ASSTT. COMMR. OF INCOME TAX, CEN. CIR-1,, RAJKOT vs. RAJESHKUMAR GOVINDBHAI PATEL,, RAJKOT

In the result both the appeals filed by the Revenue and the Cross Objections filed by the assessee are hereby dismissed

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

carried out at several places. When the disclosure is made as a precautionary measure, the same is obviously conditional and the addition thereof can be made only if some corroborating material is found in the search. Hence, such an addition is uncalled for. 5.29 It has also been emphasized that on revocation of PO, the ADIT had confronted the assessee

ASSTT. COMMR. OF INCOME TAX, CEN. CIR-1,, RAJKOT vs. RAJESHKUMAR GOVINDBHAI PATEL,, RAJKOT

In the result both the appeals filed by the Revenue and the Cross Objections filed by the assessee are hereby dismissed

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

carried out at several places. When the disclosure is made as a precautionary measure, the same is obviously conditional and the addition thereof can be made only if some corroborating material is found in the search. Hence, such an addition is uncalled for. 5.29 It has also been emphasized that on revocation of PO, the ADIT had confronted the assessee

GOPAL SNACKS PVT LTD ,RAJKOT vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAJKOT

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita Nos. 498 & 499/Rjt/2025 "नधा"रणवष"/ Assessment Years: 2015-16 & 2020-21 बनाम Gopal Snacks Pvt. Ltd. Asst. Commissioner Of Plot No.2322-2324, Gidc Metoda, Income Tax Vs. Lodhika, Rajkot, Gujarat-360021 Circle-1(1), Rajkot Pan : Aadcg6113A (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Prakash Jhunjhunwala & Shri K. K. Maloo, Ars. राज"व क" ओर से/Revenue By : Shri Shramdeep Sinha, Cit.Dr & Shri Abhimanyu Singh, Sr. Dr सुनवाई क" तार"ख /Date Of Hearing : 19/11/2025 घोषणा क" तार"ख /Date Of Pronouncement : 08/12/2025

carried the matter in appeal before the Ld. CIT(A), who has confirmed, the action of the assessing officer, observing as follows: “6.1 I have gone through the facts of the entire case. In brief it can be stated that the return of income filed by the appellant was processed u/s 143(1) after making some adjustment to the returned

M/S. SIMERO VITRIFIED P. LTD. ,MORBI vs. THE PR. CIT-3 , RAJKOT

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

forward to subsequent years.\n2\nITA 276/Rjt/2019 (AY 2016-17) SIMERO VITRIFIED P. LTD.\n5. Later on, Learned Principal Commissioner of Income-tax (in short \"Ld PCIT\") exercised his jurisdiction under section 263 of the Income-tax Act, 1961. On verification of the assessment records, it was noticed by the learned PCIT that 68,54,519 equity shares have been

PRANAM ENTERPRISE,JUNAGADH vs. DCIT, CIRCLE-1(1), RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.391/Rjt/2024 Assessment Year: (2017-18) (Hybrid Hearing) Pranam Enterprise Vs. The Dcit Office No.3, City Centre, Opp. Circle-1(1), Rajkot New Collector Office, Junagadh – 362001, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaffp7926H (Assessee) (Respondent) Assessee By Shri Mehul Ranpura, Ar Respondent By Shri Abhimanyu Singh Yadav, Sr.Dr Date Of Hearing 18/12/2024 Date Of Pronouncement 06/03/2025 आदेश / O R D E R Per Dr. A. L. Saini, Am:

carried the matter, in appeal, before the Ld. CIT(A), who has confirmed the action of the assessing officer. The ld CIT(A) noticed that the facts of the assessee, make it clear that regular electricity and maintenance charges were sought to be passed off, as part of income from developing and building housing projects in order to avail excess

AJAYKUMAR NATWARLAL SHETH,RAJKOT vs. THE DCIT, CIRCLE 1(2) RAJKOT, RAJKOT

In the result, the assessee's appeal is allowed in the terms indicated above

carried\nout does not mean that such modification is for evading taxes more particularly when\nDepartment also are accepting that CCM has never been illegal.\nThus on providing each and every transaction where the allegation have been made that\nthe CCM have been utilized as a tool of tax evasion may be supplied so as to enable me\nto give

SEABIRD MARINE SERVICES PRIVATE LIMITED,JAMNAGAR vs. ACIT, CIRCLE - 1, JAMNAGAR, JAMANGAR

In the result, ground No.4 raised by the assessee is allowed

carried forward to the subsequent year or years\nunder the provisions of sub-section (2) of section 32 or sub-section (3) of section 32A or clause\n(ii) of sub-section (1) of section 72 or section 73 or section 74 or sub-section (3) of section 74A\nor sub-section (3) of section 80J.\"\n4. For deciding this

