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

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

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

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

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

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

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 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

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

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

In the result, ground No.4 raised by the assessee is allowed

73 or section 74 or sub-section (3) of section 74A\nor sub-section (3) of section 80J.\"\n4. For deciding this issue, it is necessary for us to examine the object of introducing section\n115J which can be easily deduced from the Budget Speech of the then Finance Minister of India\nmade in the Parliament while introducing the said

ABDULKADAR HAJIAHMED VADIWALA,JAMNAGAR vs. PR. COMMISSIONER OF INCOME TAX, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.103/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2016-17 Abdulkadar Hajiahmed Vadiwala The Pr.Cit बनाम Maniar Street, Lindi Bazar Jamanagar. Jamnagar-361001 Vs. Pan : Aatpv 4729 Q (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

73. Section 151 imposes a check upon the power of the Revenue to reopen assessments. The provision imposes a responsibility on the Revenue to ensure that it obtains the sanction of the specified authority before issuing a notice under section 148. The purpose behind this procedural check is to save the assesses from harassment resulting from the mechanical reopening

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

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

reassessment notice 2) under section 148 has undergone a change by replacing the old procedure under sections 147 to 151 by new procedure under section 147 to 151 including the insertion provision of section 148A providing an opportunity of hearing to the petitioners in consonance with the decision of the Hon'ble Apex Court in case of GKN Driveshafts India

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

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

reassessment notice 2) under section 148 has undergone a change by replacing the old procedure under sections 147 to 151 by new procedure under section 147 to 151 including the insertion provision of section 148A providing an opportunity of hearing to the petitioners in consonance with the decision of the Hon'ble Apex Court in case of GKN Driveshafts India

JIGAR INDUSTRIES,JAMWADI vs. INCOME TAX OFFICER, RAJKOT

In the result, the assessee`s appeal is allowed

73,96,200/-without invoice. Further, the assessee have filed an appeal before\ncustoms, excise and service tax appellate tribunal against the impugned demand\nof excise duty which is pending for hearing. Therefore, the matter is under sub-\judice and not finalized. Hence the proposed addition cannot be made till the\ndecision of CESTAT-Ahmedbad.\n6. However, the Assessing Officer

DILIP DAYABHAI DHORIYANI,MORBI vs. INCOME TAX OFFICER WARD 1, MORBI, MORBI

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.401/Rjt/2025 "नधा"रण वष"/ Assessment Year: (2017-18) Dilip Dayabhai Dhoriyani, Income Tax Officer, Prop. Of Sairam Enterprise, Ceramic बनाम/ Ward-1, Morbi Plaza Shop No.0808 A National Income Tax Office, Morvi- 363 Vs. Highway, Trajpur, Morbi-363 642 642(Gujarat) "थायीलेखासं जीआइआरसं /. /. Pan/Gir No Asxpd1808J (अपीलाथ"/Appellant) (""यथ"/Respondent) .. "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ld. Ar राज"व क" ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr सुनवाई क" तार"ख /Date Of Hearing : 06/08/2025 घोषणा क" तार"ख /Date Of Pronouncement : 09/10/2025 आदेश/Order Per Dr. Arjun Lal Saini, A.M:

section 147/148 of the Act is bad in law, hence, reassessment proceeding should be quashed. 11. The Ld. Counsel for the assessee also on third technical issue submitted that amount escaped for assessment, as per assessing officer, is Rs.21,73