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

69C of the Act, vide approval under section 151 of the Act, for assessment year 2013–14, reproduced above in this order.Therefore, we note that provisions of section 151 of the Act is not an empty formality, it is a jurisdictional requirement for the assessing officer to exercise power to Page 16of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022

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

69C of the Act, vide approval under section 151 of the Act, for assessment year 2013–14, reproduced above in this order.Therefore, we note that provisions of section 151 of the Act is not an empty formality, it is a jurisdictional requirement for the assessing officer to exercise power to Page 16of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022

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

69C of the Act, vide approval under section 151 of the Act, for assessment year 2013–14, reproduced above in this order.Therefore, we note that provisions of section 151 of the Act is not an empty formality, it is a jurisdictional requirement for the assessing officer to exercise power to Page 16of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022

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

69C of the Act, vide approval under section 151 of the Act, for assessment year 2013–14, reproduced above in this order.Therefore, we note that provisions of section 151 of the Act is not an empty formality, it is a jurisdictional requirement for the assessing officer to exercise power to Page 16of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022

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

69C of the Act, vide approval under section 151 of the Act, for assessment year 2013–14, reproduced above in this order.Therefore, we note that provisions of section 151 of the Act is not an empty formality, it is a jurisdictional requirement for the assessing officer to exercise power to Page 16of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022

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

69C of the Act, vide approval under section 151 of the Act, for assessment year 2013–14, reproduced above in this order.Therefore, we note that provisions of section 151 of the Act is not an empty formality, it is a jurisdictional requirement for the assessing officer to exercise power to Page 16of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022

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

69C of the Act, vide approval under section 151 of the Act, for assessment year 2013–14, reproduced above in this order.Therefore, we note that provisions of section 151 of the Act is not an empty formality, it is a jurisdictional requirement for the assessing officer to exercise power to Page 16of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022

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

69C of the Act, vide approval under section 151 of the Act, for assessment year 2013–14, reproduced above in this order.Therefore, we note that provisions of section 151 of the Act is not an empty formality, it is a jurisdictional requirement for the assessing officer to exercise power to Page 16of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022

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

69C of the Act, vide approval under section 151 of the Act, for assessment year 2013–14, reproduced above in this order.Therefore, we note that provisions of section 151 of the Act is not an empty formality, it is a jurisdictional requirement for the assessing officer to exercise power to Page 16of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022

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

69C of the Act, vide approval under section 151 of the Act, for assessment year 2013–14, reproduced above in this order.Therefore, we note that provisions of section 151 of the Act is not an empty formality, it is a jurisdictional requirement for the assessing officer to exercise power to Page 16of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022

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

69C of the Act, vide approval under section 151 of the Act, for assessment year 2013–14, reproduced above in this order.Therefore, we note that provisions of section 151 of the Act is not an empty formality, it is a jurisdictional requirement for the assessing officer to exercise power to Page 16of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022

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

69C of the Act, vide approval under section 151 of the Act, for assessment year 2013–14, reproduced above in this order.Therefore, we note that provisions of section 151 of the Act is not an empty formality, it is a jurisdictional requirement for the assessing officer to exercise power to Page 16of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022

HETALKUMAR PRAVINCHANDRA RAJYAGURU,RAJKOT vs. PR. CIT, RAJKOT-1, RAJKOT, RAJKOT

sections": [ "69A", "115BBE", "263", "143(3)", "142(1)", "69B", "69C", "43B", "133(6)" ], "issues": "Whether the reassessment order passed by the PCIT

JAY PRABHUDAS VITHALANI,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, both the appeals of the same assessee (ITA No

69C r.w.s. of the Act.\n3.5 The above peculiarities of the purchases lead to conclusion that the\ntransaction of purchases are bogus and have remained unverified. The AO\nshould have verified such transactions in details particularly when the\ncore reason of selection of case for assessment is to verify the geniuses of\npurchases. However, it is seen that AO allowed

ILA JIGNESHKUMAR VAKHARIA,RAJKOT vs. THE INCOME TAX OFFICER, WARD 1(2)(1), RAJKOT

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Dr. Arjun Lal Saini, Am. & Dr. Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 599/Rjt/2025 "नधा"रणवष" / Assessment Year: (2014-15) (Hybrid Hearing) Ila Jignesh Kumar Vakharia, Vs. The Income Tax Officer, Ward Bagasra Road, At Derdi Kumbhaji, 1(2)(1), Derdi – Gondal - 364465 New Aayakar Bhawan, Vatiaka Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aqfpv0899R (Appellant) (Respondent) Appellant By : Shri Samir Bhuptani, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 01 / 12 /2025 Date Of Pronouncement : 20 / 01 /2026

reassess the income of the person in accordance with the provisions of section 153C of the Act. Section 153 starts with Non obstante clause that is Notwithstanding which overrides the other provisions mentioned after this word. The language used in these sections, i.e. 'notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section

