JIVANBHAI DE vs. HIBHAI SARLA,THANGADH, DIST. SURENDRANAGARVS.THE ITO WARD-2, SURENDRANAGAR, SURENDRANAGAR

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

condone the delay in both appeals and admit these appeals for hearing. 7. In both these appeals, the assessee has raised the grounds pertaining to technical issue, being notice issued under section 148 of the Act, is time barred. When these cases were called for hearing, Ld. Counsel for the assessee submitted that the issue under consideration, in both appeals

JIVANBHAI DE vs. HIBHAI SARLA,THANGADH, DIST. SURENDRANAGARVS.THE ITO WARD 2, SURENDRANAGAR, SURENDRANAGAR

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

condone the delay in both appeals and admit these appeals for hearing. 7. In both these appeals, the assessee has raised the grounds pertaining to technical issue, being notice issued under section 148 of the Act, is time barred. When these cases were called for hearing, Ld. Counsel for the assessee submitted that the issue under consideration, in both appeals

NILESH ASHANAND THACKER,BHUJ vs. ITO WARD 4, GANDHIDHAM (BHUJ)

In the result, appeal filed by the assessee, is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.377/Rjt/2025 (िनधा"रण वष" /Assessment Year: (2012-13) (Physical Hearing) Nilesh Ashanand Thacker, बनाम Income-Tax Officer, Ward-4, / Near-Laxmi Vekari Mahakali Gandhidham (Bhuj-2)-370 201 Vs. Shopping Mall, Jublee Circle, Bhuj, Kutch-300 001(Gujarat) "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Adhpt 8610R (अपीलाथ"/ Appellant) (""थ"/Respondent)

condone the delay and admit the appeal of the assessee for hearing on merit. 8. Succinctly, the factual panorama of the case is that assessee before us is an Individual and had filed his return of income for assessment year (A.Y.) 2012-13, on 25.03.2013, declaring total income of Rs. 1,78,070/-. During the year, the assessee has earned

MITHAPUR NUTAN BAL SHIKSHAN SANGH,MITHAPUR vs. INCOME TAX OFFICER - WARD (1), DWARKA, DWARKA

In the result, the above penalty appeals filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./Ita Nos. 783 To 786/Rjt/2025 (Assessment Year: 2018-19 & 2019-20) (Hybrid Hearing) Mithapur Nutan Bal Shikshan Vs. The Ito, Ward-1, Sangh. Dwarka Sangh Bal Mandir Zanda Chowk, Mithapur-361345 (Guj) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaam0815C (अपीलाथ"/Assessee) (""यथ"/Respondent)

condoned the delay in filing the appeal before CIT(A) and I noted that ld. CIT(A) himself remitted the assessee’s appeal for A.Y. 2019- 20 in quantum proceedings, vide order dated 13-11-2025 of the Ld. CIT(A) wherein the ld. CIT(A) in the quantum proceedings held as follows: “5.4 In accordance with the proviso

MITHAPUR NUTAN BAL SHIKSHAN SANGH,MITHAPUR vs. INCOME TAX OFFICER - WARD (1), DWARKA, DWARKA

In the result, the above penalty appeals filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./Ita Nos. 783 To 786/Rjt/2025 (Assessment Year: 2018-19 & 2019-20) (Hybrid Hearing) Mithapur Nutan Bal Shikshan Vs. The Ito, Ward-1, Sangh. Dwarka Sangh Bal Mandir Zanda Chowk, Mithapur-361345 (Guj) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaam0815C (अपीलाथ"/Assessee) (""यथ"/Respondent)

condoned the delay in filing the appeal before CIT(A) and I noted that ld. CIT(A) himself remitted the assessee’s appeal for A.Y. 2019- 20 in quantum proceedings, vide order dated 13-11-2025 of the Ld. CIT(A) wherein the ld. CIT(A) in the quantum proceedings held as follows: “5.4 In accordance with the proviso

MITHAPUR NUTAN BAL SHIKSHAN SANGH,MITHAPUR vs. INCOME TAX OFFICER - WARD (1), DWARKA, DWARKA

In the result, the above penalty appeals filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./Ita Nos. 783 To 786/Rjt/2025 (Assessment Year: 2018-19 & 2019-20) (Hybrid Hearing) Mithapur Nutan Bal Shikshan Vs. The Ito, Ward-1, Sangh. Dwarka Sangh Bal Mandir Zanda Chowk, Mithapur-361345 (Guj) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaam0815C (अपीलाथ"/Assessee) (""यथ"/Respondent)

condoned the delay in filing the appeal before CIT(A) and I noted that ld. CIT(A) himself remitted the assessee’s appeal for A.Y. 2019- 20 in quantum proceedings, vide order dated 13-11-2025 of the Ld. CIT(A) wherein the ld. CIT(A) in the quantum proceedings held as follows: “5.4 In accordance with the proviso

