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

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/ reassessment made u/s 153C requires approval from

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

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/ reassessment made u/s 153C requires approval from

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

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/ reassessment made u/s 153C requires approval from

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

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/ reassessment made u/s 153C requires approval from

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

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/ reassessment made u/s 153C requires approval from

SHRI BHAKTINAGAR CO-OPERATIVE HOUSING SOCIETY LTD.,RAJKOT vs. THE ITO 3 (1) (1), RAJKOT

In the result the appeal filed by the assessee (ITA No

Bench: Dr. Arjun Lal Saini. & Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.200/Rjt/2024 िनधा"रणवष"/ Assessment Year: (2014-15) (Hybrid Hearing) Shri Bhakti Nagar Co Operative Housing Vs. Income Tax Officer, Ward 3(1)(1) Society Ltd. (Bhaktinagar Circle, Meghani Rang Bhavan, Aaykar Bhawan, Race Course Rajkot) Rong Road, A D Vyas & Co, Charted Accounts, Kotecha Rajkot - 360001 Nagar Main Road, Opp Kotecha Girl’S School, Off Kalawad Road. Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaas2363M (Appellant) (Respondent)

263 of the I.T. Act on 10.06.2019. Consequently, penalty proceedings u/s 271(1)(c) of the I.T. Act was initiated by issuing a notice to the assessee on 10.06.2019 and dully served upon the assessee. Further, due to change of incumbent an opportunity of being heard was given by the undersigned vide letter dated 14.11.2019 with request to submit

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)

u/s 271(1)(c) of the Act. Since we are remitting back entire quantum proceedings to the file of AO for fresh adjudication, therefore penalty proceedings is also remitted back to the file of AO for fresh initiation of penalty, if any, as per the quantum proceedings. 17. In case of ITA Nos.45-46/RJT/2023 AO issued notices on 03.12.2019 and assessment

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

u/s 271(1)(c) of the Act. Since we are remitting back entire quantum proceedings to the file of AO for fresh adjudication, therefore penalty proceedings is also remitted back to the file of AO for fresh initiation of penalty, if any, as per the quantum proceedings.\n17. In case of ITA Nos.45-46/RJT/2023 AO issued notices on 03.12.2019 and assessment

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

271(1)(c) of the Act. Since we are remitting back entire quantum\nproceedings to the file of AO for fresh adjudication, therefore penalty\nproceedings is also remitted back to the file of AO for fresh initiation of penalty,\nif any, as per the quantum proceedings.\n17. In case of ITA Nos.45-46/RJT/2023 AO issued notices on 03.12.2019 and\nassessment order

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 No. 1 and 2, above, raised

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

u/s 263 of the Act, and directed the\nassessing officer to verify the source of cash deposited in the bank accounts, which have\nbeen left out, during the course of original assessment proceedings. Accordingly,\nassessing officer made addition of peak credit in individual bank accounts. However, on\nfurther appeal by assessee, before

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

u/s 263 of the Act, and directed the\nassessing officer to verify the source of cash deposited in the bank accounts, which have\nbeen left out, during the course of original assessment proceedings. Accordingly,\nassessing officer made addition of peak credit in individual bank accounts. However, on\nfurther appeal by assessee, before

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

section 143(3) r.w.s. 263 of the Act and\nAssessing Officer made following addition:\n34\nH\nBHARATKUMAR ISHWARBHAI BHATIYA\nDHAMJIBHAI & KHIRAJMAL LEKHRAJBHAI THALVANI\ni.\nAddition an account of commission income of Rs. 8,61,446/-.\nii.\nAddition of peak credit in bank account of Rs. 46,50,353/-.\nOn appeal, before Ld. CIT(A), the assessee did not press ground

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

section 143(3) r.w.s. 263 of the Act and\nAssessing Officer made following addition:\n34\n1. BHARATKUMAR ISHWARBHAI BHATIYA\n2. DHAMJIBHAI & KHIRAJMAL LEKHRAJBHAI THALVANI\ni.\nAddition an account of commission income of Rs. 8,61,446/-.\nii.\nAddition of peak credit in bank account of Rs. 46,50,353/-.\nOn appeal, before Ld. CIT(A), the assessee did not press

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

section 143(3) read with section 263 of the Act and some of the\nassessment orders were passed by the Assessing Officer under section 153A r.w.s.\n143(3) of the Income Tax Act, 1961 (in short ‘the Act').The main ground of appeal by\nthe department (Revenue) is pertaining to assailing and deletion of 70% of additions\nmade on account

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

section 143(3) read with section 263 of the Act and some of the\nassessment orders were passed by the Assessing Officer under section 153A r.w.s.\n143(3) of the Income Tax Act, 1961 (in short ‘the Act').The main ground of appeal by\nthe department (Revenue) is pertaining to assailing and deletion of 70% of additions\nmade on account

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

section 143(3) read with section 263 of the Act and some of the\nassessment orders were passed by the Assessing Officer under section 153A r.w.s.\n143(3) of the Income Tax Act, 1961 (in short ‘the Act').The main ground of appeal by\nthe department (Revenue) is pertaining to assailing and deletion of 70% of additions\nmade on account

PAREEN RIAZ DOSANI,BHANVAD vs. THE ITO WARD-1, DWARKA, DWARKA

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

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

Penalty proceedings are initiated separately u/s 271(1)(c) of the Income- tax Act, 1961 for furnishing inaccurate particulars of income.” 8. Therefore, ld. Counsel for the assessee contended that the gross profit estimated by the assessing officer in the original assessment proceedings may be sustained in the hands of the assessee. 9. On the other hand