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

154(3) of the Act.\n3. The facts of the case which can be stated quite shortly are as follows: The\nassessee e-filed its return of income for assessment year (A.Y.) 2020-21 on\n28.01.2021, declaring total income Rs.58,44,15,970/-, which was processed u/s\n143(1) of the Income Tax Act, 1961 by the CPC, Bengaluru

KUMAR RAMESH SAHU,RAJKOT, GUJARAT vs. ACIT, CIRCLE-2(2), RAJKOT, RAJKOT, GUJARAT

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./I.T.A. No.336/Rjt/2023 (िनधा"रण वष" / Assessment Year : 2009-10) Kumar Ramesh Sahu बनाम/ The Acit, Sundaram, 72/3, New Cirtcle-2(3) Vs. College Wadi Rajkot – 60 001 150Ft5. Ring Road Opp. Meera Apartment Rajkot – 360 005 (Gujarat) "ायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aesps 5531 C (अपीलाथ" /Appellant) (""थ" / Respondent) .. Assessee By : Shri M.N. Manvar, Ld. Ar Revenue By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr सुनवाई की तारीख / Date Of Hearing 13/01/2025 घोषणा की तारीख /Date Of Pronouncement 04/04/2025 आदेश / O R D E R Per Dinesh Mohan Sinha:

Section 147 of the of the Act. (iii) According to written statement, the reasons recorded on the basis of the information by some other officer could not satisfy the requirement in law. This is a case of only borrowed satisfaction, which is not at all permissible and therefore the power u/s 147 of the Act should not be exercised mechanically

THE ITO, WARD-3(1)(1),, RAJKOT-GUJARAT vs. SHRI GIRISHKUMAR M. PURUSWANI,, RAJKOT-GUJARAT

In the result, the appeal filed by the Revenue is hereby dismissed

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

154) held as under: (Quote) "Section 147 provides that if the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may, subject to the provisions of sections 148 to 163, assess or reassess such income and also any other income chargeable to tax, which has escaped assessment and which

THE ITO, WARD-3(1)(1),, RAJKOT-GUJARAT vs. SHRI GIRISHKUMAR M. PURUSWANI,, RAJKOT-GUJARAT

In the result, the appeal filed by the Revenue is hereby dismissed

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

154) held as under: (Quote) "Section 147 provides that if the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may, subject to the provisions of sections 148 to 163, assess or reassess such income and also any other income chargeable to tax, which has escaped assessment and which

THE ITO, WARD-3(1)(1),, RAJKOT-GUJARAT vs. SHRI GIRISHKUMAR M. PURUSWANI,, RAJKOT-GUJARAT

In the result, the appeal filed by the Revenue is hereby dismissed

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

154) held as under: (Quote) "Section 147 provides that if the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may, subject to the provisions of sections 148 to 163, assess or reassess such income and also any other income chargeable to tax, which has escaped assessment and which

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

reassessment shall be issued by the Assessing\nOfficer for the relevant assessment year or years unless\n(a) the Assessing Officer has in his possession books of account or other documents or\nevidence which reveal that the income, represented in the form of asset, which has\nescaped assessment amounts to or is likely to amount to fifty lakh rupees