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6 results for “condonation of delay”+ Section 149(1)(b)clear

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Key Topics

Section 25016Section 143(3)10Section 1488Section 2637Section 1475Section 148A5Limitation/Time-bar4Unexplained Investment3Addition to Income

JIVANBHAI DE vs. HIBHAI SARLA,THANGADH, DIST. SURENDRANAGARVS.THE ITO WARD-2, SURENDRANAGAR, SURENDRANAGAR

ITA 519/RJT/2025[2013-14]Status: DisposedITAT Rajkot09 Feb 2026AY 2013-14

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

For Appellant: Ms. Devina Patel, ARFor Respondent: Shri Sanjay Punglia, CIT-DR &
Section 147Section 250Section 271(1)(c)

condone the delay in both appeals and admit these appeals for hearing. 7. In both these appeals, the assessee has raised the grounds pertaining to technical issue, being notice issued under section 148 of the Act, is time barred. When these cases were called for hearing, Ld. Counsel for the assessee submitted that the issue under consideration, in both appeals

JIVANBHAI DE vs. HIBHAI SARLA,THANGADH, DIST. SURENDRANAGARVS.THE ITO WARD 2, SURENDRANAGAR, SURENDRANAGAR

3
Section 1492
Section 69A2
Exemption2
ITA 521/RJT/2025[2014-15]Status: Disposed
ITAT Rajkot
09 Feb 2026
AY 2014-15

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

For Appellant: Ms. Devina Patel, ARFor Respondent: Shri Sanjay Punglia, CIT-DR &
Section 147Section 250Section 271(1)(c)

condone the delay in both appeals and admit these appeals for hearing. 7. In both these appeals, the assessee has raised the grounds pertaining to technical issue, being notice issued under section 148 of the Act, is time barred. When these cases were called for hearing, Ld. Counsel for the assessee submitted that the issue under consideration, in both appeals

SMT. RANI HARERAM SAHANI,KOVAYA, RAJULA, DIST. AMRELI vs. THE ITO, WARD-3 (1) (4), RAJULA, DIST. AMRELI, RAJULA, DIST. AMRELI

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

ITA 148/RJT/2021[2011-12]Status: DisposedITAT Rajkot31 Jan 2023AY 2011-12

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 139Section 143(3)Section 147Section 148

149(1)(b) of the Act and invalid in law. Therefore the same is liable to be quashed. Thus the grounds raised by the Assessee is hereby allowed. I.T.A No. 148/Rjt/2021 & 09/Rjt/2022 A.Y. 2011-12 & 2017-18 Page No 7 Smt. Rani Hareram Sahani vs. ITO 5. In the result, the appeal filed by the Assessee is allowed. 7. This

SMT. RANI HARERAM SAHANI,KOVAYA, RAJULA, DIST. AMRELI vs. THE ACIT, WARD-2 (4), BHAVNAGAR, BHAVNAGAR

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

ITA 9/RJT/2022[2017-18]Status: DisposedITAT Rajkot31 Jan 2023AY 2017-18

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 139Section 143(3)Section 147Section 148

149(1)(b) of the Act and invalid in law. Therefore the same is liable to be quashed. Thus the grounds raised by the Assessee is hereby allowed. I.T.A No. 148/Rjt/2021 & 09/Rjt/2022 A.Y. 2011-12 & 2017-18 Page No 7 Smt. Rani Hareram Sahani vs. ITO 5. In the result, the appeal filed by the Assessee is allowed. 7. This

SHREEJI CERAMIC INDUSTRIES,MORBI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAJKOT

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

ITA 266/RJT/2024[2015-16]Status: DisposedITAT Rajkot12 Aug 2025AY 2015-16

Bench: Dr. A.L.Saini, Am & Diesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.266/Rjt/2024 ("नधा"रणवष" / Assessment Year: (2015-16) (Hybrid Hearing) Shreeji Ceramic Industries, The Principal Commissioner Of Vs. 8/A National Highway, Lalpar Income Tax – 1, Morbi - 363642 Rajkot "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aalfs8846B (Appellant) (Respondent) Appellant By : Shri D. M. Rindani, Ld. Ar Respondent By : Shri Sanjay Punglia, Cit (Dr) सुनवाईक"तार"ख/ Date Of Hearing : 17/07/2025 घोषणाक"तार"ख/Date Of Pronouncement : 12/08/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm: This Appeal Has Been Filed By The Assessee Against The Order Of Learned Principle Commissioner Of Income Tax, Rajkot – 1 [In Short, “The Ld. Pcit”], Dated 30.03.2021 For The Assessment Year (Ay) 2015-16. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows.

For Appellant: Shri D. M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT (DR)
Section 142(1)Section 143(2)Section 143(3)Section 144Section 263Section 263o

149). As mentioned in the judgement, liberal approach is Assessment Year.2015-16 Shreeji Ceramic adopted by the Hon’ble High Court in such a matter so as to ensure that substantive rights are not defeated on the basis of technicalities or limitation. The relevant para of judgement is reproduced in the application under para 20. As mentioned in para

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

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

ITA 939/RJT/2024[2017-18]Status: DisposedITAT Rajkot07 May 2025AY 2017-18

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

For Appellant: Shri Rajendra Singhal, A.RFor Respondent: Shri Abhimanyu Singh Yadav, Sr. D.R
Section 147Section 148Section 148ASection 149Section 151Section 151ASection 69A

b) of the Act was issued, in violation of the provisions of sec. 149 of the Act, as there were no any books of account/document or evidence in his possession, which might had revealed escapement of income. e. The order u/s 148A(d) of the Act was passed without approval of the competent specified authority