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

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

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)

1 had considered the effect and interpretation of the Section 151 (A) of the Income Tax as extracted herein under: "3. It is apparent that the impugned notice dated 5 April, 2022 issued under Section 148 of the Act and the order of the same date under Section 148A(d) of the Act are issued by the Jurisdictional Assessing Officer

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)

163, assess or reassess such income and also any other income chargeable to tax, which has escaped assessment and which comes to his notice subsequently in the course of the proceedings under the section. The first proviso to section 147 has no application to the facts of the instant case. The basic postulate, which underlines section 147, is the formation

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)

163, assess or reassess such income and also any other income chargeable to tax, which has escaped assessment and which comes to his notice subsequently in the course of the proceedings under the section. The first proviso to section 147 has no application to the facts of the instant case. The basic postulate, which underlines section 147, is the formation

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)

163, assess or reassess such income and also any other income chargeable to tax, which has escaped assessment and which comes to his notice subsequently in the course of the proceedings under the section. The first proviso to section 147 has no application to the facts of the instant case. The basic postulate, which underlines section 147, is the formation

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.,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

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