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

MUKESH MANEKCHAND SHETH,RAJKOT vs. THE DCIT-ACIT, CENTRAL CIRCLE -2, RAJKOT., RAJKOT

90,00,000/- by way of set off of brought forward unabsorbed depreciation.\n[This is ground No.6 in ITA N0.546/Rjt/2024 A.Y.2018-19]\n4. Now we shall take above, summarised and concise ground of appeals, of\nassessee and revenue, as follows.\n5. The summarised and concise ground No.1, is reproduced below for ready\nreference.\n\"1.Ground No.1. The Ld.CIT(A) erred

MUKESH MANEKCHAND SHETH,RAJKOT vs. THE DCIT-ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

90,00,000/- by way of set off of brought forward unabsorbed depreciation.\n[This is ground No.6 in ITA N0.546/Rjt/2024 A.Y.2018-19]\n4. Now we shall take above, summarised and concise ground of appeals, of\nassessee and revenue, as follows.\n5. The summarised and concise ground No.1, is reproduced below for ready\nreference.\n“1.Ground No.1. The Ld.CIT(A) erred

MUKESH MANEKCHAND SHETH,RAJKOT vs. THE DCIT-ACIT, CENTRAL CIRCLE -2, RAJKOT, RAJKOT

90,00,000/- by way of set off of brought forward unabsorbed depreciation.\n[This is ground No.6 in ITA N0.546/Rjt/2024 A.Y.2018-19]\n4. Now we shall take above, summarised and concise ground of appeals, of\nassessee and revenue, as follows.\n5. The summarised and concise ground No.1, is reproduced below for ready\nreference.\n“1.Ground No.1. The Ld.CIT(A) erred

SHRI VIJAY JAMNADAS VINCHHI,JAMNAGAR vs. THE INCOME TAX OFFICER, WARD-2(5), JAMNAGAR

In the result, the appeal filed by the Assessee is hereby allowed

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

reassessment order passed under section 143(3) r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year (A.Y) 2010-11. I.T.A No. 309/Rjt/2019 A.Y. 2010-11 Page No 2 Shri Vijaybhai Jamnadas Vinchhi. vs. ITO 2. The Registry has noted that there is a delay of 58 days in filing

YESHA DHIRAJLAL THAKRAR,RAJKOT vs. THE DCIT, NFAC DELHI, DELHI

In the result, appeal of the assessee in ITA no

Bench: Ld. Cit(A) From Penalty Order Dated 29.01.2022 (Din: Itba/Pnl/F/271(1)(B)/2021-22/1039193062(1)) Passed By Ld. Assessing Officer,Nfac, Delhi(Hereinafter Called “The Ao”) U/S 271(1)(B) Of The 1961 Act Levying Penalty Of Rs. 30,000/- Against The Assesse For Non Compliance Of Three Notices Dated 27.07.2021, 06.08.2021 & 16.08.2021 Issued During Reassessment Proceedings , All Three Aforesaid Notices U/S 142(1) Of The 1961 Act. The Proceedings Were Conducted Before Division Bench Through E-Court Through Virtual Hearing Mode.

reassessment order dated 17.09.2021 passed by the AO u/s 147 read with Section 144 read with Section 144B of the 1961 Act(DIN ITBA/AST/S/147/2021-22/ 1035663980(1), wherein addition of Rs. 1,90

DCIT, CENTRAL CIRCLE 2, RAJKOT, RAJKOT vs. SHRI MUKESH MANEKCHAND SHETH, RAJKOT

90,00,000/- by way of set off of brought forward unabsorbed depreciation.\n[This is ground No.6 in ITA N0.546/Rjt/2024 A.Y.2018-19]\n4. Now we shall take above, summarised and concise ground of appeals, of\nassessee and revenue, as follows.\n5. The summarised and concise ground No.1, is reproduced below for ready\nreference.\n“1.Ground No.1. The Ld.CIT(A) erred

MUKESH MANEKCHAND SHETH,RAJKOT vs. THE DCIT-ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

90,00,000/- by way of set off of brought forward unabsorbed depreciation.\n[This is ground No.6 in ITA N0.546/Rjt/2024 A.Y.2018-19]\n4. Now we shall take above, summarised and concise ground of appeals, of\nassessee and revenue, as follows.\n5. The summarised and concise ground No.1, is reproduced below for ready\nreference.\n“1.Ground No.1. The Ld.CIT(A) erred

