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

271A, 271B and 271F of the Act. 8. That, the Ld. AO has wrongly charged interest u/s 234A and 234B of the Act. 9. That, the findings of the Ld. AO are not justified and are bad-in-law. The appellant craves to add, amend, alter or delete any of the above grounds of appeal” Page

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:

271A(8) of the Act. 128- ITA.391/RJT/2024 – A.Y. 2017-18 Pranam Enterprise vs. DCIT 11. Section 270A provides for penalty for "under-reporting of income" [penalty at fifty per cent, of tax payable on such under-reported income, under sub Section (7)] and "misreporting of income" [under sub Section (8) and (9), penalty at two hundred per cent

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

reassessment proceedings under Section 147, leading to additions and penalty proceedings. The assessee's appeals to the CIT(A) resulted in partial relief. Subsequently, the matter reached the Income Tax Appellate Tribunal.", "held": "The Tribunal held that the notice issued under Section 148 for Assessment Year 2015-16 was time-barred and invalid as it was issued after the prescribed

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

reassessment order of assessing officer framed under section 147 r.w.s. 144B of the Act dated 27.05.2023, itself is quashed, therefore all other issues on merits of the additions, in the impugned assessment proceedings, are rendered academic and infructuous. 18. In the result, the appeal filed by the assessee, in ITA No.515/RJT/2025, for assessment year 2015-16, is allowed. 19. Since

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

reassessment order of assessing officer framed under section 147 r.w.s. 144B of the Act dated 27.05.2023, itself is quashed, therefore all other issues on merits of the additions, in the impugned assessment proceedings, are rendered academic and infructuous. 18. In the result, the appeal filed by the assessee, in ITA No.515/RJT/2025, for assessment year 2015-16, is allowed. 19. Since

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

reassessment order of assessing officer framed under section 147 r.w.s. 144B of the Act dated 27.05.2023, itself is quashed, therefore all other issues on merits of the additions, in the impugned assessment proceedings, are rendered academic and infructuous. 18. In the result, the appeal filed by the assessee, in ITA No.515/RJT/2025, for assessment year 2015-16, is allowed. 19. Since

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

reassessment order of assessing officer framed under section 147 r.w.s. 144B of the Act dated 27.05.2023, itself is quashed, therefore all other issues on merits of the additions, in the impugned assessment proceedings, are rendered academic and infructuous. 18. In the result, the appeal filed by the assessee, in ITA No.515/RJT/2025, for assessment year 2015-16, is allowed. 19. Since

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

reassessment order of assessing officer framed under section 147 r.w.s. 144B of the Act dated 27.05.2023, itself is quashed, therefore all other issues on merits of the additions, in the impugned assessment proceedings, are rendered academic and infructuous. 18. In the result, the appeal filed by the assessee, in ITA No.515/RJT/2025, for assessment year 2015-16, is allowed. 19. Since

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

reassessment order of assessing officer framed under section 147 r.w.s. 144B of the Act dated 27.05.2023, itself is quashed, therefore all other issues on merits of the additions, in the impugned assessment proceedings, are rendered academic and infructuous. 18. In the result, the appeal filed by the assessee, in ITA No.515/RJT/2025, for assessment year 2015-16, is allowed. 19. Since

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

reassessment order of assessing officer framed under section 147 r.w.s. 144B of the Act dated 27.05.2023, itself is quashed, therefore all other issues on merits of the additions, in the impugned assessment proceedings, are rendered academic and infructuous. 18. In the result, the appeal filed by the assessee, in ITA No.515/RJT/2025, for assessment year 2015-16, is allowed. 19. Since

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

reassessment order of assessing officer framed under section 147 r.w.s. 144B of the Act dated 27.05.2023, itself is quashed, therefore all other issues on merits of the additions, in the impugned assessment proceedings, are rendered academic and infructuous. 18. In the result, the appeal filed by the assessee, in ITA No.515/RJT/2025, for assessment year 2015-16, is allowed. 19. Since

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

reassessment order of assessing officer framed under section 147 r.w.s. 144B of the Act dated 27.05.2023, itself is quashed, therefore all other issues on merits of the additions, in the impugned assessment proceedings, are rendered academic and infructuous. 18. In the result, the appeal filed by the assessee, in ITA No.515/RJT/2025, for assessment year 2015-16, is allowed. 19. Since