SHRI MANOJ B. MANSUKHANI,,RAJKOT-GUJARAT vs. THE PR. COMMISSIONER OF INCOME TAX-1, , RAJKOT

In the result, the appeal of the assessee is allowed

reassessment stage, there is no question of having taken one view of the matter or taking two different views by the AO or by the CIT. The Hon'ble ITAT, Cochin in the case of Shri Narayana Dharam Paripaiana Yuvadhana Samiti vs. ITO, Exemption (2019) 111 taxmnan.com 416 has held that where the AO has taken a wrong decision without

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

SHRI KHODIDAS PREMJIBHAI BHAGIYA,,RAJKOT-GUJARAT vs. THE PR. CIT-3,, RAJKOT-GUJARAT

In the result, all the appeals of the assessee are allowed

Bench: Shri Waseem Ahmed & Smt Madhumita Roy

reassessment order needs to be set aside and should be examined in pursuance to the direction of ld CIT passed u/s 263 of the Act. 7. The ld. AR in his rejoinder submitted that the explanation to section 263 of the Act is not applicable. The ld. CIT(A) u/s 263 of the Act has not pointed out any defect

AMRAPAR SEVA SAHKARI MANDLI LTD,AMRAPAR vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is dismissed

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 324/Rjt/2025 Assessment Year: (2018-19) Amrapar Seva Sahkari Mandali Ltd. Vs. The Principal Commissioner Of C/O., Sarda & Sarda, Sakar, 1St Floor, Income Tax – 1, Dr. Radha Krishna Road, Opp. Aayakar Bhavan, Race Course Rajkumar Collage, Rajkot - 360001 Ring Road, Rajkot – 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaaa0819N (Appellant) (Respondent) Appellant By : Shri Vimal Desai, Ld. Ar : Shri Sanjay Punglia, Ld. Cit(Dr) Respondent By Date Of Hearing : 18/03/2026 : 17/04/2026 Date Of Pronouncement

reassessment order on an issue unrelated to the reason recorded for reopening the assessment when no income was assessed in respect of the issue of reopening. ” 3. Brief facts of the case that the assessee has not filed his return of income for AY 2018-19, as per the information received by the AO that the assessee has c cash

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

SHRI PARESHKUMAR NARSHIBHAI SIROYA,DHORAJI, DIST. RAJKOT vs. THE PR. CIT-1, RAJKOT, RAJKOT

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

reassessment stage, there is no question\nof having taken one view of the matter or taking two different views by the assessing officer\nor by the CIT.\n(iii)The Hon'ble ITAT, Cochin in the case of Shri Narayana Dharam Paripalana\nYuvadhana Samiti vs. ITO, Exemption (2019) 111 taxmnan.com 416 has held that where\nthe assessing officer has taken

SHRI ASHISH KANJIBHAI RATHOD,RAJKOT vs. THE DCIT, CIR-2(2)(2),, RAJKOT

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

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

reassessment order passed under section 143(3) r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year (A.Y) 2012- 13. I.T.A No. 152/Rjt/2021 A.Y. 2012-13 Page No 2 Shri Ashish Kanjibhai Rathod vs. DCIT 2. The brief facts of the case is that the assessee is an individual and Proprietor

M/S RADHE RENEWABLE ENERGY DEVELOPMENT PVT. LTD.,,RAJKOT-GUJARAT vs. THE ASSTT. COMMR. INCOME TAX, CIRCLE-5,, RAJKOT-GUJARAT

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

reassessment every year. As one reaches close to the end of the warranty period, the probability that the warranty expenses will be incurred is considerably reduced and that should be reflected in the estimation amount. Whether this should be done through a pro rata reversal or otherwise would require assessment of historical trend. If warranty provisions are based on experience

THE DEPUTY COMMR. INCOME TAX, CIRCLE-1(2),, RAJKOT vs. M/S RADHE RENEWABLE ENERGY DEVELOPMENT PVT. LTD.,, RAJKOT

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

reassessment every year. As one reaches close to the end of the warranty period, the probability that the warranty expenses will be incurred is considerably reduced and that should be reflected in the estimation amount. Whether this should be done through a pro rata reversal or otherwise would require assessment of historical trend. If warranty provisions are based on experience

THE DY. COMMR. OF INCOME TAX, CIRCLE-1(1),, RAJKOT-GUJARAT vs. M/S. RADHE RENEWABLE ENERGY DEVELOPEMENT PVT. LTD.,, RAJKOT-GUJARAT

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

reassessment every year. As one reaches close to the end of the warranty period, the probability that the warranty expenses will be incurred is considerably reduced and that should be reflected in the estimation amount. Whether this should be done through a pro rata reversal or otherwise would require assessment of historical trend. If warranty provisions are based on experience

