SHRI GANDHI MAULANA AZAD SHRAMJIVI ASHRA,KUTCH vs. INCOME TAX OFFICER, EXEMPTION WARD 1, RAJKOT, RAJKOT

In the result, appeals of the assessee, are allowed

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

reassessment under Section 148 within the prescribed time limits. Further, Section 151 requires assessing officers to obtain sanction of the specified authority before issuing notice under Section 148. In Chhugamal Rajpal v. S P Chaliha, a three-Judge Bench of this Court held that Section 151 must be strictly adhered to because it contains "important safeguards." 65 Section 151 imposes

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAJKOT vs. CLASSIC NETWORK PVT. LTD., RJAKOT

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

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

section 143(3) of the Act, should be treated invalid, and therefore, the reassessment order framed by the assessing officer, may be be quashed and for that, learned Counsel for the assessee relied on the judgement of Hon’ble High Court of Allahabad in the case of Vikas Gupta (2022) 142 taxmann.com 253 (Allahabad HC). The learned Counsel also relied

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

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

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

section 143(3) of the Act, should be treated invalid, and therefore, the reassessment order framed by the assessing officer, may be be quashed and for that, learned Counsel for the assessee relied on the judgement of Hon’ble High Court of Allahabad in the case of Vikas Gupta (2022) 142 taxmann.com 253 (Allahabad HC). The learned Counsel also relied

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

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

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

section 143(3) of the Act, should be treated invalid, and therefore, the reassessment order framed by the assessing officer, may be be quashed and for that, learned Counsel for the assessee relied on the judgement of Hon’ble High Court of Allahabad in the case of Vikas Gupta (2022) 142 taxmann.com 253 (Allahabad HC). The learned Counsel also relied

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAJKOT, RAJKOT vs. CLASSIC NETWORK PVT. LTD., RAJKOT

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

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

section 143(3) of the Act, should be treated invalid, and therefore, the reassessment order framed by the assessing officer, may be be quashed and for that, learned Counsel for the assessee relied on the judgement of Hon’ble High Court of Allahabad in the case of Vikas Gupta (2022) 142 taxmann.com 253 (Allahabad HC). The learned Counsel also relied

CLASSIC NETWORK PRIVATE LIMITED,RAJKOT vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL - 1, RAJKOT, RAJKOT

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

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

section 143(3) of the Act, should be treated invalid, and therefore, the reassessment order framed by the assessing officer, may be be quashed and for that, learned Counsel for the assessee relied on the judgement of Hon’ble High Court of Allahabad in the case of Vikas Gupta (2022) 142 taxmann.com 253 (Allahabad HC). The learned Counsel also relied

CLASSIC NETWORK PRIVATE LIMITED,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1 RAJKOT, RAJKOT

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

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

section 143(3) of the Act, should be treated invalid, and therefore, the reassessment order framed by the assessing officer, may be be quashed and for that, learned Counsel for the assessee relied on the judgement of Hon’ble High Court of Allahabad in the case of Vikas Gupta (2022) 142 taxmann.com 253 (Allahabad HC). The learned Counsel also relied

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

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

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

section 143(3) of the Act, should be treated invalid, and therefore, the reassessment order framed by the assessing officer, may be be quashed and for that, learned Counsel for the assessee relied on the judgement of Hon’ble High Court of Allahabad in the case of Vikas Gupta (2022) 142 taxmann.com 253 (Allahabad HC). The learned Counsel also relied

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

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

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

section 143(3) of the Act, should be treated invalid, and therefore, the reassessment order framed by the assessing officer, may be be quashed and for that, learned Counsel for the assessee relied on the judgement of Hon’ble High Court of Allahabad in the case of Vikas Gupta (2022) 142 taxmann.com 253 (Allahabad HC). The learned Counsel also relied

CLASSIC NETWORK PRIVATE LIMITED,RAJKOT vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1, RAJKOT, RAJKOT

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

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

section 143(3) of the Act, should be treated invalid, and therefore, the reassessment order framed by the assessing officer, may be be quashed and for that, learned Counsel for the assessee relied on the judgement of Hon’ble High Court of Allahabad in the case of Vikas Gupta (2022) 142 taxmann.com 253 (Allahabad HC). The learned Counsel also relied

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

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

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

section 143(3) of the Act, should be treated invalid, and therefore, the reassessment order framed by the assessing officer, may be be quashed and for that, learned Counsel for the assessee relied on the judgement of Hon’ble High Court of Allahabad in the case of Vikas Gupta (2022) 142 taxmann.com 253 (Allahabad HC). The learned Counsel also relied

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

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

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

section 143(3) of the Act, should be treated invalid, and therefore, the reassessment order framed by the assessing officer, may be be quashed and for that, learned Counsel for the assessee relied on the judgement of Hon’ble High Court of Allahabad in the case of Vikas Gupta (2022) 142 taxmann.com 253 (Allahabad HC). The learned Counsel also relied

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

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

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

section 143(3) of the Act, should be treated invalid, and therefore, the reassessment order framed by the assessing officer, may be be quashed and for that, learned Counsel for the assessee relied on the judgement of Hon’ble High Court of Allahabad in the case of Vikas Gupta (2022) 142 taxmann.com 253 (Allahabad HC). The learned Counsel also relied

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

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

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

section 143(3) of the Act, should be treated invalid, and therefore, the reassessment order framed by the assessing officer, may be be quashed and for that, learned Counsel for the assessee relied on the judgement of Hon’ble High Court of Allahabad in the case of Vikas Gupta (2022) 142 taxmann.com 253 (Allahabad HC). The learned Counsel also relied

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

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

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

section 143(3) of the Act, should be treated invalid, and therefore, the reassessment order framed by the assessing officer, may be be quashed and for that, learned Counsel for the assessee relied on the judgement of Hon’ble High Court of Allahabad in the case of Vikas Gupta (2022) 142 taxmann.com 253 (Allahabad HC). The learned Counsel also relied

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:

10. The issue for consideration before us is that whether penalty under Section 270A of the Act can be levied in the instant set of facts, when as per the assessee, she was under the genuine belief that since taxes has been deducted at source on such sale of property then there was no occasion to file return of income

SHRI GIRISHBHAI NANJIBHAI SOLANKI,RAJKOT vs. THE ITO, WARD-1 (1) (2), RAJKOT

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकरअपीलसं./Ita Nos. 31 & 32/Rjt/2020 िनधा"रणवष"/Asstt. Years:2011-12, 2012-13 िनधा"रणवष" िनधा"रणवष" िनधा"रणवष"

10. It is settled position of law that the once notice for reopening assessment under section 148 of the Act was issued, the assessee is required to furnish return of income in response to such notice. It is further provided that the return filed under section 148 of the Act is deemed to have filed under section

SHRI GIRISHBHAI NANJIBHAI SOLANKI,RAJKOT vs. THE ITO, WARD-1 (1) (2), RAJKOT

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकरअपीलसं./Ita Nos. 31 & 32/Rjt/2020 िनधा"रणवष"/Asstt. Years:2011-12, 2012-13 िनधा"रणवष" िनधा"रणवष" िनधा"रणवष"

10. It is settled position of law that the once notice for reopening assessment under section 148 of the Act was issued, the assessee is required to furnish return of income in response to such notice. It is further provided that the return filed under section 148 of the Act is deemed to have filed under section

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)

reassessment proceedings carried out is bad in law and liable to be quashed. In the absence of signature by the concerned authority on the approval under section 151 of the Act, such approval document, cannot be enforced in the eye of law. 10