ACIT, CIR-1(1), RAJKOT, RAJKOT vs. SHRI RAJKOT DISTRICT CO OPERATIVE BANK LTD, RAJKOT

The appeal of the revenue is dismissed

Bench: Dr. Arjun Lal Saini. & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.188/Rjt/2024 िनधा"रणवष"/ Assessment Year: (2015-16) (Hybrid Hearing) Assistant Commissioner Of Income- Vs. Rajkot District Co-Operative Bank Tax, Circle-1 (1), Rajkot Limited Room No.502, Aayakar Bhawan, Jilla Bankbhavan, Kasturba Road, Race Course Ring Road, Rajkot- Opp: Chaudhary High School, 360001 Rajkot 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaar0564K (Appellant) (Respondent) Appellant By : Shri D. M. Rindani, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld.Sr.Dr : 09/06 /2025 Date Of Hearing Date Of Pronouncement : 05/08 /2025

24,98,450/-. The case was selected for scrutiny and after detail scrutiny of the case the assessment was completed on 28.12.2017 u/s 143(3) of the Act determining total income at Rs. 32,00,13,650/- by making addition on account of excess claim of deduction u/s 36(1) (viii) of Rs. 75,15,201/-.The appellant

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

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

24-08-2021 and pursuant to the search, notice under\nSection 148 of the Act was issued in case of assessee. As search was carried out\nin the case of assessee after 01-04-2021 wherein provisions of Section 148 were\namended and provides deemed satisfaction for three assessment years prior to the\ndate of search and even on this

DCIT, CENTRAL CIRCLE 2, RAJKOT, RAJKOT vs. SHRI MUKESH MANEKCHAND SHETH, RAJKOT

24-08-2021 and pursuant to the search, notice under\nSection 148 of the Act was issued in case of assessee. As search was carried out\nin the case of assessee after 01-04-2021 wherein provisions of Section 148 were\namended and provides deemed satisfaction for three assessment years prior to the\ndate of search and even on this

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

24-08-2021 and pursuant to the search, notice under\nSection 148 of the Act was issued in case of assessee. As search was carried out\nin the case of assessee after 01-04-2021 wherein provisions of Section 148 were\namended and provides deemed satisfaction for three assessment years prior to the\ndate of search and even on this

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

24-08-2021 and pursuant to the search, notice under\nSection 148 of the Act was issued in case of assessee. As search was carried out\nin the case of assessee after 01-04-2021 wherein provisions of Section 148 were\namended and provides deemed satisfaction for three assessment years prior to the\ndate of search and even on this

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

24-08-2021 and pursuant to the search, notice under\nSection 148 of the Act was issued in case of assessee. As search was carried out\nin the case of assessee after 01-04-2021 wherein provisions of Section 148 were\namended and provides deemed satisfaction for three assessment years prior to the\ndate of search and even on this

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

24-08-2021 and pursuant to the search, notice under\nSection 148 of the Act was issued in case of assessee. As search was carried out\nin the case of assessee after 01-04-2021 wherein provisions of Section 148 were\namended and provides deemed satisfaction for three assessment years prior to the\ndate of search and even on this

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

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकरअपीलसं./Ita Nos. 31 & 32/Rjt/2020 िनधा"रणवष"/Asstt. Years:2011-12, 2012-13 िनधा"रणवष" िनधा"रणवष" िनधा"रणवष"

24-10-2015 and the AO was required to issue notice under section 143(2) of the Act on or before 30th September 2016. However, the notice was issued dated 07-12-2016 which was beyond the time limit provided under the statute. Hence, the notice issued under section 143(2) of the Act was invalid. Therefore

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

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकरअपीलसं./Ita Nos. 31 & 32/Rjt/2020 िनधा"रणवष"/Asstt. Years:2011-12, 2012-13 िनधा"रणवष" िनधा"रणवष" िनधा"रणवष"

24-10-2015 and the AO was required to issue notice under section 143(2) of the Act on or before 30th September 2016. However, the notice was issued dated 07-12-2016 which was beyond the time limit provided under the statute. Hence, the notice issued under section 143(2) of the Act was invalid. Therefore

