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

reassessed or recomputed as loss than\nthe amount of tax will be calculated on the under reported\nincome as it was the total income.\nThis finding is w.r.t. disallowance of Rs.70,71,531/- of\npreliminary and pre operating expenses charge to revenue\nbefore date of assets put to use and dropping out penalty\nproceedings initiated under section 270(1

SEABIRD MARINE SERVICES PRIVATE LIMITED,JAMNAGAR vs. ACIT, CIRCLE - 1, JAMNAGAR, JAMANGAR

In the result, ground No.4 raised by the assessee is allowed

36,85,000 (Thirty Six Lakh Eighty Five Thousand) 6% Non-Cumulative, Non-\nConvertible, Redeemable fully paid up preference shares of Rs.100/- (Rupees Hundred)\neach held by Seabird Marine Services Privat Limited and having an aggregate paid up\nvalue of Rs.36,85,00,000/- (Rupees Thirty Six Crores Eight Five Lakhs); (“Proposed\nCapital Reduction”); and (b) NIL consideration being payable

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

1)(b) has been followed by taking\napproval from the specified authority. However, as submitted above, there is no\nmention of asset or expenditure represented by the alleged-escaped income and\nhence, the notice issued u/s. 148 of the Act is barred by the limitation period of\ntime prescribed u/s. 149 of the Act.In view of the above

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

1)(b) has been followed by taking\napproval from the specified authority. However, as submitted above, there is no\nmention of asset or expenditure represented by the alleged-escaped income and\nhence, the notice issued u/s. 148 of the Act is barred by the limitation period of\ntime prescribed u/s. 149 of the Act.In view of the above

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

1)(b) has been followed by taking\napproval from the specified authority. However, as submitted above, there is no\nmention of asset or expenditure represented by the alleged-escaped income and\nhence, the notice issued u/s. 148 of the Act is barred by the limitation period of\ntime prescribed u/s. 149 of the Act.In view of the above

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

1)(b) has been followed by taking\napproval from the specified authority. However, as submitted above, there is no\nmention of asset or expenditure represented by the alleged-escaped income and\nhence, the notice issued u/s. 148 of the Act is barred by the limitation period of\ntime prescribed u/s. 149 of the Act.In view of the above

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

1)(b) has been followed by taking\napproval from the specified authority. However, as submitted above, there is no\nmention of asset or expenditure represented by the alleged-escaped income and\nhence, the notice issued u/s. 148 of the Act is barred by the limitation period of\ntime prescribed u/s. 149 of the Act.In view of the above

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

1)(b) has been followed by taking\napproval from the specified authority. However, as submitted above, there is no\nmention of asset or expenditure represented by the alleged-escaped income and\nhence, the notice issued u/s. 148 of the Act is barred by the limitation period of\ntime prescribed u/s. 149 of the Act.In view of the above

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

vii). In respect ofITA No. 335/Rjt/2024,in the case of Dhruv Craft Mill\nPvt. Ltd\nThe ld. PCIT noticedthe contention of the assessee, in respect ofexcess stock\nof Rs.33,75,886/-, that the quantification of stock made by the Registered\nSurveyor on volume density basis, which is on estimate basis and cannot\ngive exact quantification of stock and hence

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)

vii) of Section 153 B from the time barring date i.e. 31.03.2014 is not in consonance with the provisions of law as in that case the proviso to Explanation would become redundant / non workable and thus the same would not be in accordance with the provisions of law as intended by the legislature. The relevancy/applicability of the said proviso

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)

vii) of Section 153 B from the time barring date i.e. 31.03.2014 is not in consonance with the provisions of law as in that case the proviso to Explanation would become redundant / non workable and thus the same would not be in accordance with the provisions of law as intended by the legislature. The relevancy/applicability of the said proviso

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ACIT, CENTRAL CIRL-1,, RAJKOT

In the result, appeals filed by the Revenue, in ITA No

Bench: Dr. Arjun Lal Saini & Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 134 & 135/Rjt/2023 (िनधा"रणवष" / Assessment Years: (2007-08 & 2008-09) Income Tax Officer, Ward- Shri Kherajmal Lekhrajbjai 5Th 1(2)(1), Aaykar Bhavan, Thavrani, 4- Parsana Nagar, Shri Vs. Floor, Room No. 517, Race Vaheguru Grupa, Near Refugee Course Ring Road, Rajkot-360 Colony, Rajkot-360 001 001 "थायी लेखा सं./जी आइ आर सं./Pan/Gir No.: Adrpt 5807 E (Appellant) (Respondent)

vii. In last decade, several decisions of ITATs in Gujarat, and Hon. High court of Gujarat can be found wherein the term Angadiya /shroff have been used interchangeably to cover the cases of unaccounted transactions of cash. Due to lack of clarity between these terms, several decisions of Ld. ITAT and Hon. HC have actually considered the activity of depositing