MITHAPUR NUTAN BAL SHIKSHAN SANGH,MITHAPUR vs. INCOME TAX OFFICER - WARD (1), DWARKA, DWARKA

In the result, the above penalty appeals filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./Ita Nos. 783 To 786/Rjt/2025 (Assessment Year: 2018-19 & 2019-20) (Hybrid Hearing) Mithapur Nutan Bal Shikshan Vs. The Ito, Ward-1, Sangh. Dwarka Sangh Bal Mandir Zanda Chowk, Mithapur-361345 (Guj) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaam0815C (अपीलाथ"/Assessee) (""यथ"/Respondent)

condoned the delay in filing the appeal before CIT(A) and I noted that ld. CIT(A) himself remitted the assessee’s appeal for A.Y. 2019- 20 in quantum proceedings, vide order dated 13-11-2025 of the Ld. CIT(A) wherein the ld. CIT(A) in the quantum proceedings held as follows: “5.4 In accordance with the proviso

BABUBHAI KANJIBHAI SAKARIYA LEGAL HEIR OF LATE SMT. UJIBEN KANJIBHAI SAKARIYA,JETPUR vs. ITO WARD 1(2)(1), RAJKOT, RAJKOT

In the result, the appeal filed by the assessee is allowed

condone the delay. Learned Counsel for the assessee, has explained the\ndelay in filing the appeal before this Tribunal stating that Late Smt. Ujiben\nKanjibhai Sakariya left for heavenly abode on 26.11.2020, intestate. The\nassessee, including his two brothers reside in three different cities. The\nassessee, including his brother, have decided to get registered their name as\nlegal heir

RAJENDRASINH RANJITSINH JADEJA,KHAKHADABELA,PADDHARI vs. ITO WD 2(1)(4), RKT, RAJKOT

In the result, appeal filed by the assessee, is allowed, to the extent indicated above

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No.459/Rjt/2025 "नधा"रणवष" / Assessment Year: (2012-13) (Hybrid Hearing) Rajendrasinh Ranjitsinh Jadeja Vs. Ito Ward 2 (1) (4), Khakhadabela, Paddhari, Aayakar Bhawan, Race Course Rajkot - 360110 Ring Road, Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Agvpj2529E (Appellant) (Respondent) Appellant By : Shri Gaurang Khakhar, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 01/09/2025 Date Of Pronouncement : 17/11/2025 आदेश / O R D E R Per, Dr. Arjun Lal Saini, Am ; Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2012-13, Is Directed Against The Order Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) By National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income-Tax (Appeals), Dated 26/07/2024, Which In Turn Arises Out Of An Order Passed By The Assessing Officer Dated 25/11/2009 U/S 144 R.W.S 147 Of The Income Tax Act, 1961. 2. Grounds Of Appeal Raised By The Assessee Are As Follows: “1. That The Reasons Recorded U/S 147 Of The I.T. Act, 1961 By The Ld. A.O. Were Merely Based On The Suspicion & Without Any Tangible Material So As To Suggest Any Escapement Of Income. Hence The Reassessment Proceedings Are Liable To Be Quashed Rajendrasinh Ranjitsinh Jadeja

condone the delay. 6. Brief facts qua the issue, on merit, are that assessee has filed return of income on 03.07.2013, declaring total income of Rs. 1,56,860/- for the year under consideration. As per the information available with the department and on enquiry, it was noticed by the assessing officer that the assessee has made cash deposit amounting

M/S. GREEN EARTH BIOGAS PVT. LTD.,SURENDRANAGAR vs. THE PR. CIT-3, AHMEDABAD, AHMEDABAD

In the result, appeal filed by the assessee is dismissed

condone the delay.\n7. Succinctly, the factual panorama of the case is that assessee before us is a\nprivate limited company.The assessee- company had filed return of income for\nthe assessment year (AY) 2017-18, on 13/10/2017, declaring total loss of\nRs.2,36,06,293/-. The assessee`s case was selected for Scrutiny through CASS.\nThe assessment was finalized

