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

section 147/148 of the Act, therefore, reassessment proceedings may be quashed. Page 23of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 35. The Ld. Counsel also submitted that the reopening of assessment was made for particular reasons, say, for X, however, ultimate addition was made on different footing, say, for Y, therefore, re-assessment

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

section 147/148 of the Act, therefore, reassessment proceedings may be quashed. Page 23of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 35. The Ld. Counsel also submitted that the reopening of assessment was made for particular reasons, say, for X, however, ultimate addition was made on different footing, say, for Y, therefore, re-assessment

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

section 147/148 of the Act, therefore, reassessment proceedings may be quashed. Page 23of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 35. The Ld. Counsel also submitted that the reopening of assessment was made for particular reasons, say, for X, however, ultimate addition was made on different footing, say, for Y, therefore, re-assessment

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

section 147/148 of the Act, therefore, reassessment proceedings may be quashed. Page 23of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 35. The Ld. Counsel also submitted that the reopening of assessment was made for particular reasons, say, for X, however, ultimate addition was made on different footing, say, for Y, therefore, re-assessment

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

section 147/148 of the Act, therefore, reassessment proceedings may be quashed. Page 23of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 35. The Ld. Counsel also submitted that the reopening of assessment was made for particular reasons, say, for X, however, ultimate addition was made on different footing, say, for Y, therefore, re-assessment

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

section 147/148 of the Act, therefore, reassessment proceedings may be quashed. Page 23of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 35. The Ld. Counsel also submitted that the reopening of assessment was made for particular reasons, say, for X, however, ultimate addition was made on different footing, say, for Y, therefore, re-assessment

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

section 147/148 of the Act, therefore, reassessment proceedings may be quashed. Page 23of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 35. The Ld. Counsel also submitted that the reopening of assessment was made for particular reasons, say, for X, however, ultimate addition was made on different footing, say, for Y, therefore, re-assessment

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

section 147/148 of the Act, therefore, reassessment proceedings may be quashed. Page 23of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 35. The Ld. Counsel also submitted that the reopening of assessment was made for particular reasons, say, for X, however, ultimate addition was made on different footing, say, for Y, therefore, re-assessment

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

section 147/148 of the Act, therefore, reassessment proceedings may be quashed. Page 23of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 35. The Ld. Counsel also submitted that the reopening of assessment was made for particular reasons, say, for X, however, ultimate addition was made on different footing, say, for Y, therefore, re-assessment

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

section 147/148 of the Act, therefore, reassessment proceedings may be quashed. Page 23of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 35. The Ld. Counsel also submitted that the reopening of assessment was made for particular reasons, say, for X, however, ultimate addition was made on different footing, say, for Y, therefore, re-assessment

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

section 147/148 of the Act, therefore, reassessment proceedings may be quashed. Page 23of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 35. The Ld. Counsel also submitted that the reopening of assessment was made for particular reasons, say, for X, however, ultimate addition was made on different footing, say, for Y, therefore, re-assessment

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

section 147/148 of the Act, therefore, reassessment proceedings may be quashed. Page 23of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 35. The Ld. Counsel also submitted that the reopening of assessment was made for particular reasons, say, for X, however, ultimate addition was made on different footing, say, for Y, therefore, re-assessment

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

37\nof this order). This means that while reopening the proceedings, assessing officer\nhad formed an opinion and a belief that, either search has been carried out in\nassessee's case or that assessee`s representative of any other search person (In\nthis case of RK Group). Thus, the very initiation of the reassessment\nproceedings is on a completely incorrect

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

37,77,313/-. The assessment was reopened by issue of notice under section 148 of the Act on 23.04.2021 and notice was deemed to be a notice issued under section 148A(b) as per the directions of the Hon'ble Supreme Court in the case Ashish Agrawal (supra). The AO issued a notice under section 148 dated 30.07.2022 after passing

KALPESH RAVJIBHAI SOJITRA,JASDAN vs. THE INCOME TAX OFFICER, WARD 2(1)(2), RAJKOT, RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrid Hearing) Kalpesh Ravjibhai Sojitra, Vs. The Ito, Prop. Sojitra Petrolium, Bypass Ward-2(1)(2), Circle Atkot Road, Jasdan, Rajkot 360050, Rajkot-( Guj) "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Bqmps8120G (/Appellant) (/Respondent)

reassessment or recomputation under Section 147 of the Act and inapplicable to the issuance of notice under Section 148 of the Act. The Scheme is clearly applicable for issuance of notice under Section 148 of the Act and accordingly, it is only the FAO which can issue the notice under Section

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

37\nof this order). This means that while reopening the proceedings, assessing officer\nhad formed an opinion and a belief that, either search has been carried out in\nassessee's case or that assessee`s representative of any other search person (In\nthis case of RK Group). Thus, the very initiation of the reassessment\nproceedings is on a completely incorrect

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

section 144B of the Act with reference to making assessment or 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

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

37\nof this order). This means that while reopening the proceedings, assessing officer\nhad formed an opinion and a belief that, either search has been carried out in\nassessee's case or that assessee`s representative of any other search person (In\nthis case of RK Group). Thus, the very initiation of the reassessment\nproceedings is on a completely incorrect