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

43(1) of the Act. The dropping of penalty in respect of amortization\nexpenses has resulted into loss to the revenue as the amount of penalty would\nhave positive revenue impact as per the provisions of Section 270A(10b) of the\nAct, which states that where the total income determined under clause (a) of\nsub-section (1) of section

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)

5 Kalpesh Ravjibhai Sojitra Mandatory and Overrides Manual Jurisdiction. The Revenue's entire edifice rests on the incorrect presumption that the Jurisdictional Assessing Officer ("JAO") and Faceless Assessing Officer ("FAO") enjoy concurrent jurisdiction. This is contrary to the express framework of Section 144B of the Act, and the Faceless Assessment/Reassessment Scheme, 2022, and binding judicial precedents on the subject

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

43) premises were covered,out of which 32 premises were\ncovered under section 132 of the Income Tax Act 1961 and the other 11 premises\nwere covered u/s 133A of the Income Tax Act 1961. The premises covered were\na mix of residential and business premises of their related entities, their family\nmembers, key associates and employees. The RK Group

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

43. Hence, from the above analysis, we find that there is no whisper in the reasons recorded, of any tangible material which came to the possession of Page 28of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) the assessing officer. It reflects an arbitrary exercise of the power conferred under section 147/148

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

43. Hence, from the above analysis, we find that there is no whisper in the reasons recorded, of any tangible material which came to the possession of Page 28of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) the assessing officer. It reflects an arbitrary exercise of the power conferred under section 147/148

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

43. Hence, from the above analysis, we find that there is no whisper in the reasons recorded, of any tangible material which came to the possession of Page 28of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) the assessing officer. It reflects an arbitrary exercise of the power conferred under section 147/148

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

43. Hence, from the above analysis, we find that there is no whisper in the reasons recorded, of any tangible material which came to the possession of Page 28of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) the assessing officer. It reflects an arbitrary exercise of the power conferred under section 147/148

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

43. Hence, from the above analysis, we find that there is no whisper in the reasons recorded, of any tangible material which came to the possession of Page 28of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) the assessing officer. It reflects an arbitrary exercise of the power conferred under section 147/148

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

43. Hence, from the above analysis, we find that there is no whisper in the reasons recorded, of any tangible material which came to the possession of Page 28of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) the assessing officer. It reflects an arbitrary exercise of the power conferred under section 147/148

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

43. Hence, from the above analysis, we find that there is no whisper in the reasons recorded, of any tangible material which came to the possession of Page 28of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) the assessing officer. It reflects an arbitrary exercise of the power conferred under section 147/148

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

43. Hence, from the above analysis, we find that there is no whisper in the reasons recorded, of any tangible material which came to the possession of Page 28of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) the assessing officer. It reflects an arbitrary exercise of the power conferred under section 147/148

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

43. Hence, from the above analysis, we find that there is no whisper in the reasons recorded, of any tangible material which came to the possession of Page 28of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) the assessing officer. It reflects an arbitrary exercise of the power conferred under section 147/148

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

43. Hence, from the above analysis, we find that there is no whisper in the reasons recorded, of any tangible material which came to the possession of Page 28of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) the assessing officer. It reflects an arbitrary exercise of the power conferred under section 147/148

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

43. Hence, from the above analysis, we find that there is no whisper in the reasons recorded, of any tangible material which came to the possession of Page 28of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) the assessing officer. It reflects an arbitrary exercise of the power conferred under section 147/148

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

43. Hence, from the above analysis, we find that there is no whisper in the reasons recorded, of any tangible material which came to the possession of Page 28of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) the assessing officer. It reflects an arbitrary exercise of the power conferred under section 147/148

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

43. Hence, from the above analysis, we find that there is no whisper in the reasons recorded, of any tangible material which came to the possession of Page 28of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) the assessing officer. It reflects an arbitrary exercise of the power conferred under section 147/148

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

43. Hence, from the above analysis, we find that there is no whisper in the reasons recorded, of any tangible material which came to the possession of Page 28of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) the assessing officer. It reflects an arbitrary exercise of the power conferred under section 147/148

M/S. KANDLA ENERGY AND CHEMICALS LTD.,VILLAGE DEVALIYA, TAL. ANJAR(KUTCH) vs. ADD. CIT, GANDHIDHAM RANGE,, GANDHIDHAM(KUTCH)

In the result, the appeal filed by the Assessee is hereby dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

43,24,000/-. During the assessment proceedings, it was noticed that the assessee company had entered into certain specified domestic transactions whose value exceeded Rs. 5 Crores with related party u/s. 40A(2)(b) of the Act and also Chartered Accountant’s report u/s. 92E of the Act on international/domestic transactions. Therefore the case was referred to Transfer Pricing Officer

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

5.O. 1466(1). In exercise of the powers conferred by sub-sections (1) and (2) of section 151A of the Income-tax Act, 1961 (43 of 1961), the Central Government hereby makes the following Scheme, namely 1. Short title and commencement (1) This Scheme may be called the e-Assessment of Income Escaping Assessment Scheme, 2022. (2) It shall