MANISH GYANCHAND JAIN,GANDHIDHAM vs. ASSTT. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE, , GANDHIDHAM

In the result the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

reassessment' cannot he reduced beyond the income originally assessed.' 14.9 In the light of above decision and after analyzing all the facts as discussed above, we find that the assessee is entitled to claim the deduction of the expenditures in respect of which the escaped income has sought to be assessed. The loss from the share trading activity has direct

MANISH GYANCHAND JAIN,GANDHIDHAM vs. ASSTT. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE, , GANDHIDHAM

In the result the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

reassessment' cannot he reduced beyond the income originally assessed.' 14.9 In the light of above decision and after analyzing all the facts as discussed above, we find that the assessee is entitled to claim the deduction of the expenditures in respect of which the escaped income has sought to be assessed. The loss from the share trading activity has direct

MANISH GYANCHAND JAIN,GANDHIDHAM vs. ASSTT. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE, , GANDHIDHAM

In the result the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

reassessment' cannot he reduced beyond the income originally assessed.' 14.9 In the light of above decision and after analyzing all the facts as discussed above, we find that the assessee is entitled to claim the deduction of the expenditures in respect of which the escaped income has sought to be assessed. The loss from the share trading activity has direct

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

70,74-80 50-57 9. After perusal of the aforesaid facts and the contentions of the Ld. AO vide the notice u/s 148A(b) of the Act and vide the order u/s 148A(d) of the Act, it is clearly discernible that, the Ld. AO has failed to apply his mind properly and has reopened the assessment

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

70,74-80 50-57 9. After perusal of the aforesaid facts and the contentions of the Ld. AO vide the notice u/s 148A(b) of the Act and vide the order u/s 148A(d) of the Act, it is clearly discernible that, the Ld. AO has failed to apply his mind properly and has reopened the assessment

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

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

section 148A(d) based on the available material and the reply of the assessee; and (iii) Issue a notice u/s 148 of the Act, under new regime, if it is a fit case for reassessment. The surviving time limit, as prescribed under the Income-tax Act read with TOLA, was available to the assessing officer to issue the reassessment notices

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

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

section 148A(d) based on the available material and the reply of the assessee; and (iii) Issue a notice u/s 148 of the Act, under new regime, if it is a fit case for reassessment. The surviving time limit, as prescribed under the Income-tax Act read with TOLA, was available to the assessing officer to issue the reassessment notices

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) :

70 Kishan Beej Vs. ITO 5 (SC).Therefore, the ld.DR contended that order of the assessing officer may be upheld. 9. We have heard both the parties and carefully gone through the submissions put forth on behalf of the assessee. First, we shall adjudicate ground no.2 raised by the assessee, challenging the reassessment proceedings under section

M/S. SHREEDHAR CONSTRUCTION ,JAMNAGAR vs. THE ITO WARD- 1 (3) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, is allowed

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 542/Rjt/2025 (Assessment Year: 2014-15) (Hybrid Hearing) M/S. Shreedhar Construction, The Ito, Vs. 211, Divyam Complex Airodrome Ward-1(3), Road,Jamnagar-361006 ( Gujarat) Jamnagar "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aclfs0395R (अपीलाथ"/Appellant) (""यथ"/Respondent)

reassessment proceedings initiated by the assessing officer and notice under section 148 of the Act, issued by the assessing officer, are bad in law. The assessee has also raised the technical ground before the learned CIT(A) that notice under section 148 of the Act is barred by limitation, therefore, assessment proceedings should be quashed. The assessee also raised

R K INFRALINK LLP,RAJKOT vs. ACIT, CC-1, RAJKOT, RAJKOT

In the result, ground No. 3 in Revenue`s appeal in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

70,755/- for the year under consideration invoking provisions of section 145(3) of the Act and after considering all the facts and submissions of the assessee. 8. Aggrieved by the order of the assessing officer, the assessee filed an appeal against the order of assessment dated 21.04.2023 before Ld. CIT(A). The Ld. CIT(A), vide order dated

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. RK INFRALINK LLP, RAJKOT

In the result, ground No. 3 in Revenue`s appeal in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

70,755/- for the year under consideration invoking provisions of section 145(3) of the Act and after considering all the facts and submissions of the assessee. 8. Aggrieved by the order of the assessing officer, the assessee filed an appeal against the order of assessment dated 21.04.2023 before Ld. CIT(A). The Ld. CIT(A), vide order dated

R K INFRALINK LLP,RAJKOT vs. ACIT, CC-1, RAJKOT, RAJKOT

In the result, ground No. 3 in Revenue`s appeal in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

70,755/- for the year under consideration invoking provisions of section 145(3) of the Act and after considering all the facts and submissions of the assessee. 8. Aggrieved by the order of the assessing officer, the assessee filed an appeal against the order of assessment dated 21.04.2023 before Ld. CIT(A). The Ld. CIT(A), vide order dated

R K INFRALINK LLP,RAJKOT vs. ACIT, CC-1, RAJKOT , RAJKOT

In the result, ground No. 3 in Revenue`s appeal in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

70,755/- for the year under consideration invoking provisions of section 145(3) of the Act and after considering all the facts and submissions of the assessee. 8. Aggrieved by the order of the assessing officer, the assessee filed an appeal against the order of assessment dated 21.04.2023 before Ld. CIT(A). The Ld. CIT(A), vide order dated

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. RK INFRALINK LLP, RAJKOT

In the result, ground No. 3 in Revenue`s appeal in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

70,755/- for the year under consideration invoking provisions of section 145(3) of the Act and after considering all the facts and submissions of the assessee. 8. Aggrieved by the order of the assessing officer, the assessee filed an appeal against the order of assessment dated 21.04.2023 before Ld. CIT(A). The Ld. CIT(A), vide order dated

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. RK INFRALINK LLP, RAJKOT

In the result, ground No. 3 in Revenue`s appeal in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

70,755/- for the year under consideration invoking provisions of section 145(3) of the Act and after considering all the facts and submissions of the assessee. 8. Aggrieved by the order of the assessing officer, the assessee filed an appeal against the order of assessment dated 21.04.2023 before Ld. CIT(A). The Ld. CIT(A), vide order dated

R K INFRALINK LLP,RAJKOT vs. ACIT, CC-1, RAJKOT, RAJOKT

In the result, ground No. 3 in Revenue`s appeal in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

70,755/- for the year under consideration invoking provisions of section 145(3) of the Act and after considering all the facts and submissions of the assessee. 8. Aggrieved by the order of the assessing officer, the assessee filed an appeal against the order of assessment dated 21.04.2023 before Ld. CIT(A). The Ld. CIT(A), vide order dated

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. RK INFRALINK LLP, RAJKOT

In the result, ground No. 3 in Revenue`s appeal in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

70,755/- for the year under consideration invoking provisions of section 145(3) of the Act and after considering all the facts and submissions of the assessee. 8. Aggrieved by the order of the assessing officer, the assessee filed an appeal against the order of assessment dated 21.04.2023 before Ld. CIT(A). The Ld. CIT(A), vide order dated

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

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 been

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

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 been