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 proceedings can sustain on the basis of a foundational notice being issued by a Non-Jurisdictional AO. 7. Reliance is placed on: Nimir Kishore Mehta v. Assistant Commissioner of Income-tax/20241 161 axmann.com 553 (Bombay) For 15 Page 12 of 25 ITA No. 611 & 612/RJT/2025 Dff Shri Gandhi Maulana Azas Shramjivi Ashra The further point is Respondent

KALPESH RAVJIBHAI SOJITRA,JASDAN vs. THE INCOME TAX OFFICER, WARD 2(1)(2), RAJKOT, RAJKOT

In the result, appeal filed by the assessee is allowed, in above terms

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrid Hearing) Kalpesh Ravjibhai Sojitra, Vs. The Ito, Prop. Sojitra Petrolium, Bypass Ward-2(1)(2), Circle Atkot Road, Jasdan, Rajkot 360050, Rajkot-( Guj) "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Bqmps8120G (/Appellant) (/Respondent)

reassessment order was quashed. The findings of the Tribunal are as follows: 7. The assessee’s contention is that jurisdictional notice issued by the JAO u/s 148 after 09.03.2023 in order to reopen the assessment is bad in law since he didn’t adhere to the provisions of Section 151 of the Act and the scheme notified by the CBDT

PRANAM ENTERPRISE,JUNAGADH vs. DCIT, CIRCLE-1(1), RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.391/Rjt/2024 Assessment Year: (2017-18) (Hybrid Hearing) Pranam Enterprise Vs. The Dcit Office No.3, City Centre, Opp. Circle-1(1), Rajkot New Collector Office, Junagadh – 362001, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaffp7926H (Assessee) (Respondent) Assessee By Shri Mehul Ranpura, Ar Respondent By Shri Abhimanyu Singh Yadav, Sr.Dr Date Of Hearing 18/12/2024 Date Of Pronouncement 06/03/2025 आदेश / O R D E R Per Dr. A. L. Saini, Am:

163 taxmann.com 191 (Ahmedabad – trib.), wherein Tribunal held as follows: “9. We have heard the rival contentions and perused the material on record. 10. The issue for consideration before us is that whether penalty under Section 270A of the Act can be levied in the instant set of facts, when as per the assessee, she was under the genuine belief

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)

sections 148 to 163, assess or reassess such income and also any other income chargeable to tax, which has escaped

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)

sections 148 to 163, assess or reassess such income and also any other income chargeable to tax, which has escaped

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)

sections 148 to 163, assess or reassess such income and also any other income chargeable to tax, which has escaped

THE DCIT, (INTL. TAXN.), RAJKOT vs. M/S. KOREA SOUTH EAST POWER CO. LTD., MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Smt. Annapurna Gupta & Shri T.R. Senthil Kumar(Conducted Through Virtual Court) Assessment Year: 2011-12 The Dcit (Intl. Taxn.) M/S.Korea South East Power Amruta Estate Co.Ltd. Room No.312 Mg Road बनाम/ C/O. P.V. Page & Co., Girnar Cinema 201, Sardar Griha, 198 L.T. Marg Vs. Rajkot Mumbai – 400 002 (Appellant) (Respondent) Pan: Pan : Ahvps 3555Q Assessee By None Revenue By Shri Ashish Kumar Pandey, Sr.Dr Date Of Hearing 25/09/2023 Date Of Pronouncement 15/12/2023

163 Taxman 533 (Delhi): "Section 271(1)(c) of the Income-tax Act, 1961- Penalty For concealment of income - Assessment year 2001-02-Assessee had declared its income from brokerage and other income against which it had claimed share trading loss - Assessing Officer found that loss was speculative in nature and could not be adjusted against assessee's normal income

SIX TWENTY REALTY PVT. LTD.,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

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

163 Taxman 654 (Delhi) upheld the finding of the tribunal that no income can be estimated on the basis of the evidences found for a particular period.  Hon'ble ITAT Ahmedabad in case of Savaliya Developers Pvt. Ltd V. DCIT in ITA No. 401/Ahd/2014 & 3188/Ahd/2015 vide order 30.06.2019held as under in context to extrapolation: "Besides, estimated cash receipts

SIX TWENTY REALTY PVT LTD,RAJOT vs. DCIT, CC-1, RAJKOT, RAJKOT

163\nTaxman 654 (Delhi) upheld the finding of the tribunal that no income can be\nestimated on the basis of the evidences found for a particular period.\n\n• Hon'ble ITAT Ahmedabad in case of Savaliya Developers Pvt. Ltd V. DCIT in ITA\nNo. 401/Ahd/2014 & 3188/Ahd/2015 vide order 30.06.2019held as under in context\nto extrapolation:\n\"Besides, estimated

DCIT, CENTRAL CIRCLE-1, RAJKOT, RAJKOT vs. SIX TWENTY REALTY PRIVATE LIMITED, RAJKOT

163\nTaxman 654 (Delhi) upheld the finding of the tribunal that no income can be\nestimated on the basis of the evidences found for a particular period.\n\n• Hon'ble ITAT Ahmedabad in case of Savaliya Developers Pvt. Ltd V. DCIT in ITA\nNo. 401/Ahd/2014 & 3188/Ahd/2015 vide order 30.06.2019held as under in context\nto extrapolation:\n\"Besides, estimated

SIX TWENTY REALTY PVT. LTD.,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

163\nTaxman 654 (Delhi) upheld the finding of the tribunal that no income can be\nestimated on the basis of the evidences found for a particular period.\n\n•\nHon'ble ITAT Ahmedabad in case of Savaliya Developers Pvt. Ltd V. DCIT in ITA\nNo. 401/Ahd/2014 & 3188/Ahd/2015 vide order 30.06.2019held as under in context\nto extrapolation:\n\"Besides, estimated