1) 1 That Impugned Order dated March 27, 2023 has been passed without application of mind as learned appellate authority has merely reiterated allegations of notice and confirmed assessment order without considering submissions of Appellant made in first appeal, evidence