H J ENTERPRISE,RAJKOT vs. ACIT, CIRCLE-1(1), RAJKOT, RAJKOT

In the result, the appeal of the assessee is partly allowed, in above terms

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

section 143(3) r.w.s. 147 of the Income Tax Act, 1961 (in short “the Act”), vide order dated 16.12.2016. 2. Grounds of appeal raised by the assessee are as follows (ITA No. 99/Rjt/2023- A.Y. 2015-16) : 1. The grounds of appeal mentioned hereunder are without prejudice to one another. 2. The Ld. Commissioner of Income-tax (Appeals), National Faceless Appeal

ALTAF AYOOBBHAI VEHVARIA,JAMNAGAR vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR, JAMNAGAR

In the result, assessee’s appeal ITA No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita Nos.26/Rjt/2025 िनधा"रणवष"/Assessment Year : 2021-22 Jabir Ayoob Vahevaria Principal Commissioner Of बनाम Plot No.3452 Gidc 3, Dared Income-Tax, Jamnagar, Jamnagar-361 004 ( Gujarat) Vs. Room No.101, 1St Floor, Aaykar Bhavan, Nr. Shubhas Bridge, Jamnagar-361 001 /. /. Pan/Gir No.:Aeqpv3027C "थायीलेखासं जीआइआरसं (अपीलाथ"/Appellant) .. (""यथ"/Respondent) आयकरअपीलसं/.Ita Nos.27/Rjt/2025 िनधा"रणवष"/Assessment Year : 2021-22 Altaf Ayoobbhai Vehvaria, Principal Commissioner Of बनाम Prop. Of K A Enterprise, Ground Income-Tax, Floor, Near Alamin Park, Vs. Jamnagar, Room No.101, 1St Vehwaria Madresa, Jamnagar- 361 004 Floor, Aaykar Bhavan, Nr. Shubhas Bridge, Jamnagar-361 001 /. /. Pan/Gir No.: Aempv7317M "थायीलेखासं जीआइआरसं (अपीलाथ"/Appellant) .. (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Cit- Dr

69C r.w.s. 155BBE of the Act. The ld.PCIT observed that assessing officer failed to conduct any verification or inquiry to ascertain the genuineness of these transactions, despite it being the primary reason for scrutiny selection. 6. Considering the above facts, the Ld. PCIT issued show -cause notice to the assessee, u/s 263 of the Act, dated 11.12.2024, which is reproduced

JABIR AYOOB VAHEVARIA,JAMNAGAR vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR, JAMNAGAR

In the result, assessee’s appeal ITA No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita Nos.26/Rjt/2025 िनधा"रणवष"/Assessment Year : 2021-22 Jabir Ayoob Vahevaria Principal Commissioner Of बनाम Plot No.3452 Gidc 3, Dared Income-Tax, Jamnagar, Jamnagar-361 004 ( Gujarat) Vs. Room No.101, 1St Floor, Aaykar Bhavan, Nr. Shubhas Bridge, Jamnagar-361 001 /. /. Pan/Gir No.:Aeqpv3027C "थायीलेखासं जीआइआरसं (अपीलाथ"/Appellant) .. (""यथ"/Respondent) आयकरअपीलसं/.Ita Nos.27/Rjt/2025 िनधा"रणवष"/Assessment Year : 2021-22 Altaf Ayoobbhai Vehvaria, Principal Commissioner Of बनाम Prop. Of K A Enterprise, Ground Income-Tax, Floor, Near Alamin Park, Vs. Jamnagar, Room No.101, 1St Vehwaria Madresa, Jamnagar- 361 004 Floor, Aaykar Bhavan, Nr. Shubhas Bridge, Jamnagar-361 001 /. /. Pan/Gir No.: Aempv7317M "थायीलेखासं जीआइआरसं (अपीलाथ"/Appellant) .. (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Cit- Dr

69C r.w.s. 155BBE of the Act. The ld.PCIT observed that assessing officer failed to conduct any verification or inquiry to ascertain the genuineness of these transactions, despite it being the primary reason for scrutiny selection. 6. Considering the above facts, the Ld. PCIT issued show -cause notice to the assessee, u/s 263 of the Act, dated 11.12.2024, which is reproduced