SHRI JAWAHIR RAVICHANDRA MEHTA,DUBAI(UAE) vs. THE DCIT, CIRCLE-2, RAJKOT, RAJKOT

In the result appeal of the assessee vide ITA/81/Rjt/2020 stands dismissed

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Amarjit Singh, Accountant Memebr

reassessment had already expired. 17. We do not find the above reasoning of the High Court is sound. The plain language of sub-section (2) of Section 150 clearly restricts application of sub- section (1) to enable the Authority to reopen assessments which have not already become final on the expiry of prescribed period of limitation under Section 149

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. SHRI MUKESH MANEKCHAND SHETH, RAJKOT

reassessment proceedings invalid.", "result": "Allowed", "sections": ["Section 147", "Section 148", "Section 143(3)", "Section 145(3)", "Section 148A", "Section 149

RAVICHANDRA V. MEHTA,,RAJKOT vs. ASSTT. COMMR. OF INCOME TAX, CEN. CIR.-2, , RAJKOT

In the result, appeals of the assessee are allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

reassessment had already expired. 17. We do not find the above reasoning of the High Court is sound. The plain language of sub-section (2) of Section 150 clearly restricts application of sub- section (1) to enable the Authority to reopen assessments which have not already become final on the expiry of prescribed period of limitation under Section 149

ASSTT. COMMR. OF INCOME TAX, CEN. CIR.-2, , RAJKOT vs. RAVICHANDRA V. MEHTA,, RAJKOT

In the result, appeals of the assessee are allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

reassessment had already expired. 17. We do not find the above reasoning of the High Court is sound. The plain language of sub-section (2) of Section 150 clearly restricts application of sub- section (1) to enable the Authority to reopen assessments which have not already become final on the expiry of prescribed period of limitation under Section 149

DCIT, CENTRAL CIRCLE 2, RAJKOT, RAJKOT vs. SHRI MUKESH MANEKCHAND SHETH, RAJKOT

reassessment proceedings were invalid due to procedural defects and lack of proper documentation.", "held": "The Tribunal found that the reasons recorded by the Assessing Officer, the approval of the satisfaction note, the notice under section 148, and the procedures under sections 148A and 149

MUKESH MANEKCHAND SHETH,RAJKOT vs. THE DCIT-ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

sections": ["147", "148", "143(3)", "145(3)", "132", "133A", "131", "148A", "149", "149(1)(b)", "43CA", "153A", "153C", "151"], "issues": "The primary issue was the validity of the reassessment

MUKESH MANEKCHAND SHETH,RAJKOT vs. THE DCIT-ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

sections": [ "147", "148", "148A", "149", "153A", "153C", "143(3)", "145(3)", "43CA" ], "issues": "Whether the reassessment proceedings initiated under section

MUKESH MANEKCHAND SHETH,RAJKOT vs. THE DCIT-ACIT, CENTRAL CIRCLE -2, RAJKOT., RAJKOT

Section 149(1)(b) of the Act. Consequently, the reassessment proceedings were quashed.", "result": "Allowed", "sections": [ "147", "148", "148A", "149

SHIV EXTRUSION,JAMNAGAR vs. INCOME TAX OFFICER, JAMNAGAR

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini, Am. & Dr. Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 646/Rjt/2025 "नधा"रणवष" / Assessment Year: (2016-17) (Hybrid Hearing) Shiv Extrusion Vs. Income Tax Officer Plot No.3978 Phase Iiiroad Income Tax Office, Ito Ward No.-R Dared, Jamnagar 2(10), Jamnagar, Income 361004, Gujarat, India, Jamnagar Tax Office, Shiv Smruti, Jamnagar, Jamnagar, Gujarat, 361008, Jamnagar "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abkfs7199F (Appellant) (Respondent) Appellant By : Shri Ramesh M. Patel, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 23/12/2025 Date Of Pronouncement : 12/03/2026

Section 149(1)(b)): The NFAC erred in sustaining the reassessment initiated under the extended period of limitation prescribed by Section

MUKESH MANEKCHAND SHETH,RAJKOT vs. THE DCIT-ACIT, CENTRAL CIRCLE -2, RAJKOT, RAJKOT

sections": [ "147", "148", "143(3)", "148A", "149", "153A", "153C", "43CA", "145(3)" ], "issues": "Whether the reassessment proceedings initiated under Section

