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 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

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

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

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. 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

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

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

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

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

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

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"

39 & 40/Rjt/2020 िनधा"रणवष"/Asstt. Years:2010-11, 2011-12 & 2012-13 िनधा"रणवष" िनधा"रणवष" िनधा"रणवष" Chandresh Nanjibhai Bhayani Vs. ITO A-202, Shyamal Plaza, Nr. Raiya Ward-1(1)(2), Circle, Raiya Road, Rajkot Rajkot PAN: AGTPB2935N (Applicant) (Respondent) Assessee by : Shri Kalpesh Doshi, A.R. Revenue by : Shri B. D. Gupta, Sr. DR सुनवाईक"तारीख/Date

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"

39 & 40/Rjt/2020 िनधा"रणवष"/Asstt. Years:2010-11, 2011-12 & 2012-13 िनधा"रणवष" िनधा"रणवष" िनधा"रणवष" Chandresh Nanjibhai Bhayani Vs. ITO A-202, Shyamal Plaza, Nr. Raiya Ward-1(1)(2), Circle, Raiya Road, Rajkot Rajkot PAN: AGTPB2935N (Applicant) (Respondent) Assessee by : Shri Kalpesh Doshi, A.R. Revenue by : Shri B. D. Gupta, Sr. DR सुनवाईक"तारीख/Date

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

THE ACIT-CENTRAL CIRCLE-2, RAJKOT vs. SHRI VICKY BALKRISHNA MEHTA, RAJKOT

The appeal of the Revenue is dismissed

Bench: Mrs. Annapurna Gupta & Shri Siddhartha Nautiyal"नधा"रणवष"/Assessment Year: 2004-05 Assistant Commissioner Of Vs. Shri Vicky Balkrishna Mehta, Income-Tax, 7Th Floor, Mansrovar Central Circle-2, Apartment, Royal Park, Rajkot Kalawad Road, Rajkot Pan : Agqpm 6495 B अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri D.M. Rindani, Ar Revenue By : Shri Shramdeep Sinha, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 28.11.2022 घोषणा क" तार"ख /Date Of Pronouncement: 22.02.2023 आदेश/O R D E R Per Annapurna Gupta: This Appeal Is Preferred By The Revenue Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)-13, Ahmedabad (Hereinafter Referred To As “Cit(A)”) Dated 22.01.2020 Passed U/S 250(6) Of The Income-Tax Act, 1961, (Hereinafter Referred To As “The Act”) For Assessment Year (Ay) 2004-05. 2. The Grounds Of Appeal Raised By The Revenue Read As Under:

Section 149(1) was brought on the Statute by Finance Act, 2012 with effect from 01.07.2012 extending the limitation to 16 years in cases where the escaped income was on account of foreign assets. The learned CIT(A) noted that the proposition laid down by the Hon’ble Delhi High Court in the case of Braham Dutt (supra

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)

section 68 amounting to Rs. 90,39,290/- is duly justified, owing to the failure of the assessee to explain the nature and source of cash deposits; no violation of principles of natural justice has been established and no supporting documentary evidence has been submitted either at assessment, therefore findings of the assessing officer, was confirmed by the learned