DCIT, CENTRAL CIRCLE 2, RAJKOT, RAJKOT vs. SHRI MUKESH MANEKCHAND SHETH, RAJKOT

carried\nout by the office of DDIT (Investigation), Rajkot, in the case of leading real\nestate builders of Rajkot and their associates on 24.08. 2021. Therefore, the\nactual date of search was 24.08.2021, whereas the date is mentioned in the notice\nunder section 148 of the Act, is as on 22.10.2021, which is wrong, therefore, the\nnotice issued u/s.148

MUKESH MANEKCHAND SHETH,RAJKOT vs. THE DCIT-ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

carried\nout by the office of DDIT (Investigation), Rajkot, in the case of leading real\nestate builders of Rajkot and their associates on 24.08. 2021. Therefore, the\nactual date of search was 24.08.2021, whereas the date is mentioned in the notice\nunder section 148 of the Act, is as on 22.10.2021, which is wrong, therefore, the\nnotice issued u/s.148

R K INFRALINK LLP,RAJKOT vs. ACIT, CC-1, RAJKOT, RAJOKT

In the result, ground No. 3 in Revenue`s appeal in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

loss of Rs.48,098/-. Subsequently, notice under section 143(2) of the Income tax Act has been issued and served on 18.12.2022, on the e-filing portal of the assessee. Subsequent notice under section 142(1) of the Act, have been issued from time to time, seeking primary as well as further details from the assessee for carrying

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. RK INFRALINK LLP, RAJKOT

In the result, ground No. 3 in Revenue`s appeal in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

loss of Rs.48,098/-. Subsequently, notice under section 143(2) of the Income tax Act has been issued and served on 18.12.2022, on the e-filing portal of the assessee. Subsequent notice under section 142(1) of the Act, have been issued from time to time, seeking primary as well as further details from the assessee for carrying

R K INFRALINK LLP,RAJKOT vs. ACIT, CC-1, RAJKOT , RAJKOT

In the result, ground No. 3 in Revenue`s appeal in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

loss of Rs.48,098/-. Subsequently, notice under section 143(2) of the Income tax Act has been issued and served on 18.12.2022, on the e-filing portal of the assessee. Subsequent notice under section 142(1) of the Act, have been issued from time to time, seeking primary as well as further details from the assessee for carrying

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. RK INFRALINK LLP, RAJKOT

In the result, ground No. 3 in Revenue`s appeal in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

loss of Rs.48,098/-. Subsequently, notice under section 143(2) of the Income tax Act has been issued and served on 18.12.2022, on the e-filing portal of the assessee. Subsequent notice under section 142(1) of the Act, have been issued from time to time, seeking primary as well as further details from the assessee for carrying

R K INFRALINK LLP,RAJKOT vs. ACIT, CC-1, RAJKOT, RAJKOT

In the result, ground No. 3 in Revenue`s appeal in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

loss of Rs.48,098/-. Subsequently, notice under section 143(2) of the Income tax Act has been issued and served on 18.12.2022, on the e-filing portal of the assessee. Subsequent notice under section 142(1) of the Act, have been issued from time to time, seeking primary as well as further details from the assessee for carrying

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. RK INFRALINK LLP, RAJKOT

In the result, ground No. 3 in Revenue`s appeal in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

loss of Rs.48,098/-. Subsequently, notice under section 143(2) of the Income tax Act has been issued and served on 18.12.2022, on the e-filing portal of the assessee. Subsequent notice under section 142(1) of the Act, have been issued from time to time, seeking primary as well as further details from the assessee for carrying

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. RK INFRALINK LLP, RAJKOT

In the result, ground No. 3 in Revenue`s appeal in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

loss of Rs.48,098/-. Subsequently, notice under section 143(2) of the Income tax Act has been issued and served on 18.12.2022, on the e-filing portal of the assessee. Subsequent notice under section 142(1) of the Act, have been issued from time to time, seeking primary as well as further details from the assessee for carrying

R K INFRALINK LLP,RAJKOT vs. ACIT, CC-1, RAJKOT, RAJKOT

In the result, ground No. 3 in Revenue`s appeal in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

loss of Rs.48,098/-. Subsequently, notice under section 143(2) of the Income tax Act has been issued and served on 18.12.2022, on the e-filing portal of the assessee. Subsequent notice under section 142(1) of the Act, have been issued from time to time, seeking primary as well as further details from the assessee for carrying

ACCURATE BUILDCON,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

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

carried out in the case of the assessee after 01.04.2021, wherein, provisions of section 148 were amended and provides deemed satisfaction for three assessment years prior to the date of search, and even on this ground, the assessing officer has validly issued notice under section 148 of the Act. Hence, there is no defect in the reassessment proceedings, therefore