SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,,JUNAGADH vs. THE INCOME TAX OFFICER-WARD 1(2)(4),, RAJKOT

revised order u/s 263 of the Act and setting aside the assessment orders for de novo assessment and there are also, the AO has made entire addition. The Ld. CIT-DR also submitted that assessee has submitted on page-31, which is only a declaration under VSVS-Scheme wherein the assessee has agreed to pay tax under the VSVS

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ACIT, CENTRAL CIRL-1,, RAJKOT

In the result, appeals filed by the Revenue, in ITA No

Bench: Dr. Arjun Lal Saini & Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 134 & 135/Rjt/2023 (िनधा"रणवष" / Assessment Years: (2007-08 & 2008-09) Income Tax Officer, Ward- Shri Kherajmal Lekhrajbjai 5Th 1(2)(1), Aaykar Bhavan, Thavrani, 4- Parsana Nagar, Shri Vs. Floor, Room No. 517, Race Vaheguru Grupa, Near Refugee Course Ring Road, Rajkot-360 Colony, Rajkot-360 001 001 "थायी लेखा सं./जी आइ आर सं./Pan/Gir No.: Adrpt 5807 E (Appellant) (Respondent)

revised order u/s 263 of the Act and setting aside the assessment orders for de novo assessment and there are also, the AO has made entire addition. The Ld. CIT-DR also submitted that assessee has submitted on page-31, which is only a declaration under VSVS-Scheme wherein the assessee has agreed to pay tax under the VSVS

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ITO, WARD-1 (1) (2),, RAJKOT

revised order u/s 263 of the Act and setting aside the\nassessment orders for de novo assessment and there are also, the AO has made\nentire addition. The Ld. CIT-DR also submitted that assessee has submitted on\npage-31, which is only a declaration under VSVS-Scheme wherein the assessee\nhas agreed to pay tax under the VSVS

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ITO, WARD-1 (1) (2),, RAJKOT

revised order u/s 263 of the Act and setting aside the\nassessment orders for de novo assessment and there are also, the AO has made\nentire addition. The Ld. CIT-DR also submitted that assessee has submitted on\npage-31, which is only a declaration under VSVS-Scheme wherein the assessee\nhas agreed to pay tax under the VSVS

THE DY. COMMR. OF INCOME TAX, CEN. CIR.-1,, RAJKOT vs. BHARATKUMAR ISHWARBHAI BHATIYA,, RAJKOT

revised order u/s 263 of the Act and setting aside the\nassessment orders for de novo assessment and there are also, the AO has made\nentire addition. The Ld. CIT-DR also submitted that assessee has submitted on\npage-31, which is only a declaration under VSVS-Scheme wherein the assessee\nhas agreed to pay tax under the VSVS

THE ITO WARD-1 (2) (1),, RAJKOT vs. SHRI KHRAJMAL LEKHRAJBHAI THAVRANI, RAJKOT

revised order u/s 263 of the Act and setting aside the\nassessment orders for de novo assessment and there are also, the AO has made\nentire addition. The Ld. CIT-DR also submitted that assessee has submitted on\npage-31, which is only a declaration under VSVS-Scheme wherein the assessee\nhas agreed to pay tax under the VSVS

SHRI BHARATKUMAR ISHWARBHAI BHATIYA,RAJKOT-GUJARAT vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, RAJKOT-GUJARAT

revised order u/s 263 of the Act and setting aside the\nassessment orders for de novo assessment and there are also, the AO has made\nentire addition. The Ld. CIT-DR also submitted that assessee has submitted on\npage-31, which is only a declaration under VSVS-Scheme wherein the assessee\nhas agreed to pay tax under the VSVS

BHARATKUMAR ISHWARBHAI BHATIYA,,RAJKOT vs. ASSTT. COMMR. OF INCOME TAX, CEN. CIR.-1,, RAJKOT

revised order u/s 263 of the Act and setting aside the\nassessment orders for de novo assessment and there are also, the AO has made\nentire addition. The Ld. CIT-DR also submitted that assessee has submitted on\npage-31, which is only a declaration under VSVS-Scheme wherein the assessee\nhas agreed to pay tax under the VSVS

THE INCOME TAX OFFICER-WARD-2,, JUNAGADH vs. SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,, JUNAGADH

revised order u/s 263 of the Act and setting aside the\nassessment orders for de novo assessment and there are also, the AO has made\nentire addition. The Ld. CIT-DR also submitted that assessee has submitted on\npage-31, which is only a declaration under VSVS-Scheme wherein the assessee\nhas agreed to pay tax under the VSVS

THE INCOME TAX OFFICER-WARD-2,, JUNAGADH vs. SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,, JUNAGADH

revised order u/s 263 of the Act and setting aside the\nassessment orders for de novo assessment and there are also, the AO has made\nentire addition. The Ld. CIT-DR also submitted that assessee has submitted on\npage-31, which is only a declaration under VSVS-Scheme wherein the assessee\nhas agreed to pay tax under the VSVS

SURENDRANAGAR DISTRICT CO OP PRODUCERS UNION LIMITED,SURENDRANAGAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, SURENDRANAGAR CIRCLE

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 429/Rjt/2025 ("नधा"रणवष"/Assessment Year: (2014-15) Surendranagar District Co. Op. Acit, Circle, Producers Union Ltd. Vs. Surendranagar-363035 Plot No.249, Phase 2 Gidc Market Yard Circle, Sursagar Dairy, Wadhwan Road, Surendranagar-363035 (Guj) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaas8375B (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Kalpesh Doshi, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : Heard On 09/10/2025, Refixed For Clarification On 03.11.2025 & Finally Heard On 02.02.2026 : 10/02/2026 Date Of Pronouncement Order Per, Dr. Arjun Lal Saini, A.M.:

penalty proceedings u/s 271(1)(c) of the I.T. Act, 1961. 7. That, the Ld. CIT(A) has wrongly confirmed the interest charged u/s 234A/B/C of the I. T. Act, 1961. 8. That, the findings of the Ld. CIT(A) are not justified and are bad-in-law.” 3. First, we shall take ground