SHRI SHAMJIBHAI SADHABHAI KANGAD,GANDHIDHAM-KUTCH vs. THE DCIT CENTRAL CIRCLE-1 , RAJKOT

153A is required to be issued beyond the period of six\nyears. For ready reference, extract from provision is reproduced:\n153A. (1) Notwithstanding anything contained in section 139, section 147, section\n148, section 149, section 151 and section 153, in the case of a person where a search is initiated\nunder section 132 or books of account, other documents

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

1)(b) were defective. The Tribunal also noted a non-application of mind by the Assessing Officer in not quoting the 'assessment year' and that the reasons provided were insufficient for reopening the assessment.", "result": "Allowed", "sections": [ "147", "148", "148A", "149", "143(3)", "145(3)", "43CA", "153A", "153C", "151" ], "issues": "The primary issue was whether the reassessment

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

153A or section 153C. as the case may\nbe they stood immediately before the commencement of the Finance Act, 2021\n40. In the context of the above provisions of section 149(1)(b) of the Act vis-a-\nvisnotice u/s 148 of the Act, it was submitted by ld Counsel that provisions of\nsection 149(1

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

1)(b).", "result": "Allowed", "sections": [ "147", "148", "148A", "149", "153A", "153C", "143(3)", "145(3)", "43CA" ], "issues": "Whether the reassessment

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

1)(b) of the Act. Consequently, the reassessment proceedings were quashed.", "result": "Allowed", "sections": [ "147", "148", "148A", "149", "143(3)", "132", "133A", "145(3)", "43CA", "153A

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

153A or the assessment year referred to in clause (b) of sub-section (1) of section 153B, except with the prior approval of the Joint Commissioner: Provided that nothing contained in this section shall apply where the assessment or reassessment

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

153A or the assessment year referred to in clause (b) of sub-section (1) of section 153B, except with the prior approval of the Joint Commissioner: Provided that nothing contained in this section shall apply where the assessment or reassessment

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

153A or the assessment year referred to in clause (b) of sub-section (1) of section 153B, except with the prior approval of the Joint Commissioner: Provided that nothing contained in this section shall apply where the assessment or reassessment

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

153A or the assessment year referred to in clause (b) of sub-section (1) of section 153B, except with the prior approval of the Joint Commissioner: Provided that nothing contained in this section shall apply where the assessment or reassessment

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

153A or the assessment year referred to in clause (b) of sub-section (1) of section 153B, except with the prior approval of the Joint Commissioner: Provided that nothing contained in this section shall apply where the assessment or reassessment

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

153A or section 153C. as the case may\nbe they stood immediately before the commencement of the Finance Act, 2021\n40. In the context of the above provisions of section 149(1)(b) of the Act vis-a-\nvisnotice u/s 148 of the Act, it was submitted by ld Counsel that provisions of\nsection 149(1

ASSTT. COMMR. OF INCOME TAX, CEN. CIR-1,, RAJKOT vs. RAJESHKUMAR GOVINDBHAI PATEL,, RAJKOT

In the result both the appeals filed by the Revenue and the Cross Objections filed by the assessee are hereby dismissed

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

1) of section 153A mandates the AO to issue notice in respect of the preceding six assessment years. Clause (b) mandates the AO to assess or reassess

ASSTT. COMMR. OF INCOME TAX, CEN. CIR-1,, RAJKOT vs. RAJESHKUMAR GOVINDBHAI PATEL,, RAJKOT

In the result both the appeals filed by the Revenue and the Cross Objections filed by the assessee are hereby dismissed

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

1) of section 153A mandates the AO to issue notice in respect of the preceding six assessment years. Clause (b) mandates the AO to assess or reassess

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ACIT, CENTRAL CIRL-1,, RAJKOT