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita Nos. 498 & 499/Rjt/2025 "नधा"रणवष"/ Assessment Years: 2015-16 & 2020-21 बनाम Gopal Snacks Pvt. Ltd. Asst. Commissioner Of Plot No.2322-2324, Gidc Metoda, Income Tax Vs. Lodhika, Rajkot, Gujarat-360021 Circle-1(1), Rajkot Pan : Aadcg6113A (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Prakash Jhunjhunwala & Shri K. K. Maloo, Ars. राज"व क" ओर से/Revenue By : Shri Shramdeep Sinha, Cit.Dr & Shri Abhimanyu Singh, Sr. Dr सुनवाई क" तार"ख /Date Of Hearing : 19/11/2025 घोषणा क" तार"ख /Date Of Pronouncement : 08/12/2025

reassessment of total income or loss of assessee." 2.1. We have also gone through the notice u/s 142(1) of the Act dated 29.11.2021 which is as follows: ITA Nos. 498 & 499/Rjt/2025 Gopal Snacks Pvt. Ltd. vs. ACIT 15 2.2. We further find the show cause notice issued that also reflects the date 28.03.2022 which is as follows

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 under Section 148 within the prescribed time limits. Further, Section 151 requires assessing officers to obtain sanction of the specified authority before issuing notice under Section 148. In Chhugamal Rajpal v. S P Chaliha, a three-Judge Bench of this Court held that Section 151 must be strictly adhered to because it contains "important safeguards." 65 Section 151 imposes

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 under Section 148 within the prescribed time limits. Further, Section 151 requires assessing officers to obtain sanction of the specified authority before issuing notice under Section 148. In Chhugamal Rajpal v. S P Chaliha, a three-Judge Bench of this Court held that Section 151 must be strictly adhered to because it contains "important safeguards." 65 Section 151 imposes

HETALKUMAR PRAVINCHANDRA RAJYAGURU,RAJKOT vs. PR. CIT, RAJKOT-1, RAJKOT, RAJKOT

24\n25\nITA No. 312, 322 to 329/Rjt/2024\nITA No. 331 & 335 & 371/Rjt/2024\nloose paper were unaccounted purchase and sales made by the assessee\nduring the year under consideration is not sufficient to claim these\nunaccounted receipts as business receipts. To claim the receipts as business\nreceipts the assessee should have explained entries appearing in the loose\npaper before

ASSTT. COMMR. OF INCOME TAX, CEN. CIR-1,, RAJKOT vs. RAJESHKUMAR GOVINDBHAI PATEL,, RAJKOT

In the result both the appeals filed by the Revenue and the Cross Objections filed by the assessee are hereby dismissed

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

24 ACIT vs. Shri Rajeshkumat G. Patel (iv) On 18th December, 2006, the stay order was vacated with liberty to the Revenue to issue a fresh notice and after considering the reply, pass an order under Section 142(2A). (v) On 19th January, 2007, an order under Section 142(2A) was passed (the special audit was to be completed within

ASSTT. COMMR. OF INCOME TAX, CEN. CIR-1,, RAJKOT vs. RAJESHKUMAR GOVINDBHAI PATEL,, RAJKOT

In the result both the appeals filed by the Revenue and the Cross Objections filed by the assessee are hereby dismissed

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

24 ACIT vs. Shri Rajeshkumat G. Patel (iv) On 18th December, 2006, the stay order was vacated with liberty to the Revenue to issue a fresh notice and after considering the reply, pass an order under Section 142(2A). (v) On 19th January, 2007, an order under Section 142(2A) was passed (the special audit was to be completed within

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

reassessment order itself, therefore we thought it appropriate to take up and decide this additional ground first. 24. For assessment year 2015–16, the assessee had already raised the above legal ground in the Memo of Appeal filed in Form 36 before the Bench, which reads as follows: “The Learned Commissioner of Income tax (Appeals)–11 Ahmedabad, erred in upholding

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

reassessment order itself, therefore we thought it appropriate to take up and decide this additional ground first. 24. For assessment year 2015–16, the assessee had already raised the above legal ground in the Memo of Appeal filed in Form 36 before the Bench, which reads as follows: “The Learned Commissioner of Income tax (Appeals)–11 Ahmedabad, erred in upholding

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

reassessment order itself, therefore we thought it appropriate to take up and decide this additional ground first. 24. For assessment year 2015–16, the assessee had already raised the above legal ground in the Memo of Appeal filed in Form 36 before the Bench, which reads as follows: “The Learned Commissioner of Income tax (Appeals)–11 Ahmedabad, erred in upholding