MOHAN HARDASMAL TAHILYANI,GANDHIDHAM vs. INCOMETAX OFFICER WARD 1 GANDHIDHAM, GANDHIDHAM

In the result, appeal filed by the assessee is allowed

149", "Section 151", "Section 69A", "Section 148A"], "issues": "Whether the reassessment notice issued under Section 148 of the Income Tax Act, 1961, is valid

KISHAN BEEJ,JAMNAGAR vs. ITO WARD 2(1), JAMNAGAR

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.384/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2017-18 Kishan Beej Ito, Wared-2(1) बनाम Kashivishvanath Road Jamnagar – 361 001 Nr. P & T Office Vs. Jamnagar – 361 001 Pan : Aacfk 2114 P (अपीलाथ"/Appellant) (""यथ"/Respondent) :

reassessment notice under section 148 after 1-4- 2021, the revenue would still have to look at: (i) the time limit specified under section 149

KANTILAL RANCHHODBHAI NAKUM,JAMNAGAR vs. ITO WARD - 1(3), JAMNAGAR

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./ Ita No.551/Rjt/2025 Assessment Year: 2015-16 Kantilal Ranchhodbhai Nakum Income Tax Officer, Ward-1(3), Plot No.762, Gidc, Phase-2, बनाम/ Jamnagar, Aaykar Bhawan, Nr. Dared, Jamnagar-361 004 Vs. Chamber Of Commerce Hall, Jamnagar- Rajkot Highway, Jamnagar-361 001 "ायीलेखासं/.जीआइआरसं./ Pan/Gir No.: Aflpn 8072 P (अपीलाथ"/Appellant) (""थ"/Respondent) : िनधा"रती की ओर से/Assessee By : Shri Ravindra Manek, Ar राज" की ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 17/12/2025 घोषणा की तारीख/Date Of Pronouncement : 13/02/2026 आदेश / O R D E R Per, Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2015-16, 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) [In Short, “Cit(A)”] Dated 29.07.2025, Which In Turn Arises Out Of An Assessment Order Passed By Assessing Officer U/S 147 R.W.S. 144B Of The Act, On 12.05.2023. 2. Grounds Of Appeal Raised By The Assessee Are As Follows: “1.The Hon’Ble Cit(A) Erred In Law & On Facts In Confirming Reopening Of Assessment U/S 148 Of The Act.

Section 149(1)(b) of the Act, as it existed prior to 4 Kantilal R Nakum 01.04.2021, then notice u/s 148A(b) would be time barred by 31.03.2022. The decision of Hon’ble Supreme Court in case of Ashish Agarwal would not apply to the case of assessee as it would only apply to judgments and orders passed by different

NILESHKUMAR M BHALODI,RAJKOT vs. THE INCOME TAX OFFICER, WARD - 2(1)(1), RAJKOT, RAJKOT

In the result, appeal filed by the assessee is allowed

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

section 149 of the Act with effect from 01.04.2021, three years would be over on 31.03.2019 which is prior to coming into force of TOLA and six years would be completed on 31.03.2022 which is after operation of TOLA. In such circumstances, notices for Assessment Year 2015-2016 are held to be invalid by Hon'ble Apex Court in case

SANJAYKUMAR HARIBHAI PARSANA,RAJKOT vs. DCIT/ACIT CIR 1(1), RKT, RAJKOT

In the result, appeal filed by the assessee is allowed

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

149(1)(b) of the Act, as it existed prior to 01.04.2021, then notice u/s 148A(b) would be time barred by 31.03.2022. The decision of Hon’ble Supreme Court in case of Ashish Agarwal would not apply to the case of assessee as it would only apply to judgments and orders passed by different High Courts where similar notices

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. Section 149 requires assessing officers to issue a notice of reassessment under Section 148 within the prescribed time limits

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. Section 149 requires assessing officers to issue a notice of reassessment under Section 148 within the prescribed time limits

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

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

reassessment notice 2) under section 148 has undergone a change by replacing the old procedure under sections 147 to 151 by new procedure under section 147 to 151 including the insertion provision of section 148A providing an opportunity of hearing to the petitioners in consonance with the decision of the Hon'ble Apex Court in case of GKN Driveshafts India

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

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

reassessment notice 2) under section 148 has undergone a change by replacing the old procedure under sections 147 to 151 by new procedure under section 147 to 151 including the insertion provision of section 148A providing an opportunity of hearing to the petitioners in consonance with the decision of the Hon'ble Apex Court in case of GKN Driveshafts India