THE ACIT-CENTRAL CIRCLE-2, RAJKOT vs. SHRI VICKY BALKRISHNA MEHTA, RAJKOT

The appeal of the Revenue is dismissed

Bench: Mrs. Annapurna Gupta & Shri Siddhartha Nautiyal"नधा"रणवष"/Assessment Year: 2004-05 Assistant Commissioner Of Vs. Shri Vicky Balkrishna Mehta, Income-Tax, 7Th Floor, Mansrovar Central Circle-2, Apartment, Royal Park, Rajkot Kalawad Road, Rajkot Pan : Agqpm 6495 B अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri D.M. Rindani, Ar Revenue By : Shri Shramdeep Sinha, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 28.11.2022 घोषणा क" तार"ख /Date Of Pronouncement: 22.02.2023 आदेश/O R D E R Per Annapurna Gupta: This Appeal Is Preferred By The Revenue Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)-13, Ahmedabad (Hereinafter Referred To As “Cit(A)”) Dated 22.01.2020 Passed U/S 250(6) Of The Income-Tax Act, 1961, (Hereinafter Referred To As “The Act”) For Assessment Year (Ay) 2004-05. 2. The Grounds Of Appeal Raised By The Revenue Read As Under:

reassessment notice and all consequent 17 ACIT Vs. Shri Vicky Balkrishna Mehta AY : 2004-05 proceedings are hereby quashed and set aside. The writ petition is allowed; however without order on costs." 10. Thus, in all above cases Courts have held that when the time limit for issuing notice u/s.148 has expired before any amendment in law from a prospective

M/S. SHREEDHAR CONSTRUCTION ,JAMNAGAR vs. THE ITO WARD- 1 (3) JAMNAGAR, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 542/Rjt/2025 (Assessment Year: 2014-15) (Hybrid Hearing) M/S. Shreedhar Construction, The Ito, Vs. 211, Divyam Complex Airodrome Ward-1(3), Road,Jamnagar-361006 ( Gujarat) Jamnagar "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aclfs0395R (अपीलाथ"/Appellant) (""यथ"/Respondent)

reassessment notices under section 148 of the new regime. 112. Let us take the instance of a notice issued on 1 May 2021 under

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

reassessed or recomputed as loss than\nthe amount of tax will be calculated on the under reported\nincome as it was the total income.\nThis finding is w.r.t. disallowance of Rs.70,71,531/- of\npreliminary and pre operating expenses charge to revenue\nbefore date of assets put to use and dropping out penalty\nproceedings initiated under section

THE ITO, WARD-3(1)(1),, RAJKOT-GUJARAT vs. SHRI GIRISHKUMAR M. PURUSWANI,, RAJKOT-GUJARAT

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

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

112 (Gujarat) to consolidate his argument that desire to verify the cash deposits cannot be reason to reopen the assessment. 5.7 The provisions of Section 147 requires that the assessing officer should have reason to believe that income has escaped the assessment and then only, he can issue notice u/s. 148 of the Act. On careful consideration, I agree with

THE ITO, WARD-3(1)(1),, RAJKOT-GUJARAT vs. SHRI GIRISHKUMAR M. PURUSWANI,, RAJKOT-GUJARAT

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

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

112 (Gujarat) to consolidate his argument that desire to verify the cash deposits cannot be reason to reopen the assessment. 5.7 The provisions of Section 147 requires that the assessing officer should have reason to believe that income has escaped the assessment and then only, he can issue notice u/s. 148 of the Act. On careful consideration, I agree with

THE ITO, WARD-3(1)(1),, RAJKOT-GUJARAT vs. SHRI GIRISHKUMAR M. PURUSWANI,, RAJKOT-GUJARAT

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

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

112 (Gujarat) to consolidate his argument that desire to verify the cash deposits cannot be reason to reopen the assessment. 5.7 The provisions of Section 147 requires that the assessing officer should have reason to believe that income has escaped the assessment and then only, he can issue notice u/s. 148 of the Act. On careful consideration, I agree with

MANSUKHLAL KHIMJI KHIMASIYA HUF,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

reassessment order. Therefore, during the assessment proceedings, the assessee was asked for various details/documents in respect of the transaction. All details/documents, such as, Contract Note for Purchase of shares, Broker Ledger (with broker details) from whom shares were purchased and Contract Note for Sale of shares etc. were filed before the assessing officer. 8. However, ld.PCIT rejected the above contention

BHANUBEN MANSUKHLAL KHIMASIYA,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

reassessment order. Therefore, during the assessment proceedings, the assessee was asked for various details/documents in respect of the transaction. All details/documents, such as, Contract Note for Purchase of shares, Broker Ledger (with broker details) from whom shares were purchased and Contract Note for Sale of shares etc. were filed before the assessing officer. 8. However, ld.PCIT rejected the above contention

MANSUKHLAL KHIMJI KHIMASIYA,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

reassessment order. Therefore, during the assessment proceedings, the assessee was asked for various details/documents in respect of the transaction. All details/documents, such as, Contract Note for Purchase of shares, Broker Ledger (with broker details) from whom shares were purchased and Contract Note for Sale of shares etc. were filed before the assessing officer. 8. However, ld.PCIT rejected the above contention

JAYESH KHIMJI KHIMASIYA HUF,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

reassessment order. Therefore, during the assessment proceedings, the assessee was asked for various details/documents in respect of the transaction. All details/documents, such as, Contract Note for Purchase of shares, Broker Ledger (with broker details) from whom shares were purchased and Contract Note for Sale of shares etc. were filed before the assessing officer. 8. However, ld.PCIT rejected the above contention

HANSA JITENDRA HARIA,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, the appeal of the assessee is dismissed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.104/Rjt/2024 ("नधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Hansa Jitendra Haria Vs. Principal Commissioner Of 2, Oswal Colony, Near Rajendra Income Tax Balkrindagan, Jamnagar, Gujarat Jamnagar 361005. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahph4309L (Assessee) (Respondent)

Reassessment Order subjected to revision is not erroneous or nor it is prejudicial to interest of the Revenue and hence, impugned Order dt. 05/01/2024 needs to be quashed, ITA No. 104/RJT/2024/AY.2013-14 Hansa Jitendra Haria vs. PCIT 3. The learned PCIT has erred in law and in fact in disregarding the specific inquiry on the shares GLOBAL SECUR undertaken

KATARIA SNACK PELLETS PRIVATE LIMITED,RAJKOT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAJKOT

In the result, appeal of the assessee is dismissed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.468/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2015-16 Kataria Snack Pellets Pvt. Ltd. The Acit, Circle-1(1) बनाम 510, Gidc, Metoda Kalawad Road Rajkot Rajkot-360021, Gujarat Vs. Pan : Aafck2028L (अपीलाथ"/Appellant) (""यथ"/Respondent) :

reassessment proceedings, it was noticed by the assessing officer that the assessee has issued 8000 share, whose face value is Rs. 10 and at a premium of Rs.4990/-, thus the assessee during the period has received Kataria Snack Pellets Pvt. Ltd. ITA No.468 /RJT/2024 (AY : 2015-16) 3 Rs.80,000/-, as value of share and share premium