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

reopening the assessment proceedings, for assessment year 2015–16 and for assessment year 2016-17. We, therefore, quash the reassessment proceedings. As the reassessment itself is quashed, all other issues on merits of the additions, and other technical arguments of ld. Counsel for Page 32 of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case

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

reopening the assessment proceedings, for assessment year 2015–16 and for assessment year 2016-17. We, therefore, quash the reassessment proceedings. As the reassessment itself is quashed, all other issues on merits of the additions, and other technical arguments of ld. Counsel for Page 32 of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case

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

reopening the assessment proceedings, for assessment year 2015–16 and for assessment year 2016-17. We, therefore, quash the reassessment proceedings. As the reassessment itself is quashed, all other issues on merits of the additions, and other technical arguments of ld. Counsel for Page 32 of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case

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

reopening the assessment proceedings, for assessment year 2015–16 and for assessment year 2016-17. We, therefore, quash the reassessment proceedings. As the reassessment itself is quashed, all other issues on merits of the additions, and other technical arguments of ld. Counsel for Page 32 of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case

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

reopening the assessment proceedings, for assessment year 2015–16 and for assessment year 2016-17. We, therefore, quash the reassessment proceedings. As the reassessment itself is quashed, all other issues on merits of the additions, and other technical arguments of ld. Counsel for Page 32 of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case

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

reopening the assessment proceedings, for assessment year 2015–16 and for assessment year 2016-17. We, therefore, quash the reassessment proceedings. As the reassessment itself is quashed, all other issues on merits of the additions, and other technical arguments of ld. Counsel for Page 32 of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case

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

reopening the assessment proceedings, for assessment year 2015–16 and for assessment year 2016-17. We, therefore, quash the reassessment proceedings. As the reassessment itself is quashed, all other issues on merits of the additions, and other technical arguments of ld. Counsel for Page 32 of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case

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

reopening the assessment proceedings, for assessment year 2015–16 and for assessment year 2016-17. We, therefore, quash the reassessment proceedings. As the reassessment itself is quashed, all other issues on merits of the additions, and other technical arguments of ld. Counsel for Page 32 of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case

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

reopening the assessment proceedings, for assessment year 2015–16 and for assessment year 2016-17. We, therefore, quash the reassessment proceedings. As the reassessment itself is quashed, all other issues on merits of the additions, and other technical arguments of ld. Counsel for Page 32 of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case

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

reopening the assessment proceedings, for assessment year 2015–16 and for assessment year 2016-17. We, therefore, quash the reassessment proceedings. As the reassessment itself is quashed, all other issues on merits of the additions, and other technical arguments of ld. Counsel for Page 32 of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case

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

reopening the assessment proceedings, for assessment year 2015–16 and for assessment year 2016-17. We, therefore, quash the reassessment proceedings. As the reassessment itself is quashed, all other issues on merits of the additions, and other technical arguments of ld. Counsel for Page 32 of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case

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

reopening the assessment proceedings, for assessment year 2015–16 and for assessment year 2016-17. We, therefore, quash the reassessment proceedings. As the reassessment itself is quashed, all other issues on merits of the additions, and other technical arguments of ld. Counsel for Page 32 of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case

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:

147 of the Act to be not fulfilled. 4. As it transpires from the orders of the authorities below, reassessment proceedings were initiated on the assessee by issuing notice under Section 148 of the Act on 27.02.2015. The impugned year before us is AY 2004-05. The Revenue reopened the case as per the limitation prescribed for issuing notice under

SHRI GANDHI MAULANA AZAD SHRAMJIVI ASHRA,KUTCH vs. INCOME TAX OFFICER, EXEMPTION WARD 1, RAJKOT, RAJKOT

In the result, appeals of the assessee, are allowed

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

147, of the Income-tax Act, 1961 - Income escaping assessment Conducting inquiry, providing opportunity before issue of notice under section 148 (General) - Assessment year 2019-20 - Assessee-trust did not file return of income as there was no taxable income - Assessing Officer Page 7 of 25 ITA No. 611 & 612/RJT/2025 Dff Shri Gandhi Maulana Azas Shramjivi Ashra issued reopening notices

SHRI GANDHI MAULANA AZAD SHRAMJIVI ASHRA,KUTCH vs. INCOME TAX OFFICER, EXEMPTION WARD 1, RAJKOT, RAJKOT

In the result, appeals of the assessee, are allowed

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

147, of the Income-tax Act, 1961 - Income escaping assessment Conducting inquiry, providing opportunity before issue of notice under section 148 (General) - Assessment year 2019-20 - Assessee-trust did not file return of income as there was no taxable income - Assessing Officer Page 7 of 25 ITA No. 611 & 612/RJT/2025 Dff Shri Gandhi Maulana Azas Shramjivi Ashra issued reopening notices

KUMAR RAMESH SAHU,RAJKOT, GUJARAT vs. ACIT, CIRCLE-2(2), RAJKOT, RAJKOT, GUJARAT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./I.T.A. No.336/Rjt/2023 (िनधा"रण वष" / Assessment Year : 2009-10) Kumar Ramesh Sahu बनाम/ The Acit, Sundaram, 72/3, New Cirtcle-2(3) Vs. College Wadi Rajkot – 60 001 150Ft5. Ring Road Opp. Meera Apartment Rajkot – 360 005 (Gujarat) "ायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aesps 5531 C (अपीलाथ" /Appellant) (""थ" / Respondent) .. Assessee By : Shri M.N. Manvar, Ld. Ar Revenue By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr सुनवाई की तारीख / Date Of Hearing 13/01/2025 घोषणा की तारीख /Date Of Pronouncement 04/04/2025 आदेश / O R D E R Per Dinesh Mohan Sinha:

u/s. 148 of the Act and he merely relied on the information received from the other Assessing officer. It is a case when the Ld. AO failed to record his own satisfaction as to the escapement of income by the Appellant. 13. The Ld. DR. has relied on two judgments of the Hon'ble Supreme Court in the case

NILESH BIPINCHANDRA MEHTA HUF,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

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

reopen the assessment u/s 147 of the Act, was itself\nillegal when the order u/s 148 r.w.s. 147 of the Act, is itself illegal and bad in\nlaw then the assessment order is going to be bad in law and no addition should\nbe made in the hands of assessee. The Ld. Counsel, in this regard, has also\nrelied

AMIBEN RAJESHKUMAR PUNATAR,RAJKOT vs. ITO, WARD-1(2)(1), RAJKOT, RAJKOT

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

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.24/Rjt/2026 िनधा"रण वष"/Assessment Year : 2015-16 Amiben Rajeshkumar Punatar, बनाम/ Ito, Ashish, 41-New Jagnath Plot, Vs Ward – 1(2)(1), Rajkot – 360001(Gujarat) Rajkot "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahrpp4181F (अपीलाथ"/Assessee) (""थ"/Respondent)

reopening of the assessment in the assessee’s case under consideration is after four years, and assessee had disclosed the full information during the regular assessment under section 143(3) of the Act. I note that under the proviso to section147 of the Act, where an assessment has been completed u/s 143(3) of the Act, and thereafter the assessing