SHRI JAWAHIR RAVICHANDRA MEHTA,DUBAI(UAE) vs. THE DCIT, CIRCLE-2, RAJKOT, RAJKOT

In the result appeal of the assessee vide ITA/81/Rjt/2020 stands dismissed

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Amarjit Singh, Accountant Memebr

Section 149 (1) w.e.f. 01-07-2012 cannot give a fresh lease of life for reopening the same which has already become barred by limitation on 31.12.2012. ITA No. 81/Rjt/2020 & Ors. [Shri Jawahir R. Mehta & Ors.] - 36 - In view of the above, the Notice issued u/s.148 being beyond the limitation prescribed u/s.149 is bad in law and hence consequential assessment

MANSUKHBHAI KANJIBHAI SAKARIYA,RAJKOT vs. PRINCIPAL COMMISSIONER OF INCOME TAX, RAJKOT-1, RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita No.318/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2016-17 Mansukhbhai Kanjibhai Sakariya The Pr.Commissioner Of बनाम At Khajuri Gundala Income Tax-1, Rajkot. Post Station: Vavdi Vs. Amarnagar, Khajuri Gundala. Pan : Aslps 7027 E (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रतीक"ओरसे/Assessee By : Shri Rajendra Singhal, Ld.Ar राज"वक"ओरसे/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

reassessment order itself is not valid, therefore, subsequent order passed by the ld.Pr.CIT by exercising the revisionary jurisdiction is also bad in law. 6.The assessee also submitted before ld. PCIT that during the assessment proceedings, the assessing officer has conducted sufficient inquiry in respect of the issue raised by the ld. Pr. CIT. The assessee also submitted before the ld.Pr.CIT

ACIT, CIR-1(1), RAJKOT, RAJKOT vs. SHRI RAJKOT DISTRICT CO OPERATIVE BANK LTD, RAJKOT

The appeal of the revenue is dismissed

Bench: Dr. Arjun Lal Saini. & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.188/Rjt/2024 िनधा"रणवष"/ Assessment Year: (2015-16) (Hybrid Hearing) Assistant Commissioner Of Income- Vs. Rajkot District Co-Operative Bank Tax, Circle-1 (1), Rajkot Limited Room No.502, Aayakar Bhawan, Jilla Bankbhavan, Kasturba Road, Race Course Ring Road, Rajkot- Opp: Chaudhary High School, 360001 Rajkot 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaar0564K (Appellant) (Respondent) Appellant By : Shri D. M. Rindani, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld.Sr.Dr : 09/06 /2025 Date Of Hearing Date Of Pronouncement : 05/08 /2025

b) The assessee has somewhat arbitrarily allocated the expenses, not based on proportion but on some assumed weightage. In terms of salary, miscellaneous and other operating expenses, the assessee has claimed 41% as expenditure for short term loans, however, only 28% for long term Eligible Business. This again has been done without providing any cogent material proof and just

M/S. UNITED ENGINEERS, RAJKOT,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, RAJKOT, RAJKOT

In the result, the above appeals of the assessee are partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

41[Principal Commissioner or] Commissioner] in the course of any proceedings under this Act41a, is satisfied that any person— XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX 80[Explanation 5A.— Where, in the course of a search initiated under section 132 on or after the 1st day of June, 2007, the assessee is found to be the owner of— (i) any money, bullion, jewellery or other valuable

SHIV EXTRUSION,JAMNAGAR vs. INCOME TAX OFFICER, JAMNAGAR

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini, Am. & Dr. Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 646/Rjt/2025 "नधा"रणवष" / Assessment Year: (2016-17) (Hybrid Hearing) Shiv Extrusion Vs. Income Tax Officer Plot No.3978 Phase Iiiroad Income Tax Office, Ito Ward No.-R Dared, Jamnagar 2(10), Jamnagar, Income 361004, Gujarat, India, Jamnagar Tax Office, Shiv Smruti, Jamnagar, Jamnagar, Gujarat, 361008, Jamnagar "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abkfs7199F (Appellant) (Respondent) Appellant By : Shri Ramesh M. Patel, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 23/12/2025 Date Of Pronouncement : 12/03/2026

reassessment initiated under the extended period of limitation prescribed by Section 149(1)(b) despite the final assessed income falling below the mandatory threshold of Rupees fifty lakhs or more. -The AD relied on the entire alleged turnover of Rs. 1,17,14,220/- to invoke Section 149(1)(b). The NFAC itself conceded the settled legal position that only