KRUPALU METALS P. LTD.,JAMNAGAR vs. THE NFAC DELHI, DELHI

vii) The assessee has not placed any evidence on record that this is job\nwork and not sale by way of submitting copy of ITR, P&L account,\nBalance Sheet, TDS return etc. of the parties with whom alleged\ntransactions made.\n(viii) On the basis of facts and circumstances, AO has correctly adopted\nthe figures of G.P of Rs.2

MAYURBHAI JAYSUKHLAL SHAH,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 319/Rjt/2024 (Assessment Year: 2013-14) (Hybrid Hearing) Mayurbhai Jaysukhlal Shah Vs. Principal Commissioner Of 601, Cross Way, P.N. Marg, Income Tax, Jamnagar Jamnagar, Gujarat-361001 Office Of The Principal Commissioner Of Income Tax.Pcit, Jamnagar "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afgps1754J (अपीलाथ"/Assessee) (""यथ"/Respondent)

reassessment proceedings initiated by the assessing officer is bad in law. It is borrowed satisfaction and the reasons of reopening as furnished by the assessing officer, contain lot of mistakes. The reasons recorded were not spell out the belief of the assessing officer that the Income of the assessee escaped assessment. For that Ld. Counsel relied on the various judgements

ATUL VRAJLAL KARIA,RAJKOT vs. AC / DC (INT.TXN), RAJKOT

In the result, appeal filed by the assessee is allowed in above terms

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.133/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2012-13 Atul Vrajlal Karia Ac/Dc (Int. Txn), बनाम C/O. D.S. Karia & Co. Ca, 203, Rajkot Cosmo Complex, Mahila College Vs. Chowk, Kalawad Road, Rajkot Pan : Adwpk6568J (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Kalpesh Doshi, Ld.Ar राज"व क" ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Sr-Dr

vii) The approval accorded u/s 151 of the Act is invalid, without application of mind and mechanical in nature. (viii) The provisions of section 147 has been wrongly applied as against the provisions of section 153C of the I.T. Act, 1961. 4. We note that most of the above additional legal grounds were already raised in Form no. 36 along

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ITO, WARD-1 (1) (2),, RAJKOT

36,628/-\n51,69,18,800/-\nVI\nBharat I Bhatia\n2012-13\n177,72,01,183/-\n53,31,60,355/-\n124,40,40,828/-\nVII Bharat I Bhatia\n2013-14\n58,46,25,710/-\n17,53,87,713\n40,92,37,997/-\nThe A.O. is directed to consider the income of the above-mentioned cases as determined above. Thus\nthe

THE INCOME TAX OFFICER-WARD-2,, JUNAGADH vs. SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,, JUNAGADH

36,628/- 51,69,18,800/-\nVI\nBharat I Bhatia\n2012-13\n177,72,01,183/- 53,31,60,355/- 124,40,40,828/-\nVII\nBharat I Bhatia\n2013-14\n58,46,25,710/- 17,53,87,713 40,92,37,997/-H\nThe A.O. is directed to consider the income of the above-mentioned cases as determined above. Thus

SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,,JUNAGADH vs. THE INCOME TAX OFFICER-WARD 1(2)(4),, RAJKOT

36,628/-\n51,69,18,800/-\nVI\nBharat I Bhatia\n2012-13\n177,72,01,183/-\n53,31,60,355/-\n124,40,40,828/-\nVII Bharat I Bhatia\n2013-14\n58,46,25,710/-\n17,53,87,713\n40,92,37,997/-\nThe A.O. is directed to consider the income of the above-mentioned cases as determined above. Thus

THE DY. COMMR. OF INCOME TAX, CEN. CIR.-1,, RAJKOT vs. BHARATKUMAR ISHWARBHAI BHATIYA,, RAJKOT

36,628/-\n51,69,18,800/-\nVI\nBharat I Bhatia\n2012-13\n177,72,01,183/-\n53,31,60,355/-\n124,40,40,828/-\nVII\nBharat I Bhatia\n2013-14\n58,46,25,710/-\n17,53,87,713\n40,92,37,997/-\nThe A.O. is directed to consider the income of the above-mentioned cases as determined above. Thus\nthe