RADHE RENEWABLE ENERGY DEVELOPMENT PVT LTD,RAJKOT vs. THE PCIT, RAJKOT-1, RAJKOT, RAJKOT

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

reassessment every year. As one reaches close to the end of the warranty period, the probability that the warranty expenses will be incurred is considerably reduced and that should be reflected in the estimation amount. Whether this should be done through a pro rata reversal or otherwise would require assessment of historical trend. If warranty provisions are based on experience

MS ADITYA PLASTIC,RAJKOT vs. THE INCOME TAX OFFICER, NFAC, DELHI, DELHI

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./I.T.A. No.185 & 186/Rjt/2024 (िनधा"रणवष" / Assessment Year :2013-14) बनाम/ M/S Aditya Plastic The Income Tax Officer Umiya Industrial Building Ward-3(1)(1) Vs. Near New Nehru Nagar Rajkot -360 001 Main Road, Dhebar Road Rajkot – 360 004 "ायीलेखासं./जीआइआरसं./Pan/Gir No. : Aajfa 4558 In (अपीलाथ"/Appellant) .. (""थ" / Respondent) Assessee By : Shri D.M. Rindani, Ld.Ar Revenue By : Shri Abhimanyu Singh Yadav, Ld.Sr.Dr सुनवाईकीतारीख/ Date Of Hearing 05/06/2025 घोषणाकीतारीख/Date Of Pronouncement 03/09/2025 आदेश / O R D E R Per Bench-: Captioned Two Appeals Filed By The Same Assessee Pertaining To Assessment Year (Ay) 2013-14 Are Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Cit(A)-[(In Short “Ld.Cit(A)”] Vide Order Dated 01/02/2024, Which In Turn Arises Out Of An Assessment Order Dated 29/09/2021Passed By The Assessing Officer (Ao) U/S. 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short, “The Act”) Pertaining To Assessment Year (Ay) 2013-14. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows:

119 of the Act). Vide F.No.225/97/2021/ITA-II dated 06.09.2021 (Procedure for handling of assessment by JAO) it has been directed that the assessee's may be requested to get themselves registered with the e-filing portal of the department. In light of the same, the assessee was requested to get registered with the e-filing portal of the department and/or

MS ADITYA PLASTIC,RAJKOT vs. THE INCOME TAX OFFICER, WARD 3(1)(1), RAJKOT-, RAJKOT

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./I.T.A. No.185 & 186/Rjt/2024 (िनधा"रणवष" / Assessment Year :2013-14) बनाम/ M/S Aditya Plastic The Income Tax Officer Umiya Industrial Building Ward-3(1)(1) Vs. Near New Nehru Nagar Rajkot -360 001 Main Road, Dhebar Road Rajkot – 360 004 "ायीलेखासं./जीआइआरसं./Pan/Gir No. : Aajfa 4558 In (अपीलाथ"/Appellant) .. (""थ" / Respondent) Assessee By : Shri D.M. Rindani, Ld.Ar Revenue By : Shri Abhimanyu Singh Yadav, Ld.Sr.Dr सुनवाईकीतारीख/ Date Of Hearing 05/06/2025 घोषणाकीतारीख/Date Of Pronouncement 03/09/2025 आदेश / O R D E R Per Bench-: Captioned Two Appeals Filed By The Same Assessee Pertaining To Assessment Year (Ay) 2013-14 Are Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Cit(A)-[(In Short “Ld.Cit(A)”] Vide Order Dated 01/02/2024, Which In Turn Arises Out Of An Assessment Order Dated 29/09/2021Passed By The Assessing Officer (Ao) U/S. 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short, “The Act”) Pertaining To Assessment Year (Ay) 2013-14. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows:

119 of the Act). Vide F.No.225/97/2021/ITA-II dated 06.09.2021 (Procedure for handling of assessment by JAO) it has been directed that the assessee's may be requested to get themselves registered with the e-filing portal of the department. In light of the same, the assessee was requested to get registered with the e-filing portal of the department and/or

THE ASST. COMMR. INCOME TAX, CENTRAL CIRCLE-2, RAJKOT, RAJKOT vs. M/S SHIV SHIPPING SERVICES,, GANDHIDHAM-KUTCH

In the result, the appeal of the revenue is dismissed

Bench: Shri Waseem Ahmed & Shri T.R Senthil Kumarआयकर अपील सं./Ita No. 19/Rjt/2021 िनधा"रण वष"/Asstt. Year: 2010-11 A.C.I.T, M/S Shiv Shipping Services Central Circle-2, Vs. 101,102, Rajkamal Arcade, Rajkot. Plot No.353, Ward-12/B, 1St Floor, Opp. B.M Petrol Pump, Gandhidham.

2,45,30,899/- only. Accordingly, the AO treated the same as income and added to the total income of the assessee. 5. Aggrieved assessee preferred an appeal to the learned CIT(A) who deleted the addition made by the AO by observing as under: 7.5 The above finding is very clear that the impugned addition (was also made