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

147 of the Act, after recording the reasons for re-opening and obtaining approval of the Pr. CIT(Central), Ahmedabad u/s 151 of the Act, dated 22/03/2021. The notice u/s 148 of the Act has been issued to the assessee, on 23/03/2021. On 24-03-2021, the assessee has filled a return of income in response to notice u/s

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

147 of the Act, after recording the reasons for re-opening and obtaining approval of the Pr. CIT(Central), Ahmedabad u/s 151 of the Act, dated 22/03/2021. The notice u/s 148 of the Act has been issued to the assessee, on 23/03/2021. On 24-03-2021, the assessee has filled a return of income in response to notice u/s

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

147 of the Act, after recording the reasons for re-opening and obtaining approval of the Pr. CIT(Central), Ahmedabad u/s 151 of the Act, dated 22/03/2021. The notice u/s 148 of the Act has been issued to the assessee, on 23/03/2021. On 24-03-2021, the assessee has filled a return of income in response to notice u/s

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

147 of the Act, after recording the reasons for re-opening and obtaining approval of the Pr. CIT(Central), Ahmedabad u/s 151 of the Act, dated 22/03/2021. The notice u/s 148 of the Act has been issued to the assessee, on 23/03/2021. On 24-03-2021, the assessee has filled a return of income in response to notice u/s

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

147 of the Act, after recording the reasons for re-opening and obtaining approval of the Pr. CIT(Central), Ahmedabad u/s 151 of the Act, dated 22/03/2021. The notice u/s 148 of the Act has been issued to the assessee, on 23/03/2021. On 24-03-2021, the assessee has filled a return of income in response to notice u/s

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

147 of the Act, after recording the reasons for re-opening and obtaining approval of the Pr. CIT(Central), Ahmedabad u/s 151 of the Act, dated 22/03/2021. The notice u/s 148 of the Act has been issued to the assessee, on 23/03/2021. On 24-03-2021, the assessee has filled a return of income in response to notice u/s

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

147 of the Act, after recording the reasons for re-opening and obtaining approval of the Pr. CIT(Central), Ahmedabad u/s 151 of the Act, dated 22/03/2021. The notice u/s 148 of the Act has been issued to the assessee, on 23/03/2021. On 24-03-2021, the assessee has filled a return of income in response to notice u/s

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

147 of the Act, after recording the reasons for re-opening and obtaining approval of the Pr. CIT(Central), Ahmedabad u/s 151 of the Act, dated 22/03/2021. The notice u/s 148 of the Act has been issued to the assessee, on 23/03/2021. On 24-03-2021, the assessee has filled a return of income in response to notice u/s

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

147 of the Act, after recording the reasons for re-opening and obtaining approval of the Pr. CIT(Central), Ahmedabad u/s 151 of the Act, dated 22/03/2021. The notice u/s 148 of the Act has been issued to the assessee, on 23/03/2021. On 24-03-2021, the assessee has filled a return of income in response to notice u/s

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

147 of the Act, after recording the reasons for re-opening and obtaining approval of the Pr. CIT(Central), Ahmedabad u/s 151 of the Act, dated 22/03/2021. The notice u/s 148 of the Act has been issued to the assessee, on 23/03/2021. On 24-03-2021, the assessee has filled a return of income in response to notice u/s

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

147 of the Act, after recording the reasons for re-opening and obtaining approval of the Pr. CIT(Central), Ahmedabad u/s 151 of the Act, dated 22/03/2021. The notice u/s 148 of the Act has been issued to the assessee, on 23/03/2021. On 24-03-2021, the assessee has filled a return of income in response to notice u/s

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

147 of the Act, after recording the reasons for re-opening and obtaining approval of the Pr. CIT(Central), Ahmedabad u/s 151 of the Act, dated 22/03/2021. The notice u/s 148 of the Act has been issued to the assessee, on 23/03/2021. On 24-03-2021, the assessee has filled a return of income in response to notice u/s

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

147 of the Act, after recording the reasons for re-opening and obtaining approval of the Pr. CIT(Central), Ahmedabad u/s 151 of the Act, dated 22/03/2021. The notice u/s 148 of the Act has been issued to the assessee, on 23/03/2021. On 24-03-2021, the assessee has filled a return of income in response to notice u/s

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

147 of the Act, after recording the reasons for re-opening and obtaining approval of the Pr. CIT(Central), Ahmedabad u/s 151 of the Act, dated 22/03/2021. The notice u/s 148 of the Act has been issued to the assessee, on 23/03/2021. On 24-03-2021, the assessee has filled a return of income in response to notice u/s

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"

11. We further note that the expression used under section 148 of the Act i.e. “so for as may be” has been interpreted by the Hon’ble Apex court in the case of R Dalmia Vs. CIT reported in 236 ITR 480, that once the return filed under section 148 of the Act then in making the assessment

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"

11. We further note that the expression used under section 148 of the Act i.e. “so for as may be” has been interpreted by the Hon’ble Apex court in the case of R Dalmia Vs. CIT reported in 236 ITR 480, that once the return filed under section 148 of the Act then in making the assessment

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

147 of the Act is incurably and defective. In para-3 of SCN, it is\nstated that the provision of Section 149(1)(b) has been followed by taking\napproval from the specified authority. However, as submitted above, there is no\nmention of asset or expenditure represented by the alleged-escaped income and\nhence, the notice issued u/s

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

reassessment under Section 148 within the prescribed time limits. Further, Section 151 requires assessing officers to obtain sanction of the specified authority before issuing notice under Section 148. In Chhugamal Rajpal v. S P Chaliha, a three-Judge Bench of this Court held that Section 151 must be strictly adhered to because it contains "important safeguards." 65 Section 151 imposes