SHITALBEN JYOTIKUMAR RAYCHURA,PORBANDAR vs. ITO, PORBANDAR

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

reassessment\nprocedure on the basis of mere information of cash deposit.\n3. At the outset, we notice that the appeal filed by the assessee is late by 360\ndays. The assessee filed condonation of delay

SAPNA NAINESH JATANIA,RAJKOT vs. INCOME TAX OFFICER, WARD 1(4), DWARKA, DWARKA

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

Bench: Dr. Arjun Lal Saini

condone the delay in both appeals. 3. Since, the issues involved in all the appeals are common and identical; therefore, these appeals have been heard together and are being disposed of by this consolidated order. For the sake of convenience, the grounds as well as the facts narrated in ITA No.449/RJT/2025, for assessment Year 2012-13, have been taken into

SAPNA NAINESH JATANIA,RAJKOT vs. INCOME TAX OFFICER, WARD 1(1), JAMNAGAR, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini

condone the delay in both appeals. 3. Since, the issues involved in all the appeals are common and identical; therefore, these appeals have been heard together and are being disposed of by this consolidated order. For the sake of convenience, the grounds as well as the facts narrated in ITA No.449/RJT/2025, for assessment Year 2012-13, have been taken into

SMT. RANI HARERAM SAHANI,KOVAYA, RAJULA, DIST. AMRELI vs. THE ACIT, WARD-2 (4), BHAVNAGAR, BHAVNAGAR

In the result, the appeal filed by the Assessee is allowed

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

condone the delay of 13 days in filing the appeal before Ld. CIT(A) on the Principles of Natural Justice. 4.1. On merits, the assessment was reopened on the basis of information received from DDIT, Investigation Unit-2, Rajkot that the assessee has paid an amount of Rs. 9,99,000/- to Shri Jinabhai Vagh on 10.03.2011 for Life Insurance

SMT. RANI HARERAM SAHANI,KOVAYA, RAJULA, DIST. AMRELI vs. THE ITO, WARD-3 (1) (4), RAJULA, DIST. AMRELI, RAJULA, DIST. AMRELI

In the result, the appeal filed by the Assessee is allowed

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

condone the delay of 13 days in filing the appeal before Ld. CIT(A) on the Principles of Natural Justice. 4.1. On merits, the assessment was reopened on the basis of information received from DDIT, Investigation Unit-2, Rajkot that the assessee has paid an amount of Rs. 9,99,000/- to Shri Jinabhai Vagh on 10.03.2011 for Life Insurance

SHREE MARU KANSARA SONI GNATI,ANJAR vs. ITO EXEMPTION WARD-1 RAJKOT, RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./Ita No. 789/Rjt/2025 धििाारण वर्ा/Assessment Year: (2017-18) Shree Maru Kansara Soni Gnati बनाम Income Tax Officer (Exemption), /Vs. C/O Rajesh K Soni, Shashtri Road, Ward- 1, Rajkot, Anjar, Kutch-360 001(Gujarat) It Office, New Aayakar Bhavan,Vatiaka, Rajkot-360 001 स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aarts 1920 N (Appellant) (Respondent)

delay is condoned. ITA No. 789/RJT/2025 A.Y 17-18 Shree Maru Kansara Soni Gnati 4. On merit, Learned Counsel for the assessee explained the facts of the assessee’s case that assessee trust has filed its original return of income on 13.09.2017, declaring nil income, which was processed under section 143(1) of the Act. Subsequently, the proceedings under section

M/S. KANDLA ENERGY AND CHEMICALS LTD.,VILLAGE DEVALIYA, TAL. ANJAR(KUTCH) vs. ADD. CIT, GANDHIDHAM RANGE,, GANDHIDHAM(KUTCH)

In the result, the appeal filed by the Assessee is hereby dismissed

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

condone the delay in filing objections before it u/s. 144C(2) of the Act. Further as rightly held by the Ld. DRP as against the final assessment order dated 19.12.2017 passed by the Assessing Officer u/s. 144C(3) of the Act, the assessee is open to file its appeal before Ld. CIT(A). Therefore the order passed

SHRI BHARATBHAI RAYSINH VALA,DEVALI DEDA, KODINAR, DIST. JUNAGADH vs. THE ITO, WARD-3(1)(4), AMRELI, AMRELI

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

condonation of delay support by the affidavit,\nrelevant para contain reasons for the delay, the same is reproduced.\n“3. That I was entirely unaware of the statutory requirements related to\nmaintaining books of accounts, filing income tax returns and tax audit\ncompliance. Due to my lack of formal education and knowledge of tax laws, I did\nnot file