In the result, appeals filed by the Revenue, in ITA No

Bench: Dr. Arjun Lal Saini & Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 134 & 135/Rjt/2023 (िनधा"रणवष" / Assessment Years: (2007-08 & 2008-09) Income Tax Officer, Ward- Shri Kherajmal Lekhrajbjai 5Th 1(2)(1), Aaykar Bhavan, Thavrani, 4- Parsana Nagar, Shri Vs. Floor, Room No. 517, Race Vaheguru Grupa, Near Refugee Course Ring Road, Rajkot-360 Colony, Rajkot-360 001 001 "थायी लेखा सं./जी आइ आर सं./Pan/Gir No.: Adrpt 5807 E (Appellant) (Respondent)

1. BHARATKUMAR ISHWARBHAI BHATIYA 2. DHAMJIBHAI & KHIRAJMAL LEKHRAJBHAI THALVANI i. Addition an account of commission income of Rs. 8,61,446/-. ii. Addition of peak credit in bank account of Rs. 46,50,353/-. On appeal, before Ld. CIT(A), the assessee did not press ground relating to commission income of Rs. 8,61,446/-, therefore, Ld. CIT(A) dismissed

THE INCOME TAX OFFICER, WARD-1 (1) (3),, RAJKOT vs. M/S. TIRUPATI AGENCIES,, RAJKOT

Appeals are dismissed

Bench: Smt.Annapurna Gupta & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 362 To 365/Rjt/2018 ("नधा"रण वष" / Assessment Years : 2008-09 To 2011-12) Income-Tax Officer M/S. Tirupati Agencies बनाम/ Ward-1(1)(3), Rajkot Prasang Commercial Vs. Complex, Nr. Chitralekha Apartment, 150 Ft. Ring Road, Rajkot "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aacft0834H .. (अपीलाथ" /Appellant) (""यथ" / Respondent) अपीलाथ" ओर से /Appellant By : Shri Shramdeep Sinha, Cit. D.R. ""यथ" क" ओर से / Shri Mehul Ranpura, A.R. Respondent By : सुनवाई क" तार"ख / Date Of 12/12/2022 Hearing घोषणा क" तार"ख /Date Of 22/02/2023 Pronouncement O R D E R Per Ms. Madhumita Roy - Jm: All Four Appeals At The Instance Of The Revenue Are Directed Against The Orders All Dated 05.07.2018 Passed By The Passed By The Commissioner Of Income Tax (Appeals) – 1, Rajkot (The Cit(A)), Arising Out Of The Assessment Orders All Dated 29.03.2016 Passed By The Learned Ito, Ward 1(1)(3), Rajkot Under Section

1) of the Act. Subsequently, a search under Section 132 of the Act was carried out at the premises of the assessee on 24.06.2010 and finally the assessment proceedings initiated thereon under Section 153A of the Act for A.Ys. 2005-06 to 2010-11 was completed on 25.10.2012. Fort the year under consideration, the relevant assessment has been completed determining

THE INCOME TAX OFFICER, WARD-1 (1) (3),, RAJKOT vs. M/S. TIRUPATI AGENCIES,, RAJKOT

Appeals are dismissed

Bench: Smt.Annapurna Gupta & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 362 To 365/Rjt/2018 ("नधा"रण वष" / Assessment Years : 2008-09 To 2011-12) Income-Tax Officer M/S. Tirupati Agencies बनाम/ Ward-1(1)(3), Rajkot Prasang Commercial Vs. Complex, Nr. Chitralekha Apartment, 150 Ft. Ring Road, Rajkot "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aacft0834H .. (अपीलाथ" /Appellant) (""यथ" / Respondent) अपीलाथ" ओर से /Appellant By : Shri Shramdeep Sinha, Cit. D.R. ""यथ" क" ओर से / Shri Mehul Ranpura, A.R. Respondent By : सुनवाई क" तार"ख / Date Of 12/12/2022 Hearing घोषणा क" तार"ख /Date Of 22/02/2023 Pronouncement O R D E R Per Ms. Madhumita Roy - Jm: All Four Appeals At The Instance Of The Revenue Are Directed Against The Orders All Dated 05.07.2018 Passed By The Passed By The Commissioner Of Income Tax (Appeals) – 1, Rajkot (The Cit(A)), Arising Out Of The Assessment Orders All Dated 29.03.2016 Passed By The Learned Ito, Ward 1(1)(3), Rajkot Under Section

