BHANUBEN MANSUKHLAL KHIMASIYA,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

section 263 of the I.T. Act 1961. Therefore, I intend to revise the order of the assessing officer passed u/s 147 of the I.T. Act dated 07/05/21 for the AY 2012-13. 6. Under the circumstances, you are requested to show cause as to why the order dated 07/05/21 should not be revised u/s 263 of the Income

MANSUKHLAL KHIMJI KHIMASIYA HUF,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

section 263 of the I.T. Act 1961. Therefore, I intend to revise the order of the assessing officer passed u/s 147 of the I.T. Act dated 07/05/21 for the AY 2012-13. 6. Under the circumstances, you are requested to show cause as to why the order dated 07/05/21 should not be revised u/s 263 of the Income

HANSA JITENDRA HARIA,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, the appeal of the assessee is dismissed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.104/Rjt/2024 ("नधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Hansa Jitendra Haria Vs. Principal Commissioner Of 2, Oswal Colony, Near Rajendra Income Tax Balkrindagan, Jamnagar, Gujarat Jamnagar 361005. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahph4309L (Assessee) (Respondent)

Section 263 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’), dated 05.01.2024 for the Assessment Year (in short ‘A.Y.’) 2013-14. 2. The grounds of appeal raised by the assessee are as follows: “1. The grounds of appeal are without prejudice to each other. 2. On the facts and circumstances of the case

BABUBHAI KANJIBHAI SAKARIYA LEGAL HEIR OF LATE SMT. UJIBEN KANJIBHAI SAKARIYA,JETPUR vs. ITO WARD 1(2)(1), RAJKOT, RAJKOT

In the result, the appeal filed by the assessee is allowed

reassessment order framed by the\nassessing officer under section 147 of the Act, dated 15.03.2022, should be\nquashed.\n15. We note that assessee had intimated to the Revenue Authorities by way of\nletter dated 24.11.2021, about the death of the assessee, the said letter of the\nassessee is placed in the Paper Book of the assessee. We note that

M/S. GREEN EARTH BIOGAS PVT. LTD.,SURENDRANAGAR vs. THE PR. CIT-3, AHMEDABAD, AHMEDABAD

In the result, appeal filed by the assessee is dismissed

section or assessed, reassessed or recomputed in a preceding\norder is loss, the amount of tax calculated on the under-reported income as if it\nwere the total income. Hence, non-levy of penalty is an error which is also\nprejudicial to the interest of revenue. Therefore, Show- Cause Notice for\ninitiation of proceedings u/s 263

TAKDIR TRADERS,RAJKOT vs. THE PCIT-1, RAJKOT, RAJKOT

In the result, the appeal filed by the assessee is dismissed”

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

263 of the Act such order is erroneous in so far as it is prejudicial to the interest of revenue. Takdir Trader v. PCIT 8. The assessee replied that the observation made by the Ld.PCIT is not correct at all, because of the fact that the Faceless Unit in the course of reassessment proceeding issued Notice

TAKDIR TRADERS,RAJKOT vs. THE PCIT-1, RAJKOT, RAJKOT

In the result, the appeal filed by the assessee is dismissed”

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

263 of the Act such order is erroneous in so far as it is prejudicial to the interest of revenue. Takdir Trader v. PCIT 8. The assessee replied that the observation made by the Ld.PCIT is not correct at all, because of the fact that the Faceless Unit in the course of reassessment proceeding issued Notice

TAKDIR TRADERS,RAJKOT vs. THE PCIT-1, RAJKOT, RAJKOT

In the result, the appeal filed by the assessee is dismissed”

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

263 of the Act such order is erroneous in so far as it is prejudicial to the interest of revenue. Takdir Trader v. PCIT 8. The assessee replied that the observation made by the Ld.PCIT is not correct at all, because of the fact that the Faceless Unit in the course of reassessment proceeding issued Notice

M/S PANCHNATH ENTERPRISE,,RAJKOT-GUJARAT vs. THE PR. COMMR. OF INCOME TAX-1,, RAJKOT-GUJARAT

Appeals are allowed

Section 263 show cause notice dated 07.10.2015 proposing to revise the above re-assessment for the following reasons: “3. During the assessment proceedings, the AO, vide notice u/s.142(1) of the Act dated 08/08/2013 had called for explanation for cash deposited in Bank ITA Nos. 139 to 141/Rjt/16 [M/s. Panchnath Enterprise vs. Pr.CIT

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

sections": [ "69A", "115BBE", "263", "143(3)", "142(1)", "69B", "69C", "43B", "133(6)" ], "issues": "Whether the reassessment order passed by the PCIT

JABIR AYOOB VAHEVARIA,JAMNAGAR vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR, JAMNAGAR

