KRUPALU METALS P. LTD.,JAMNAGAR vs. THE NFAC DELHI, DELHI

u/s 147 r.w.s. 148 of the Act, stated that entire re-assessment\nproceedings does not survive,as the assessee`s case was reopened on the basisof\ninformation received from the Central Goods & Service Tax, Rajkot. Therefore,\ninformation received from the office of Commissioner of Central Excise Rajkot,\nis not a tangible material, hence reassessment proceedings should be quashed

TAKDIR TRADERS,RAJKOT vs. THE PCIT-1, RAJKOT, RAJKOT

In the result, the appeal filed by the assessee is dismissed”

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

justice and since the twin conditions, namely, (i) the order of the Assessing Officer sought to be revised is erroneous; and (ii) it is prejudicial to the interests of the Revenue, are satisfied, the assessment order passed u/s. 147 rws 144B needs to be set aside for the discussion made above. Keeping in view these facts

TAKDIR TRADERS,RAJKOT vs. THE PCIT-1, RAJKOT, RAJKOT

In the result, the appeal filed by the assessee is dismissed”

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

justice and since the twin conditions, namely, (i) the order of the Assessing Officer sought to be revised is erroneous; and (ii) it is prejudicial to the interests of the Revenue, are satisfied, the assessment order passed u/s. 147 rws 144B needs to be set aside for the discussion made above. Keeping in view these facts

TAKDIR TRADERS,RAJKOT vs. THE PCIT-1, RAJKOT, RAJKOT

In the result, the appeal filed by the assessee is dismissed”

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

justice and since the twin conditions, namely, (i) the order of the Assessing Officer sought to be revised is erroneous; and (ii) it is prejudicial to the interests of the Revenue, are satisfied, the assessment order passed u/s. 147 rws 144B needs to be set aside for the discussion made above. Keeping in view these facts

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

natural justice, the objections raised by the assessee\nagainst initiation of proceedings u/s 148 of the Act, have been disposed of and\nthe images of original seized material pertaining to the assessee have been\nsupplied and discussed in the notices issued u/s 142(1) of the Act from time to\ntime.\n8. The assessing officer observed from the seized miracle

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. SHRI MUKESH MANEKCHAND SHETH, RAJKOT

natural justice, the objections raised by the assessee\nagainst initiation of proceedings u/s 148 of the Act, have been disposed of and\nthe images of original seized material pertaining to the assessee have been\nsupplied and discussed in the notices issued u/s 142(1) of the Act from time to\ntime.\n8. The assessing officer observed from the seized miracle

HANSA JITENDRA HARIA,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, the appeal of the assessee is dismissed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.104/Rjt/2024 ("नधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Hansa Jitendra Haria Vs. Principal Commissioner Of 2, Oswal Colony, Near Rajendra Income Tax Balkrindagan, Jamnagar, Gujarat Jamnagar 361005. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahph4309L (Assessee) (Respondent)

Reassessment Order subjected to revision is not erroneous or nor it is prejudicial to interest of the Revenue and hence, impugned Order dt. 05/01/2024 needs to be quashed, ITA No. 104/RJT/2024/AY.2013-14 Hansa Jitendra Haria vs. PCIT 3. The learned PCIT has erred in law and in fact in disregarding the specific inquiry on the shares GLOBAL SECUR undertaken

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

natural justice, the objections raised by the assessee\nagainst initiation of proceedings u/s 148 of the Act, have been disposed of and\nthe images of original seized material pertaining to the assessee have been\nsupplied and discussed in the notices issued u/s 142(1) of the Act from time to\ntime.\n8. The assessing officer observed from the seized miracle

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

natural justice, the objections raised by the assessee\nagainst initiation of proceedings u/s 148 of the Act, have been disposed of and\nthe images of original seized material pertaining to the assessee have been\nsupplied and discussed in the notices issued u/s 142(1) of the Act from time to\ntime.\n8. The assessing officer observed from the seized miracle

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

natural justice, the objections raised by the assessee\nagainst initiation of proceedings u/s 148 of the Act, have been disposed of and\nthe images of original seized material pertaining to the assessee have been\nsupplied and discussed in the notices issued u/s 142(1) of the Act from time to\ntime.\n8. The assessing officer observed from the seized miracle

