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

142(1) / 143(2) of the\nIncome tax Act, 1961.\nNO.\ndated\nhave concealed the particulars of your income by furnishing inaccurate particulars\nof such income.\nYou are hereby requested to appear before me on 20/07/2017 at 10.30 A.M. and\nshow cause as to why an order imposing a penalty on you should not be made under section\n271(1

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

142(1) / 143(2) of the\nIncome tax Act, 1961.\nNO.\ndated\nhave concealed the particulars of your income by furnishing inaccurate particulars\nof such income.\nYou are hereby requested to appear before me on 20/07/2017 at 10.30 A.M. and\nshow cause as to why an order imposing a penalty on you should not be made under section\n271(1

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

iii) Hon'ble ITAT, Rajkot Bench Rajkot in the case of ITO vs. Admiracle Advertising\nPvt. Ltd, ITA No. 07/Rjt/2010 and 649/Rj1/2010.\n\n14. Thus there is no question of any concealment of income in respect of addition\nmade on notional basis and therefore, proposal to levy u/s. 271(1)(c) of the Act may\nkindly be dropped

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

iii) Hon'ble ITAT, Rajkot Bench Rajkot in the case of ITO vs. Admiracle Advertising\nPvt. Ltd, ITA No. 07/Rjt/2010 and 649/Rj1/2010.\n14. Thus there is no question of any concealment of income in respect of addition\nmade on notional basis and therefore, proposal to levy u/s. 271(1)(c) of the Act may\nkindly be dropped

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

142(1) / 143(2) of the\nIncome tax Act, 1961.\nNO.\ndated\nhave concealed the particulars of your income by furnishing inaccurate particulars\nof such income.\nYou are hereby requested to appear before me on 20/07/2017 at 10.30 A.M. and\nshow cause as to why an order imposing a penalty on you should not be made under section\n271(1

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

142(1) of the Act, was issued to assessee to produce the documentary evidence related to credit in his bank accounts. In response of notice, assessee submitted certain details on 25.02.2023 including computation of income, bank account statements and certain case laws. The assessee submitted the bank statements of all the bank accounts, confirming the cash deposits/credits in the bank

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

142(1) of the Act, was issued to assessee to produce the documentary evidence related to credit in his bank accounts. In response of notice, assessee submitted certain details on 25.02.2023 including computation of income, bank account statements and certain case laws. The assessee submitted the bank statements of all the bank accounts, confirming the cash deposits/credits in the bank

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

142(1) of the Act, was issued to assessee to produce the documentary evidence related to credit in his bank accounts. In response of notice, assessee submitted certain details on 25.02.2023 including computation of income, bank account statements and certain case laws. The assessee submitted the bank statements of all the bank accounts, confirming the cash deposits/credits in the bank

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

142(1) of the Act, was issued to assessee to produce the documentary evidence related to credit in his bank accounts. In response of notice, assessee submitted certain details on 25.02.2023 including computation of income, bank account statements and certain case laws. The assessee submitted the bank statements of all the bank accounts, confirming the cash deposits/credits in the bank

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

142(1) of the Act, was issued to assessee to produce the documentary evidence related to credit in his bank accounts. In response of notice, assessee submitted certain details on 25.02.2023 including computation of income, bank account statements and certain case laws. The assessee submitted the bank statements of all the bank accounts, confirming the cash deposits/credits in the bank

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

142(1) of the Act, was issued to assessee to produce the documentary evidence related to credit in his bank accounts. In response of notice, assessee submitted certain details on 25.02.2023 including computation of income, bank account statements and certain case laws. The assessee submitted the bank statements of all the bank accounts, confirming the cash deposits/credits in the bank

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

142(1) of the Act, was issued to assessee to produce the documentary evidence related to credit in his bank accounts. In response of notice, assessee submitted certain details on 25.02.2023 including computation of income, bank account statements and certain case laws. The assessee submitted the bank statements of all the bank accounts, confirming the cash deposits/credits in the bank

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

142(1) of the Act, was issued to assessee to produce the documentary evidence related to credit in his bank accounts. In response of notice, assessee submitted certain details on 25.02.2023 including computation of income, bank account statements and certain case laws. The assessee submitted the bank statements of all the bank accounts, confirming the cash deposits/credits in the bank

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

142(1) of the Act, was issued to assessee to produce the documentary evidence related to credit in his bank accounts. In response of notice, assessee submitted certain details on 25.02.2023 including computation of income, bank account statements and certain case laws. The assessee submitted the bank statements of all the bank accounts, confirming the cash deposits/credits in the bank

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

iii) Penalty order-ITA No.530/Rjt/2025 Α.Υ. 2015-16 Penalty\nu/s.271F of the Act\nTherefore, above penalties are deleted and above appeals of the assessee, are\nallowed.\n20. Now, we shall take assessee`s remaining appeals for assessment year 2013-\n14 and for assessment year 2014–15, and for assessment year 2016-17, the details\nof these appeals, assessment year

ATMAN RAJNIKANT BHESDADIYA L/R. LATE SHRI RAJNIKANT LAVJIBHAI BHEDADIYA,RAJKOT vs. THE DCIT, CENTRAL CIRCLE-1, RAJKOT, RAJKOT

In the result, appeal of the assessee in ITA No

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

142(1) on 28.07.2017 requiring the assessee to file the Return of Income for A.Y. 2017-18. In response, the assessee filed his Return of Income on 31.03.2018 showing total income of Rs.9,84,720/- which is inclusive of additional income of Rs.7,50,000/- offered by the assessee. It is seen from the assessment records that there

M/S. IMPACT FORGING, ,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , RAJKOT

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

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

penalty proceeding can be initiated under section 271(1)(c) of the Act based on invalid assessment order. 13.1 The procedure under section 153D provides that where the assessment order u/s 153A(1)(b) or 153B(1)(b) is passed by AO below the rank of JCIT, he has to seek approval from the JCIT. The issue arises whether assessment

M/S. IMPACT FORGING, ,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , RAJKOT

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

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

penalty proceeding can be initiated under section 271(1)(c) of the Act based on invalid assessment order. 13.1 The procedure under section 153D provides that where the assessment order u/s 153A(1)(b) or 153B(1)(b) is passed by AO below the rank of JCIT, he has to seek approval from the JCIT. The issue arises whether assessment

M/S. IMPACT FORGING, RAJKOT,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAJKOT, RAJKOT

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

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

penalty proceeding can be initiated under section 271(1)(c) of the Act based on invalid assessment order. 13.1 The procedure under section 153D provides that where the assessment order u/s 153A(1)(b) or 153B(1)(b) is passed by AO below the rank of JCIT, he has to seek approval from the JCIT. The issue arises whether assessment