In the result, assessee’s appeal ITA No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita Nos.26/Rjt/2025 िनधा"रणवष"/Assessment Year : 2021-22 Jabir Ayoob Vahevaria Principal Commissioner Of बनाम Plot No.3452 Gidc 3, Dared Income-Tax, Jamnagar, Jamnagar-361 004 ( Gujarat) Vs. Room No.101, 1St Floor, Aaykar Bhavan, Nr. Shubhas Bridge, Jamnagar-361 001 /. /. Pan/Gir No.:Aeqpv3027C "थायीलेखासं जीआइआरसं (अपीलाथ"/Appellant) .. (""यथ"/Respondent) आयकरअपीलसं/.Ita Nos.27/Rjt/2025 िनधा"रणवष"/Assessment Year : 2021-22 Altaf Ayoobbhai Vehvaria, Principal Commissioner Of बनाम Prop. Of K A Enterprise, Ground Income-Tax, Floor, Near Alamin Park, Vs. Jamnagar, Room No.101, 1St Vehwaria Madresa, Jamnagar- 361 004 Floor, Aaykar Bhavan, Nr. Shubhas Bridge, Jamnagar-361 001 /. /. Pan/Gir No.: Aempv7317M "थायीलेखासं जीआइआरसं (अपीलाथ"/Appellant) .. (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Cit- Dr

section 263 of the Act. Therefore, ld.PCIT set -aside the assessment order passed under section143(3) r.w.s 144B of the Act, dated 23/12/2022 for A.Y. 2021-22 to the extent of the issues mentioned and discussed above and directed the assessing officer to conduct detailed verification of the purchases from eleven entities flagged as suspicious and reassess

ALTAF AYOOBBHAI VEHVARIA,JAMNAGAR vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR, JAMNAGAR

In the result, assessee’s appeal ITA No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita Nos.26/Rjt/2025 िनधा"रणवष"/Assessment Year : 2021-22 Jabir Ayoob Vahevaria Principal Commissioner Of बनाम Plot No.3452 Gidc 3, Dared Income-Tax, Jamnagar, Jamnagar-361 004 ( Gujarat) Vs. Room No.101, 1St Floor, Aaykar Bhavan, Nr. Shubhas Bridge, Jamnagar-361 001 /. /. Pan/Gir No.:Aeqpv3027C "थायीलेखासं जीआइआरसं (अपीलाथ"/Appellant) .. (""यथ"/Respondent) आयकरअपीलसं/.Ita Nos.27/Rjt/2025 िनधा"रणवष"/Assessment Year : 2021-22 Altaf Ayoobbhai Vehvaria, Principal Commissioner Of बनाम Prop. Of K A Enterprise, Ground Income-Tax, Floor, Near Alamin Park, Vs. Jamnagar, Room No.101, 1St Vehwaria Madresa, Jamnagar- 361 004 Floor, Aaykar Bhavan, Nr. Shubhas Bridge, Jamnagar-361 001 /. /. Pan/Gir No.: Aempv7317M "थायीलेखासं जीआइआरसं (अपीलाथ"/Appellant) .. (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Cit- Dr

section 263 of the Act. Therefore, ld.PCIT set -aside the assessment order passed under section143(3) r.w.s 144B of the Act, dated 23/12/2022 for A.Y. 2021-22 to the extent of the issues mentioned and discussed above and directed the assessing officer to conduct detailed verification of the purchases from eleven entities flagged as suspicious and reassess

ABDULKADAR HAJIAHMED VADIWALA,JAMNAGAR vs. PR. COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, appeal filed by the assessee, is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.103/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2016-17 Abdulkadar Hajiahmed Vadiwala The Pr.Cit बनाम Maniar Street, Lindi Bazar Jamanagar. Jamnagar-361001 Vs. Pan : Aatpv 4729 Q (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

reassessment notice. 80. In Ashish Agarwal (supra), this Court directed that Section 148 notices which were challenged before various High Courts "shall be deemed to have been issued under Section 148-A of the Income Tax Act as substituted by the Finance Act, 2021 and construed or treated to be show-cause notices in terms of Section

SHRI MANOJ B. MANSUKHANI,,RAJKOT-GUJARAT vs. THE PR. COMMISSIONER OF INCOME TAX-1, , RAJKOT

In the result, the appeal of the assessee is allowed

section 14A of the IT Act, 1961, Such cases where the assessment has been completed without conducting any inquiries tantamount to erroneous orders as also order prejudicial to the interest of Revenue. For such proposition of law. Reliance is made on following cases: 1. Rampyari Devi Sarogi Vs. CIT (SC) 67 ITR 84 2. Malabar Industrial

NILESH BIPINCHANDRA MEHTA HUF,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, the appeal filed by the assessee is allowed

section 263 of the\nAct, may be quashed.\n10.\nOn the other hand, Ld. CIT- DR for the Revenue supported the order of\nLd.PCIT and submitted that reassessment

SHRI PARESHKUMAR NARSHIBHAI SIROYA,DHORAJI, DIST. RAJKOT vs. THE PR. CIT-1, RAJKOT, RAJKOT

In the result, the appeal filed by the assessee is dismissed

section 263 of I.T. Act, that the order passed by the assessing\nofficer is erroneous and prejudicial to the interest of revenue. The ld. PCIT\nobserved that above facts indicate that assessing officer has not conducted any\ninquiries/ verification in respect of cash and cheque deposits in his bank\naccounts claimed to be belonging to the third parties

M/S. SIMERO VITRIFIED P. LTD. ,MORBI vs. THE PR. CIT-3 , RAJKOT

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

section 115JB of IT Act, 1961.\n2. Thereafter, Pr. Commissioner of Income Tax-3, Rajkot found some discrepancies in passed assessment and on the basis of their judgement, order for revision u/s 263 was passed on 13.09.2016 and AO was directed to re-assess the income of the assessee depicting the following issues:\n(a) Share Capital introduced during

SHREE MEENAWALA CASTING,RAJKOT vs. THE PCIT, RAJKOT-1, RAJKOT, RAJKTO

In the result, the appeal of the assessee is allowed

263 or section 264 is to be given by the Assessing Officer [or the Transfer Pricing Officer, as the case may be,] wholly or partly, otherwise than by making a fresh assessment or reassessment