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

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 approval from the JCIT. The issue arises whether assessment/ reassessment made u/s 153C

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

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 approval from the JCIT. The issue arises whether assessment/ reassessment made u/s 153C

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

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 approval from the JCIT. The issue arises whether assessment/ reassessment made u/s 153C

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

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)(b) of the Act, empowers an authority

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", "153C

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

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)(b) of the Act, empowers an authority

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

153C of the Act instead of u/s. 147/148 of the Act. In the assessee’s case under consideration, the assessment order was framed by the assessing officer under section 147/148 of the Act, therefore, reassessment proceedings may be quashed. Page 23of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 35. The Ld. Counsel also

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

153C of the Act instead of u/s. 147/148 of the Act. In the assessee’s case under consideration, the assessment order was framed by the assessing officer under section 147/148 of the Act, therefore, reassessment proceedings may be quashed. Page 23of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 35. The Ld. Counsel also

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

153C of the Act instead of u/s. 147/148 of the Act. In the assessee’s case under consideration, the assessment order was framed by the assessing officer under section 147/148 of the Act, therefore, reassessment proceedings may be quashed. Page 23of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 35. The Ld. Counsel also

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

153C of the Act instead of u/s. 147/148 of the Act. In the assessee’s case under consideration, the assessment order was framed by the assessing officer under section 147/148 of the Act, therefore, reassessment proceedings may be quashed. Page 23of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 35. The Ld. Counsel also

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

153C of the Act instead of u/s. 147/148 of the Act. In the assessee’s case under consideration, the assessment order was framed by the assessing officer under section 147/148 of the Act, therefore, reassessment proceedings may be quashed. Page 23of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 35. The Ld. Counsel also

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

153C of the Act instead of u/s. 147/148 of the Act. In the assessee’s case under consideration, the assessment order was framed by the assessing officer under section 147/148 of the Act, therefore, reassessment proceedings may be quashed. Page 23of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 35. The Ld. Counsel also

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

153C of the Act instead of u/s. 147/148 of the Act. In the assessee’s case under consideration, the assessment order was framed by the assessing officer under section 147/148 of the Act, therefore, reassessment proceedings may be quashed. Page 23of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 35. The Ld. Counsel also

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

153C of the Act instead of u/s. 147/148 of the Act. In the assessee’s case under consideration, the assessment order was framed by the assessing officer under section 147/148 of the Act, therefore, reassessment proceedings may be quashed. Page 23of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 35. The Ld. Counsel also

THE ASSISTANT 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

153C of the Act instead of u/s. 147/148 of the Act. In the assessee’s case under consideration, the assessment order was framed by the assessing officer under section 147/148 of the Act, therefore, reassessment proceedings may be quashed. Page 23of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 35. The Ld. Counsel also