M/S. IMPACT FORGING, ,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , RAJKOT

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

1. The existing provisions of making assessment and reassessment in cases where search has been conducted under section 132 or requisition is made under section 132A, does not provide for any approval for such assessment. 2. A new section 153D has been inserted to provide that no order of assessment or reassessment shall be passed by an Assessing Officer below

M/S. IMPACT FORGING, RAJKOT,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

1. The existing provisions of making assessment and reassessment in cases where search has been conducted under section 132 or requisition is made under section 132A, does not provide for any approval for such assessment. 2. A new section 153D has been inserted to provide that no order of assessment or reassessment shall be passed by an Assessing Officer below

M/S. IMPACT FORGING, ,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , RAJKOT

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

1. The existing provisions of making assessment and reassessment in cases where search has been conducted under section 132 or requisition is made under section 132A, does not provide for any approval for such assessment. 2. A new section 153D has been inserted to provide that no order of assessment or reassessment shall be passed by an Assessing Officer below

M/S. IMPACT FORGING, RAJKOT,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

1. The existing provisions of making assessment and reassessment in cases where search has been conducted under section 132 or requisition is made under section 132A, does not provide for any approval for such assessment. 2. A new section 153D has been inserted to provide that no order of assessment or reassessment shall be passed by an Assessing Officer below

M/S. IMPACT FORGING, ,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , RAJKOT

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

1. The existing provisions of making assessment and reassessment in cases where search has been conducted under section 132 or requisition is made under section 132A, does not provide for any approval for such assessment. 2. A new section 153D has been inserted to provide that no order of assessment or reassessment shall be passed by an Assessing Officer below

GOPAL SNACKS PVT LTD ,RAJKOT vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAJKOT

41,70,860/-\nfiled by the Assessee has been accepted as assessed income. At the same time the\nAssessing Officer has, while concluding, has stated that the assessment of income is\ndone as per computation sheet. A perusal of the Computation Sheet shows that the\nadjustment made while processing return of income under Section 143(1) of the Act\nhave

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)

reassess the total income of those six assessment years, and that the scheme of assessment or re-assessment of the total income of a person searched will be brought to naught if no addition is allowed to be made for those six assessment years in the absence of any seized incriminating material. 3. On the facts and in the circumstances

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)

reassess the total income of those six assessment years, and that the scheme of assessment or re-assessment of the total income of a person searched will be brought to naught if no addition is allowed to be made for those six assessment years in the absence of any seized incriminating material. 3. On the facts and in the circumstances

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

41,70,860/- filed by the Assessee has been accepted as assessed income. At the same time the Assessing Officer has, while concluding, has stated that the assessment of income is done as per computation sheet. A perusal of the Computation Sheet shows that the adjustment made while processing return of income under Section 143(1) of the Act have

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

b) For assessment year (AY) 2014-15, the assessing officer made an addition to tune of Rs.5,99,06,750/- on account of unexplained expenditure under section 69C of the Act and on account of profit chargeable to tax as per section 41(1) of the Act. Page 6of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network

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

b) For assessment year (AY) 2014-15, the assessing officer made an addition to tune of Rs.5,99,06,750/- on account of unexplained expenditure under section 69C of the Act and on account of profit chargeable to tax as per section 41(1) of the Act. Page 6of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network

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

b) For assessment year (AY) 2014-15, the assessing officer made an addition to tune of Rs.5,99,06,750/- on account of unexplained expenditure under section 69C of the Act and on account of profit chargeable to tax as per section 41(1) of the Act. Page 6of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network

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

b) For assessment year (AY) 2014-15, the assessing officer made an addition to tune of Rs.5,99,06,750/- on account of unexplained expenditure under section 69C of the Act and on account of profit chargeable to tax as per section 41(1) of the Act. Page 6of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network

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

b) For assessment year (AY) 2014-15, the assessing officer made an addition to tune of Rs.5,99,06,750/- on account of unexplained expenditure under section 69C of the Act and on account of profit chargeable to tax as per section 41(1) of the Act. Page 6of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network