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

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 & 2024 Classic Network Pvt. Ltd. (Group Case) issue notice u/s 148 of the Act, and if such approval is not signed, then consequences assessment proceedings, are invalid

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

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 & 2024 Classic Network Pvt. Ltd. (Group Case) issue notice u/s 148 of the Act, and if such approval is not signed, then consequences assessment proceedings, are invalid

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

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 & 2024 Classic Network Pvt. Ltd. (Group Case) issue notice u/s 148 of the Act, and if such approval is not signed, then consequences assessment proceedings, are invalid

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

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 & 2024 Classic Network Pvt. Ltd. (Group Case) issue notice u/s 148 of the Act, and if such approval is not signed, then consequences assessment proceedings, are invalid

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

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 & 2024 Classic Network Pvt. Ltd. (Group Case) issue notice u/s 148 of the Act, and if such approval is not signed, then consequences assessment proceedings, are invalid

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

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 & 2024 Classic Network Pvt. Ltd. (Group Case) issue notice u/s 148 of the Act, and if such approval is not signed, then consequences assessment proceedings, are invalid

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

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 & 2024 Classic Network Pvt. Ltd. (Group Case) issue notice u/s 148 of the Act, and if such approval is not signed, then consequences assessment proceedings, are invalid

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

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 & 2024 Classic Network Pvt. Ltd. (Group Case) issue notice u/s 148 of the Act, and if such approval is not signed, then consequences assessment proceedings, are invalid

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

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 & 2024 Classic Network Pvt. Ltd. (Group Case) issue notice u/s 148 of the Act, and if such approval is not signed, then consequences assessment proceedings, are invalid

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

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 & 2024 Classic Network Pvt. Ltd. (Group Case) issue notice u/s 148 of the Act, and if such approval is not signed, then consequences assessment proceedings, are invalid

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

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 & 2024 Classic Network Pvt. Ltd. (Group Case) issue notice u/s 148 of the Act, and if such approval is not signed, then consequences assessment proceedings, are invalid

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

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 & 2024 Classic Network Pvt. Ltd. (Group Case) issue notice u/s 148 of the Act, and if such approval is not signed, then consequences assessment proceedings, are invalid

THE ACIT-CENTRAL CIRCLE-2, RAJKOT vs. SHRI VICKY BALKRISHNA MEHTA, RAJKOT

The appeal of the Revenue is dismissed

Bench: Mrs. Annapurna Gupta & Shri Siddhartha Nautiyal"नधा"रणवष"/Assessment Year: 2004-05 Assistant Commissioner Of Vs. Shri Vicky Balkrishna Mehta, Income-Tax, 7Th Floor, Mansrovar Central Circle-2, Apartment, Royal Park, Rajkot Kalawad Road, Rajkot Pan : Agqpm 6495 B अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri D.M. Rindani, Ar Revenue By : Shri Shramdeep Sinha, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 28.11.2022 घोषणा क" तार"ख /Date Of Pronouncement: 22.02.2023 आदेश/O R D E R Per Annapurna Gupta: This Appeal Is Preferred By The Revenue Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)-13, Ahmedabad (Hereinafter Referred To As “Cit(A)”) Dated 22.01.2020 Passed U/S 250(6) Of The Income-Tax Act, 1961, (Hereinafter Referred To As “The Act”) For Assessment Year (Ay) 2004-05. 2. The Grounds Of Appeal Raised By The Revenue Read As Under:

72 ITR 595) held as under: "We considered that the language of the new section must be read as applicable only to those cases where the right of the ITO to reopen the assessment was not barred under the repealed section. In our view the new statute does not disclose in express terms or by necessary implication that there

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, by Finance Act, 2012, which extended limitation for initiation of reassessment proceedings to sixteen years, could not be resorted for reopening concluded proceedings in respect of which limitation had already expired/lapsed before amendment became effective – Held, yes – Whether thus, impugned reassessment notice and all consequent proceedings were to be quashed and set aside – Held, year [Paras

RAVICHANDRA V. MEHTA,,RAJKOT vs. ASSTT. COMMR. OF INCOME TAX, CEN. CIR.-2, , RAJKOT

In the result, appeals of the assessee are allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

section 149, by Finance Act, 2012, which extended limitation for initiation of reassessment proceedings to sixteen years, could not be resorted for reopening concluded proceedings in respect of which limitation had already expired/lapsed before amendment became effective – Held, yes – Whether thus, impugned reassessment notice and all consequent proceedings were to be quashed and set aside – Held, year [Paras

ASSTT. COMMR. OF INCOME TAX, CEN. CIR.-2, , RAJKOT vs. RAVICHANDRA V. MEHTA,, RAJKOT

In the result, appeals of the assessee are allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

section 149, by Finance Act, 2012, which extended limitation for initiation of reassessment proceedings to sixteen years, could not be resorted for reopening concluded proceedings in respect of which limitation had already expired/lapsed before amendment became effective – Held, yes – Whether thus, impugned reassessment notice and all consequent proceedings were to be quashed and set aside – Held, year [Paras

SEABIRD MARINE SERVICES PRIVATE LIMITED,JAMNAGAR vs. ACIT, CIRCLE - 1, JAMNAGAR, JAMANGAR

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 83/Rjt/2025 (निर्धारण वर्ष/Assessment Year: (2017-18) Seabird Marine Services Pvt. Vs. Ltd. Office No. 309 & 310, Centroid Luxuria, Nr. Crystal Mall, Khodiyar Colony, Aerodrome Road, Jamnagar 361006 Assistant Commissioner Of Income-Tax, Circle-1, Jamnagar, Aayakar Bhawan, Nr. Subhash Bridge, Jamnagar -Rajkot Highway, Jamnagar स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaccs 9869 C (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Appellant By : Shri S. N. Soparkar, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Cit-Dr Date Of Hearing : 30/04/2025 Date Of Pronouncement : 30/05/2025 Per Dr. A. L. Saini, Am: आदेश / Order Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2017-18, Is Directed Against The Order Passed By The National Faceless Appeal Centre (Nfac), Dehi/ Commissioner Of Income Tax (Appeal) [In Short 'Ld. Cit(A)'], Dated 02.01.2025, Which In Turn Arises Out Of An Assessment Order Passed By The Assessing Officer, Under Section 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”), Vide Order Dated 31.12.2019. 2. Grounds Of Appeal Raised By The Assessee Are As Follows: “All The Below Mentioned Grounds Of Appeal Are Independent & Without Prejudices To Each Other.

72 or section 73 or section 74 or sub-section (3) of section 74A or sub-section (3) of section 80J." 4. For deciding this issue, it is necessary for us to examine the object of introducing section 115J which can be easily deduced from the Budget Speech of the then Finance Minister of India made in the Parliament while

THE ACIT, MORBI CIRCLE,, RAJKOT-GUJARAT vs. M/S. VISHALDEEP SPINNING MILLA LTD.,, MUMBAI

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

reassessment was completed by making various disallowances and we are concerned only with the addition of carry forward of unabsorbed depreciation to the tune of Rs. 5,22,76,985/- belonging to the Assessment years 1996-97 to 1998- 99 which have been set off by the assessee beyond eight assessment years. 3.1. When the assessee challenged this issue before