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

9 A.Y. 2016-17 and 4 others 14. We have heard the rival contentions of both the parties and perused the materials available on record. The proceedings under section 147 of the Act are for benefit of the revenue and not for the assessee. The proceedings under section 147 of the Act cannot be allowed to be converted as 'revisional

SHRI MANISH GYANCHAND JAIN ,GANDHIDHAM vs. THEACIT, GANDHIDHAM CIRCLE, GANDHIDHAM

In the result the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

9 A.Y. 2016-17 and 4 others 14. We have heard the rival contentions of both the parties and perused the materials available on record. The proceedings under section 147 of the Act are for benefit of the revenue and not for the assessee. The proceedings under section 147 of the Act cannot be allowed to be converted as 'revisional

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

9 A.Y. 2016-17 and 4 others 14. We have heard the rival contentions of both the parties and perused the materials available on record. The proceedings under section 147 of the Act are for benefit of the revenue and not for the assessee. The proceedings under section 147 of the Act cannot be allowed to be converted as 'revisional

PRANAM ENTERPRISE,JUNAGADH vs. DCIT, CIRCLE-1(1), RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.391/Rjt/2024 Assessment Year: (2017-18) (Hybrid Hearing) Pranam Enterprise Vs. The Dcit Office No.3, City Centre, Opp. Circle-1(1), Rajkot New Collector Office, Junagadh – 362001, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaffp7926H (Assessee) (Respondent) Assessee By Shri Mehul Ranpura, Ar Respondent By Shri Abhimanyu Singh Yadav, Sr.Dr Date Of Hearing 18/12/2024 Date Of Pronouncement 06/03/2025 आदेश / O R D E R Per Dr. A. L. Saini, Am:

9), penalty at two hundred per cent, of tax payable on such income]. Penalty under sub Section (8) is independent of levy of penalty under sub Section (7) even if there is no under reported income. Under sub Section (1), the AO, Commissioner, Principal Commissioner or the Appellate Commissioner may direct that any person who has under-reported his income

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

9% of Rs.5,99,06,750). 7. Aggrieved by the order of the Ld.CIT(A), the assessee is in appeal before us. 8. Shri D. M. Rindani, Learned Counsel for the assessee, argued that during the re-assessment proceedings, the approval given by the Income Tax Authority, u/s 151 of the Act is unsigned, therefore, the reassessment order framed

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

9% of Rs.5,99,06,750). 7. Aggrieved by the order of the Ld.CIT(A), the assessee is in appeal before us. 8. Shri D. M. Rindani, Learned Counsel for the assessee, argued that during the re-assessment proceedings, the approval given by the Income Tax Authority, u/s 151 of the Act is unsigned, therefore, the reassessment order framed

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

9% of Rs.5,99,06,750). 7. Aggrieved by the order of the Ld.CIT(A), the assessee is in appeal before us. 8. Shri D. M. Rindani, Learned Counsel for the assessee, argued that during the re-assessment proceedings, the approval given by the Income Tax Authority, u/s 151 of the Act is unsigned, therefore, the reassessment order framed

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

9% of Rs.5,99,06,750). 7. Aggrieved by the order of the Ld.CIT(A), the assessee is in appeal before us. 8. Shri D. M. Rindani, Learned Counsel for the assessee, argued that during the re-assessment proceedings, the approval given by the Income Tax Authority, u/s 151 of the Act is unsigned, therefore, the reassessment order framed

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

9% of Rs.5,99,06,750). 7. Aggrieved by the order of the Ld.CIT(A), the assessee is in appeal before us. 8. Shri D. M. Rindani, Learned Counsel for the assessee, argued that during the re-assessment proceedings, the approval given by the Income Tax Authority, u/s 151 of the Act is unsigned, therefore, the reassessment order framed

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

9% of Rs.5,99,06,750). 7. Aggrieved by the order of the Ld.CIT(A), the assessee is in appeal before us. 8. Shri D. M. Rindani, Learned Counsel for the assessee, argued that during the re-assessment proceedings, the approval given by the Income Tax Authority, u/s 151 of the Act is unsigned, therefore, the reassessment order framed

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

9% of Rs.5,99,06,750). 7. Aggrieved by the order of the Ld.CIT(A), the assessee is in appeal before us. 8. Shri D. M. Rindani, Learned Counsel for the assessee, argued that during the re-assessment proceedings, the approval given by the Income Tax Authority, u/s 151 of the Act is unsigned, therefore, the reassessment order framed

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

9% of Rs.5,99,06,750). 7. Aggrieved by the order of the Ld.CIT(A), the assessee is in appeal before us. 8. Shri D. M. Rindani, Learned Counsel for the assessee, argued that during the re-assessment proceedings, the approval given by the Income Tax Authority, u/s 151 of the Act is unsigned, therefore, the reassessment order framed

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

9% of Rs.5,99,06,750). 7. Aggrieved by the order of the Ld.CIT(A), the assessee is in appeal before us. 8. Shri D. M. Rindani, Learned Counsel for the assessee, argued that during the re-assessment proceedings, the approval given by the Income Tax Authority, u/s 151 of the Act is unsigned, therefore, the reassessment order framed

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

9% of Rs.5,99,06,750). 7. Aggrieved by the order of the Ld.CIT(A), the assessee is in appeal before us. 8. Shri D. M. Rindani, Learned Counsel for the assessee, argued that during the re-assessment proceedings, the approval given by the Income Tax Authority, u/s 151 of the Act is unsigned, therefore, the reassessment order framed

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

9% of Rs.5,99,06,750). 7. Aggrieved by the order of the Ld.CIT(A), the assessee is in appeal before us. 8. Shri D. M. Rindani, Learned Counsel for the assessee, argued that during the re-assessment proceedings, the approval given by the Income Tax Authority, u/s 151 of the Act is unsigned, therefore, the reassessment order framed

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

9% of Rs.5,99,06,750). 7. Aggrieved by the order of the Ld.CIT(A), the assessee is in appeal before us. 8. Shri D. M. Rindani, Learned Counsel for the assessee, argued that during the re-assessment proceedings, the approval given by the Income Tax Authority, u/s 151 of the Act is unsigned, therefore, the reassessment order framed

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

9% of Rs.5,99,06,750). 7. Aggrieved by the order of the Ld.CIT(A), the assessee is in appeal before us. 8. Shri D. M. Rindani, Learned Counsel for the assessee, argued that during the re-assessment proceedings, the approval given by the Income Tax Authority, u/s 151 of the Act is unsigned, therefore, the reassessment order framed

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

9% of Rs.5,99,06,750). 7. Aggrieved by the order of the Ld.CIT(A), the assessee is in appeal before us. 8. Shri D. M. Rindani, Learned Counsel for the assessee, argued that during the re-assessment proceedings, the approval given by the Income Tax Authority, u/s 151 of the Act is unsigned, therefore, the reassessment order framed

SHRI GIRISHBHAI NANJIBHAI SOLANKI,RAJKOT vs. THE ITO, WARD-1 (1) (2), RAJKOT

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकरअपीलसं./Ita Nos. 31 & 32/Rjt/2020 िनधा"रणवष"/Asstt. Years:2011-12, 2012-13 िनधा"रणवष" िनधा"रणवष" िनधा"रणवष"

reassessment as the case may be. In case AO has not done so, the order framed under section 143(3) read with section 147 of the Act becomes invalid. ITA Nos.31,32 & 38to40/Rjt/2020 A.Y. 2010-11 to 2012-13 7 13. Now coming to second question whether the notice under section 143(2) issued beyond the statutory time limit provided