M/S. UNITED ENGINEERS, RAJKOT,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, RAJKOT, RAJKOT

In the result, the above appeals of the assessee are partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

3 of 2008, dated 12.3.2008 which read as under: "50. Assessment of search cases Orders of assessment and reassessment to be approved by the Joint Commissioner. 50.1 The existing provisions of making assessment and reassessment in cases where search has been conducted under section 132 or requisition is made under section 132A. does not provide for any approval for such

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

In the result the appeal filed by the assessee is allowed partly for the statistical purposes

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

Section 143(3)/147 of the Income Tax Act, 1961 (here-in-after referred to as "the Act") relevant to the Assessment Years 2010-11 to 2012-13. 2. First, we take up ITA No. 30/RJT/2020 for the AY 2010-11 2.1 The assessee has raised following grounds of appeal: Learned AO has erred in law as well

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

143(1) of the Act. Accordingly, Ground No. 1 raised by the Revenue is dismissed.” 12. Therefore, we direct the assessing officer to consider the total income chargeable to tax to the tune of Rs.58,44,15,970/-. Hence, this appeal filed by the assessee is allowed for statistical purposes. 13. In the result, appeal filed by the assessee

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

143(3) read\nwith Section 144B of the Act. Accordingly, we accept the contention of the Assessee\nthat in the facts and circumstances of the present case the doctrine of merger would\napply. Therefore, we reject the contention of the Revenue that the CIT(A) erred in\nentertaining and adjudicating the grounds raised by the Assessee in appeal before\nthe

M/S. IMPACT FORGING, RAJKOT,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

143(3) is bad in law and therefore no penalty proceeding can be initiated under section 271(1)(c) of the Act based on invalid assessment order. 13.1 The procedure under section 153D provides that where the assessment order u/s 153A(1)(b) or 153B(1)(b) is passed by AO below the rank of JCIT, he has to seek

M/S. IMPACT FORGING, ,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , RAJKOT

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

143(3) is bad in law and therefore no penalty proceeding can be initiated under section 271(1)(c) of the Act based on invalid assessment order. 13.1 The procedure under section 153D provides that where the assessment order u/s 153A(1)(b) or 153B(1)(b) is passed by AO below the rank of JCIT, he has to seek

M/S. IMPACT FORGING, ,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , RAJKOT

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

143(3) is bad in law and therefore no penalty proceeding can be initiated under section 271(1)(c) of the Act based on invalid assessment order. 13.1 The procedure under section 153D provides that where the assessment order u/s 153A(1)(b) or 153B(1)(b) is passed by AO below the rank of JCIT, he has to seek

M/S. IMPACT FORGING, ,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , RAJKOT

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

143(3) is bad in law and therefore no penalty proceeding can be initiated under section 271(1)(c) of the Act based on invalid assessment order. 13.1 The procedure under section 153D provides that where the assessment order u/s 153A(1)(b) or 153B(1)(b) is passed by AO below the rank of JCIT, he has to seek

M/S. IMPACT FORGING, RAJKOT,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

143(3) is bad in law and therefore no penalty proceeding can be initiated under section 271(1)(c) of the Act based on invalid assessment order. 13.1 The procedure under section 153D provides that where the assessment order u/s 153A(1)(b) or 153B(1)(b) is passed by AO below the rank of JCIT, he has to seek

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 83/Rjt/2025 (निर्धारण वर्ष/Assessment Year: (2017-18) Seabird Marine Services Pvt. Vs. Ltd. Office No. 309 & 310, Centroid Luxuria, Nr. Crystal Mall, Khodiyar Colony, Aerodrome Road, Jamnagar 361006 Assistant Commissioner Of Income-Tax, Circle-1, Jamnagar, Aayakar Bhawan, Nr. Subhash Bridge, Jamnagar -Rajkot Highway, Jamnagar स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaccs 9869 C (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Appellant By : Shri S. N. Soparkar, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Cit-Dr Date Of Hearing : 30/04/2025 Date Of Pronouncement : 30/05/2025 Per Dr. A. L. Saini, Am: आदेश / Order Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2017-18, Is Directed Against The Order Passed By The National Faceless Appeal Centre (Nfac), Dehi/ Commissioner Of Income Tax (Appeal) [In Short 'Ld. Cit(A)'], Dated 02.01.2025, Which In Turn Arises Out Of An Assessment Order Passed By The Assessing Officer, Under Section 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”), Vide Order Dated 31.12.2019. 2. Grounds Of Appeal Raised By The Assessee Are As Follows: “All The Below Mentioned Grounds Of Appeal Are Independent & Without Prejudices To Each Other.

143(2) of the Act, was issued and served upon the assessee. Subsequently, notice under section 142(1) of the Act was issued along with detailed questionnaire, on 15.01.2019. The authorised representative of the assessee, in response to these notices, submitted written submissions and relevant documentary evidences, before the assessing officer, through ITBA. During the course of assessment proceedings

AMIBEN RAJESHKUMAR PUNATAR,RAJKOT vs. ITO, WARD-1(2)(1), RAJKOT, RAJKOT

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

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.24/Rjt/2026 िनधा"रण वष"/Assessment Year : 2015-16 Amiben Rajeshkumar Punatar, बनाम/ Ito, Ashish, 41-New Jagnath Plot, Vs Ward – 1(2)(1), Rajkot – 360001(Gujarat) Rajkot "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahrpp4181F (अपीलाथ"/Assessee) (""थ"/Respondent)

143(3) of the Act. It reflects an arbitrary exercise of the power conferred under section 147 of the Act, therefore, reassessment

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

reassessment order framed by the assessing officer under section 147, read with section 143(3) of the Act, should be treated

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

reassessment order framed by the assessing officer under section 147, read with section 143(3) of the Act, should be treated

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

reassessment order framed by the assessing officer under section 147, read with section 143(3) of the Act, should be treated

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

reassessment order framed by the assessing officer under section 147, read with section 143(3) of the Act, should be treated

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

reassessment order framed by the assessing officer under section 147, read with section 143(3) of the Act, should be treated

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

reassessment order framed by the assessing officer under section 147, read with section 143(3) of the Act, should be treated

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

reassessment order framed by the assessing officer under section 147, read with section 143(3) of the Act, should be treated