1) of the Act. Subsequently, a search under Section 132 of the Act was carried out at the premises of the assessee on 24.06.2010 and finally the assessment proceedings initiated thereon under Section 153A of the Act for A.Ys. 2005-06 to 2010-11 was completed on 25.10.2012. Fort the year under consideration, the relevant assessment has been completed determining

THE INCOME TAX OFFICER, WARD-1 (1) (3),, RAJKOT vs. M/S. TIRUPATI AGENCIES,, RAJKOT

Appeals are dismissed

Bench: Smt.Annapurna Gupta & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 362 To 365/Rjt/2018 ("नधा"रण वष" / Assessment Years : 2008-09 To 2011-12) Income-Tax Officer M/S. Tirupati Agencies बनाम/ Ward-1(1)(3), Rajkot Prasang Commercial Vs. Complex, Nr. Chitralekha Apartment, 150 Ft. Ring Road, Rajkot "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aacft0834H .. (अपीलाथ" /Appellant) (""यथ" / Respondent) अपीलाथ" ओर से /Appellant By : Shri Shramdeep Sinha, Cit. D.R. ""यथ" क" ओर से / Shri Mehul Ranpura, A.R. Respondent By : सुनवाई क" तार"ख / Date Of 12/12/2022 Hearing घोषणा क" तार"ख /Date Of 22/02/2023 Pronouncement O R D E R Per Ms. Madhumita Roy - Jm: All Four Appeals At The Instance Of The Revenue Are Directed Against The Orders All Dated 05.07.2018 Passed By The Passed By The Commissioner Of Income Tax (Appeals) – 1, Rajkot (The Cit(A)), Arising Out Of The Assessment Orders All Dated 29.03.2016 Passed By The Learned Ito, Ward 1(1)(3), Rajkot Under Section

1) of the Act. Subsequently, a search under Section 132 of the Act was carried out at the premises of the assessee on 24.06.2010 and finally the assessment proceedings initiated thereon under Section 153A of the Act for A.Ys. 2005-06 to 2010-11 was completed on 25.10.2012. Fort the year under consideration, the relevant assessment has been completed determining

THE INCOME TAX OFFICER, WARD-1 (1) (3),, RAJKOT vs. M/S. TIRUPATI AGENCIES,, RAJKOT

Appeals are dismissed

Bench: Smt.Annapurna Gupta & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 362 To 365/Rjt/2018 ("नधा"रण वष" / Assessment Years : 2008-09 To 2011-12) Income-Tax Officer M/S. Tirupati Agencies बनाम/ Ward-1(1)(3), Rajkot Prasang Commercial Vs. Complex, Nr. Chitralekha Apartment, 150 Ft. Ring Road, Rajkot "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aacft0834H .. (अपीलाथ" /Appellant) (""यथ" / Respondent) अपीलाथ" ओर से /Appellant By : Shri Shramdeep Sinha, Cit. D.R. ""यथ" क" ओर से / Shri Mehul Ranpura, A.R. Respondent By : सुनवाई क" तार"ख / Date Of 12/12/2022 Hearing घोषणा क" तार"ख /Date Of 22/02/2023 Pronouncement O R D E R Per Ms. Madhumita Roy - Jm: All Four Appeals At The Instance Of The Revenue Are Directed Against The Orders All Dated 05.07.2018 Passed By The Passed By The Commissioner Of Income Tax (Appeals) – 1, Rajkot (The Cit(A)), Arising Out Of The Assessment Orders All Dated 29.03.2016 Passed By The Learned Ito, Ward 1(1)(3), Rajkot Under Section

1) of the Act. Subsequently, a search under Section 132 of the Act was carried out at the premises of the assessee on 24.06.2010 and finally the assessment proceedings initiated thereon under Section 153A of the Act for A.Ys. 2005-06 to 2010-11 was completed on 25.10.2012. Fort the year under consideration, the relevant assessment has been completed determining