MANSUKHBHAI KANJIBHAI SAKARIYA,RAJKOT vs. PRINCIPAL COMMISSIONER OF INCOME TAX, RAJKOT-1, RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita No.318/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2016-17 Mansukhbhai Kanjibhai Sakariya The Pr.Commissioner Of बनाम At Khajuri Gundala Income Tax-1, Rajkot. Post Station: Vavdi Vs. Amarnagar, Khajuri Gundala. Pan : Aslps 7027 E (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रतीक"ओरसे/Assessee By : Shri Rajendra Singhal, Ld.Ar राज"वक"ओरसे/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

reassessment order itself is not valid, therefore, subsequent order passed by the ld.Pr.CIT by exercising the revisionary jurisdiction is also bad in law. 6.The assessee also submitted before ld. PCIT that during the assessment proceedings, the assessing officer has conducted sufficient inquiry in respect of the issue raised by the ld. Pr. CIT. The assessee also submitted before the ld.Pr.CIT

THE ACIT-CENTRAL CIRCLE-2, RAJKOT vs. SHRI VICKY BALKRISHNA MEHTA, RAJKOT

The appeal of the Revenue is dismissed

Bench: Mrs. Annapurna Gupta & Shri Siddhartha Nautiyal"नधा"रणवष"/Assessment Year: 2004-05 Assistant Commissioner Of Vs. Shri Vicky Balkrishna Mehta, Income-Tax, 7Th Floor, Mansrovar Central Circle-2, Apartment, Royal Park, Rajkot Kalawad Road, Rajkot Pan : Agqpm 6495 B अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri D.M. Rindani, Ar Revenue By : Shri Shramdeep Sinha, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 28.11.2022 घोषणा क" तार"ख /Date Of Pronouncement: 22.02.2023 आदेश/O R D E R Per Annapurna Gupta: This Appeal Is Preferred By The Revenue Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)-13, Ahmedabad (Hereinafter Referred To As “Cit(A)”) Dated 22.01.2020 Passed U/S 250(6) Of The Income-Tax Act, 1961, (Hereinafter Referred To As “The Act”) For Assessment Year (Ay) 2004-05. 2. The Grounds Of Appeal Raised By The Revenue Read As Under:

14. To hold that the amendment to sub-section (1) would enable the authorities to reopen assessments, which had already attained finality due to bar of limitation prescribed under section 149 as applicable prior to 1.4. 1989, would amount to give sub section (1) a retrospective operation which is neither expressly nor impliedly intended by the amended sub- section

SHRI GIRISHBHAI NANJIBHAI SOLANKI,RAJKOT vs. THE ITO, WARD-1 (1) (2), RAJKOT

In the result the appeal filed by the assessee is allowed partly for the statistical purposes

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

2. This ground goes to the root of the matter and it is a legal ground as to the validity of the reassessment. 3. The legal ground can be taken up at any stage . in this regards reliance is placed on decision of Supreme Court in case of National Thermal Power

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

2 to section 147 are applicable to facts of this case andl have reasons to believe that the amount of Rs.25,00,000/-being sum as unexplained cash transaction[also violation of section 40A(3) of the Act] is chargeable to tax has escaped within the meaning of Sec 147 of the Act and the assessment year under consideration

CLASSIC NETWORK PRIVATE LIMITED,RAJKOT vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL - 1, RAJKOT, RAJKOT

In the result, appeal filed by the assessee in ITA No

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

2 to section 147 are applicable to facts of this case andl have reasons to believe that the amount of Rs.25,00,000/-being sum as unexplained cash transaction[also violation of section 40A(3) of the Act] is chargeable to tax has escaped within the meaning of Sec 147 of the Act and the assessment year under consideration

CLASSIC NETWORK PRIVATE LIMITED,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1 RAJKOT, RAJKOT

In the result, appeal filed by the assessee in ITA No

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

2 to section 147 are applicable to facts of this case andl have reasons to believe that the amount of Rs.25,00,000/-being sum as unexplained cash transaction[also violation of section 40A(3) of the Act] is chargeable to tax has escaped within the meaning of Sec 147 of the Act and the assessment year under consideration

