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

house property, it is to submit that during\nthe course of assessment proceedings, I had suo-moto offered deemed rental income\nof Rs. 72.000/-p.a. looking to the locality and standardized rent in the area. However,\nwhile finalizing the assessment for the year under consideration, an addition of Rs.\n1,80,000/- was made without bringing any credible evidence

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

154 was carried out, vide order dated\n28.02.2018 wherein addition of Rs.589,63,46,541/-,\nmade 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

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

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

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

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

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

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

SAMIRBHAI SARMANBHAI MARU,JUNAGADH vs. ITO, WARD-1, JUNAGADH, JUNAGADH

In the result, the appeal of the assessee is partly allowed, in above terms

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No. 734/Rjt/2025 (िनधा"रणवष"/Assessment Year: (2017-18) Samir Sarmanbhai Maru The Ito, Ward – 1, Plot No. 142, Raj Laxmi Park, Opp. Vs. Aayakar Bhavan, Shakti Chambers, Reliance Mall, Nr. Motibaug, Morbi – 363641 Junagadh (Guj) - 362001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Agcpm6848G (अपीलाथ"/Assessee) (""थ"/Respondent) Assessee By : Shri Mehul Ranpura, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 03/12/2025 Date Of Pronouncement : 12/01/2026 Order Per, Dr. Arjun Lal Saini, A.M.:

section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by Commissioner of Income-tax (Appeals), dated 20.08.2025, which in turn arises out of an order passed by the Assessing Officer u/s 143(3) of the Act, on 16.12.2019. 2. Grounds of appeal raised by the assessee are as under: “1. The grounds of appeal mentioned

SHRI SHAMJIBHAI SADHABHAI KANGAD,GANDHIDHAM-KUTCH vs. THE DCIT CENTRAL CIRCLE-1 , RAJKOT

property in the assessment order so framed by him. Therefore, the\nsatisfaction note recorded by the assessing officer is itself invalid and bad in law\nand consequently, assessment orders framed by the assessing officer are liable to\nbe quashed. Therefore, we note that required conditions, mentioned above, are\nnot satisfied, hence the “satisfaction note” would be defective, and the assessment