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

reassessment order itself, therefore we thought it appropriate to take up and decide this additional ground first. 24. For assessment year 2015–16, the assessee had already raised the above legal ground in the Memo of Appeal filed in Form 36 before the Bench, which reads as follows: “The Learned Commissioner of Income tax (Appeals)–11 Ahmedabad, erred in upholding

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

reassessment order itself, therefore we thought it appropriate to take up and decide this additional ground first. 24. For assessment year 2015–16, the assessee had already raised the above legal ground in the Memo of Appeal filed in Form 36 before the Bench, which reads as follows: “The Learned Commissioner of Income tax (Appeals)–11 Ahmedabad, erred in upholding

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

reassessment order itself, therefore we thought it appropriate to take up and decide this additional ground first. 24. For assessment year 2015–16, the assessee had already raised the above legal ground in the Memo of Appeal filed in Form 36 before the Bench, which reads as follows: “The Learned Commissioner of Income tax (Appeals)–11 Ahmedabad, erred in upholding

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

reassessment order itself, therefore we thought it appropriate to take up and decide this additional ground first. 24. For assessment year 2015–16, the assessee had already raised the above legal ground in the Memo of Appeal filed in Form 36 before the Bench, which reads as follows: “The Learned Commissioner of Income tax (Appeals)–11 Ahmedabad, erred in upholding

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

reassessment order itself, therefore we thought it appropriate to take up and decide this additional ground first. 24. For assessment year 2015–16, the assessee had already raised the above legal ground in the Memo of Appeal filed in Form 36 before the Bench, which reads as follows: “The Learned Commissioner of Income tax (Appeals)–11 Ahmedabad, erred in upholding

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

reassessment order itself, therefore we thought it appropriate to take up and decide this additional ground first. 24. For assessment year 2015–16, the assessee had already raised the above legal ground in the Memo of Appeal filed in Form 36 before the Bench, which reads as follows: “The Learned Commissioner of Income tax (Appeals)–11 Ahmedabad, erred in upholding

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

reassessment order itself, therefore we thought it appropriate to take up and decide this additional ground first. 24. For assessment year 2015–16, the assessee had already raised the above legal ground in the Memo of Appeal filed in Form 36 before the Bench, which reads as follows: “The Learned Commissioner of Income tax (Appeals)–11 Ahmedabad, erred in upholding

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

reassessment order itself, therefore we thought it appropriate to take up and decide this additional ground first. 24. For assessment year 2015–16, the assessee had already raised the above legal ground in the Memo of Appeal filed in Form 36 before the Bench, which reads as follows: “The Learned Commissioner of Income tax (Appeals)–11 Ahmedabad, erred in upholding

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

reassessment order itself, therefore we thought it appropriate to take up and decide this additional ground first. 24. For assessment year 2015–16, the assessee had already raised the above legal ground in the Memo of Appeal filed in Form 36 before the Bench, which reads as follows: “The Learned Commissioner of Income tax (Appeals)–11 Ahmedabad, erred in upholding

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

reassessment order itself, therefore we thought it appropriate to take up and decide this additional ground first. 24. For assessment year 2015–16, the assessee had already raised the above legal ground in the Memo of Appeal filed in Form 36 before the Bench, which reads as follows: “The Learned Commissioner of Income tax (Appeals)–11 Ahmedabad, erred in upholding

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

reassessment order itself, therefore we thought it appropriate to take up and decide this additional ground first. 24. For assessment year 2015–16, the assessee had already raised the above legal ground in the Memo of Appeal filed in Form 36 before the Bench, which reads as follows: “The Learned Commissioner of Income tax (Appeals)–11 Ahmedabad, erred in upholding

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

reassessment order itself, therefore we thought it appropriate to take up and decide this additional ground first. 24. For assessment year 2015–16, the assessee had already raised the above legal ground in the Memo of Appeal filed in Form 36 before the Bench, which reads as follows: “The Learned Commissioner of Income tax (Appeals)–11 Ahmedabad, erred in upholding

JIVANBHAI DE vs. HIBHAI SARLA,THANGADH, DIST. SURENDRANAGARVS.THE ITO WARD-2, SURENDRANAGAR, SURENDRANAGAR

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

reassessment, in paragraph no. 77, Hon'ble Apex Court referred to the provisions of TOLA wherein it is categorically observed that: "The test to determine whether Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 will apply to section 151 of the new regime is this : if the time limit of three years from

JIVANBHAI DE vs. HIBHAI SARLA,THANGADH, DIST. SURENDRANAGARVS.THE ITO WARD 2, SURENDRANAGAR, SURENDRANAGAR

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

reassessment, in paragraph no. 77, Hon'ble Apex Court referred to the provisions of TOLA wherein it is categorically observed that: "The test to determine whether Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 will apply to section 151 of the new regime is this : if the time limit of three years from

KISHAN BEEJ,JAMNAGAR vs. ITO WARD 2(1), JAMNAGAR

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.384/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2017-18 Kishan Beej Ito, Wared-2(1) बनाम Kashivishvanath Road Jamnagar – 361 001 Nr. P & T Office Vs. Jamnagar – 361 001 Pan : Aacfk 2114 P (अपीलाथ"/Appellant) (""यथ"/Respondent) :

67 ITR 11 (SC)]. Therefore, section 148 would point out to concrete information which could be facts which point out to a case of income having escaped assessment. Section 148A would only assist the Assessing Officer in coming to a conclusion whether such information is good enough to allow a notice to be issued under section 148. The new provisions

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

reassessment is passed pursuant to a search operation is a mandatory requirement of Section 153D of the Act and that such approval is not meant to be given mechanically. The Court also concurs with the finding of the ITAT that in the present cases such approval was granted mechanically without application of mind by the Additional CIT resulting in vitiating

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

reassessment is passed pursuant to a search operation is a mandatory requirement of Section 153D of the Act and that such approval is not meant to be given mechanically. The Court also concurs with the finding of the ITAT that in the present cases such approval was granted mechanically without application of mind by the Additional CIT resulting in vitiating

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

reassessment is passed pursuant to a search operation is a mandatory requirement of Section 153D of the Act and that such approval is not meant to be given mechanically. The Court also concurs with the finding of the ITAT that in the present cases such approval was granted mechanically without application of mind by the Additional CIT resulting in vitiating