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAJKOT, RAJKOT vs. CLASSIC NETWORK PVT. LTD., RAJKOT

In the result, appeal filed by the assessee in ITA No

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

2 to section 147 are applicable to facts of this case andl have reasons to believe that the amount of Rs.25,00,000/-being sum as unexplained cash transaction[also violation of section 40A(3) of the Act] is chargeable to tax has escaped within the meaning of Sec 147 of the Act and the assessment year under consideration

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAJKOT vs. CLASSIC NETWORK PVT. LTD., RJAKOT

In the result, appeal filed by the assessee in ITA No

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

2 to section 147 are applicable to facts of this case andl have reasons to believe that the amount of Rs.25,00,000/-being sum as unexplained cash transaction[also violation of section 40A(3) of the Act] is chargeable to tax has escaped within the meaning of Sec 147 of the Act and the assessment year under consideration

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

2 to section 147 are applicable to facts of this case andl have reasons to believe that the amount of Rs.25,00,000/-being sum as unexplained cash transaction[also violation of section 40A(3) of the Act] is chargeable to tax has escaped within the meaning of Sec 147 of the Act and the assessment year under consideration

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

2 to section 147 are applicable to facts of this case andl have reasons to believe that the amount of Rs.25,00,000/-being sum as unexplained cash transaction[also violation of section 40A(3) of the Act] is chargeable to tax has escaped within the meaning of Sec 147 of the Act and the assessment year under consideration

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

2 to section 147 are applicable to facts of this case andl have reasons to believe that the amount of Rs.25,00,000/-being sum as unexplained cash transaction[also violation of section 40A(3) of the Act] is chargeable to tax has escaped within the meaning of Sec 147 of the Act and the assessment year under consideration

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

2 to section 147 are applicable to facts of this case andl have reasons to believe that the amount of Rs.25,00,000/-being sum as unexplained cash transaction[also violation of section 40A(3) of the Act] is chargeable to tax has escaped within the meaning of Sec 147 of the Act and the assessment year under consideration

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

2 to section 147 are applicable to facts of this case andl have reasons to believe that the amount of Rs.25,00,000/-being sum as unexplained cash transaction[also violation of section 40A(3) of the Act] is chargeable to tax has escaped within the meaning of Sec 147 of the Act and the assessment year under consideration

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

2 to section 147 are applicable to facts of this case andl have reasons to believe that the amount of Rs.25,00,000/-being sum as unexplained cash transaction[also violation of section 40A(3) of the Act] is chargeable to tax has escaped within the meaning of Sec 147 of the Act and the assessment year under consideration

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

2 to section 147 are applicable to facts of this case andl have reasons to believe that the amount of Rs.25,00,000/-being sum as unexplained cash transaction[also violation of section 40A(3) of the Act] is chargeable to tax has escaped within the meaning of Sec 147 of the Act and the assessment year under consideration

CLASSIC NETWORK PRIVATE LIMITED,RAJKOT vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1, RAJKOT, RAJKOT

In the result, appeal filed by the assessee in ITA No

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

2 to section 147 are applicable to facts of this case andl have reasons to believe that the amount of Rs.25,00,000/-being sum as unexplained cash transaction[also violation of section 40A(3) of the Act] is chargeable to tax has escaped within the meaning of Sec 147 of the Act and the assessment year under consideration

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

2 to section 147 are applicable to facts of this case andl have reasons to believe that the amount of Rs.25,00,000/-being sum as unexplained cash transaction[also violation of section 40A(3) of the Act] is chargeable to tax has escaped within the meaning of Sec 147 of the Act and the assessment year under consideration

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

14-16)\n(iv)Copy of notice u/s. 148 of the Act dated 23.02.2023 issued by the\nDCIT/ACIT central Circle – 2, Rajkot for AY 2016-17. (Paper book pg no. 17)\n(v) Copy of reply and preliminary objections raised dated 01.03.2023 filed by the\nappellant alongwith return of income filed in response to notice u/s. 148 of the\nAct