CHAMPUBHAI DESABHAI VALA,AMRELI vs. THE I.T.O., WARD 3(1)(4), AMRELI, AMRELI

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

reassessment proceedings under section 147 after receiving information about a cash deposit of Rs. 21,90,000/- made during FY 2012-13. The assessee

THE DCIT, CIRCLE-1 (1), , RAJKOT vs. M/S. DHRUV CRAFT MILL PVT. LTD., VILLAGE: - LILAPAR, TAL. & DIST. MORBI,

In the result, both the appeals filed by the Revenue are hereby dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

reassessment order passed under section 143 r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years 2014-15 & 2015-16. Since I.T.A Nos. 206 & 207/Rjt/2022 A.Ys. 2014-15 & 2015-16 Page No 2 DCIT Vs. M/s. Dhruv Craft Mill Pvt. Ltd. identical issue of bogus purchase is involved in both cases

THE DCIT, CIRCLE-1 (1), , RAJKOT vs. M/S. DHRUV CRAFT MILL PVT. LTD., VILLAGE: - LILAPAR, TAL. & DIST. MORBI,

In the result, both the appeals filed by the Revenue are hereby dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

reassessment order passed under section 143 r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years 2014-15 & 2015-16. Since I.T.A Nos. 206 & 207/Rjt/2022 A.Ys. 2014-15 & 2015-16 Page No 2 DCIT Vs. M/s. Dhruv Craft Mill Pvt. Ltd. identical issue of bogus purchase is involved in both cases

THE ITO, WARD-3(1)(1),, RAJKOT-GUJARAT vs. SHRI GIRISHKUMAR M. PURUSWANI,, RAJKOT-GUJARAT

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

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

reassessment was held to be invalid where reasons recorded stated that certain claim/transaction required verification. These decisions are also applicable to the case of the appellant in view of similarity of reasons recorded. > Gujarat High Court in case of Shankarlal Nagji & CO. - 322 ITR 90 > Bombay High Court in case of Nivi Trading Ltd. - 375 ITR 308 > Ahmedabad ITAT

THE ITO, WARD-3(1)(1),, RAJKOT-GUJARAT vs. SHRI GIRISHKUMAR M. PURUSWANI,, RAJKOT-GUJARAT

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

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

reassessment was held to be invalid where reasons recorded stated that certain claim/transaction required verification. These decisions are also applicable to the case of the appellant in view of similarity of reasons recorded. > Gujarat High Court in case of Shankarlal Nagji & CO. - 322 ITR 90 > Bombay High Court in case of Nivi Trading Ltd. - 375 ITR 308 > Ahmedabad ITAT

THE ITO, WARD-3(1)(1),, RAJKOT-GUJARAT vs. SHRI GIRISHKUMAR M. PURUSWANI,, RAJKOT-GUJARAT

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

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

reassessment was held to be invalid where reasons recorded stated that certain claim/transaction required verification. These decisions are also applicable to the case of the appellant in view of similarity of reasons recorded. > Gujarat High Court in case of Shankarlal Nagji & CO. - 322 ITR 90 > Bombay High Court in case of Nivi Trading Ltd. - 375 ITR 308 > Ahmedabad ITAT

SHRI SHAMJIBHAI SADHABHAI KANGAD,GANDHIDHAM-KUTCH vs. THE DCIT CENTRAL CIRCLE-1 , RAJKOT

reassessment shall be issued by the Assessing\nOfficer for the relevant assessment year or years unless\n(a) the Assessing Officer has in his possession books of account or other documents or\nevidence which reveal that the income, represented in the form of asset, which has\nescaped assessment amounts to or is likely to amount to fifty lakh rupees

ACCURATE BUILDCON,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

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

section 148 of the Act. Hence, there is no defect in the reassessment proceedings, therefore, we dismiss the ground raised by the assessee and confirm the findings of the learned CIT(A).” 10. Respectfully following the above findings in assessee’s own case, we dismiss the assessee’s appeals. 11. In the result, following grounds of appeal of assessee

ACCURATE BUILDCON ,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

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

section 148 of the Act. Hence, there is no defect in the reassessment proceedings, therefore, we dismiss the ground raised by the assessee and confirm the findings of the learned CIT(A).” 10. Respectfully following the above findings in assessee’s own case, we dismiss the assessee’s appeals. 11. In the result, following grounds of appeal of assessee