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

natural justice, the objections raised by the assessee\nagainst initiation of proceedings u/s 148 of the Act, have been disposed of and\nthe images of original seized material pertaining to the assessee have been\nsupplied and discussed in the notices issued u/s 142(1) of the Act from time to\ntime.\n8. The assessing officer observed from the seized miracle

PARESHKUMAR NENSHIBHAI THAKKAR,RAJKOT vs. THE PCIT-1, RAJKOT, RAJKOT

Bench: Dr. Arjun Lal Saini, Am.- & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.381&382/Rjt/2024 "नधा"रणवष" / Assessment Year: (2013-14, 2015-16) (Hybrid Hearing) Pareshkumar Nenshibhai Thakkar Vs. Aayakar Bhavan, 6, Dharmendra Road, Race Course Ring Road, Rajkot-360001. Rajkot-360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abdt0333R (Appellant) (Respondent)

147 r.w.s. 1448 of the Income-tax Act, 1961 on 27.03.2022 hs set aside for fresh assessment only to the extent of the issues discussed supraand direct the Assessing Officer to pass a fresh Nationsment order after making necessary enquiries relating to cash transactions made by the assessee with M/s reational Shroff and if not found satisfactorily, appropriate addition under

PARESHKUMAR NENSHIBHAI THAKKAR,RAJKOT vs. THE PCIT- RAJKOT, RAJKOT

Bench: Dr. Arjun Lal Saini, Am.- & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.381&382/Rjt/2024 "नधा"रणवष" / Assessment Year: (2013-14, 2015-16) (Hybrid Hearing) Pareshkumar Nenshibhai Thakkar Vs. Aayakar Bhavan, 6, Dharmendra Road, Race Course Ring Road, Rajkot-360001. Rajkot-360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abdt0333R (Appellant) (Respondent)

147 r.w.s. 1448 of the Income-tax Act, 1961 on 27.03.2022 hs set aside for fresh assessment only to the extent of the issues discussed supraand direct the Assessing Officer to pass a fresh Nationsment order after making necessary enquiries relating to cash transactions made by the assessee with M/s reational Shroff and if not found satisfactorily, appropriate addition under

MANSUKHLAL KHIMJI KHIMASIYA,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

reassessment order. Therefore, during the assessment proceedings, the assessee was asked for various details/documents in respect of the transaction. All details/documents, such as, Contract Note for Purchase of shares, Broker Ledger (with broker details) from whom shares were purchased and Contract Note for Sale of shares etc. were filed before the assessing officer. 8. However, ld.PCIT rejected the above contention

BHANUBEN MANSUKHLAL KHIMASIYA,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

reassessment order. Therefore, during the assessment proceedings, the assessee was asked for various details/documents in respect of the transaction. All details/documents, such as, Contract Note for Purchase of shares, Broker Ledger (with broker details) from whom shares were purchased and Contract Note for Sale of shares etc. were filed before the assessing officer. 8. However, ld.PCIT rejected the above contention

JAYESH KHIMJI KHIMASIYA HUF,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

reassessment order. Therefore, during the assessment proceedings, the assessee was asked for various details/documents in respect of the transaction. All details/documents, such as, Contract Note for Purchase of shares, Broker Ledger (with broker details) from whom shares were purchased and Contract Note for Sale of shares etc. were filed before the assessing officer. 8. However, ld.PCIT rejected the above contention

MANSUKHLAL KHIMJI KHIMASIYA HUF,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

reassessment order. Therefore, during the assessment proceedings, the assessee was asked for various details/documents in respect of the transaction. All details/documents, such as, Contract Note for Purchase of shares, Broker Ledger (with broker details) from whom shares were purchased and Contract Note for Sale of shares etc. were filed before the assessing officer. 8. However, ld.PCIT rejected the above contention

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

u/s 147, which is bad in law." 22. Learned Counsel for the assessee, respectfully submitted that the aforesaid ground of appeal is purely legal in nature and does not require any fresh facts to be investigated, as it arises from the facts which are on record and goes to the root of the matter, therefore, above legal ground