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

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

1) of section 149 are\nmutually exclusive. Further, the notice issued under section 148 specifically\nprescribes the name of specified authority granting sanction as per section 151 of the\nAct which can indicate the specific condition under which the approval is granted. i.e.\nif the notice u/s 148 is issued within three years from the end of the relevant

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

1) of section 149 are\nmutually exclusive. Further, the notice issued under section 148 specifically\nprescribes the name of specified authority granting sanction as per section 151 of the\nAct which can indicate the specific condition under which the approval is granted. i.e.\nif the notice u/s 148 is issued within three years from the end of the relevant

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

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

MUKESH MANEKCHAND SHETH,RAJKOT vs. THE DCIT-ACIT, CENTRAL CIRCLE -2, RAJKOT, 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 SHAMJIBHAI SADHABHAI KANGAD,GANDHIDHAM-KUTCH vs. THE DCIT CENTRAL CIRCLE-1 , RAJKOT

u/s 153A is required to be issued beyond the period of six\nyears. For ready reference, extract from provision is reproduced:\n153A. (1) Notwithstanding anything contained in section 139, section 147, section\n148, section 149, section 151 and section 153, in the case of a person where a search is initiated\nunder section 132 or books of account, other documents

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

section 139(1) of the Act. Further, the assessee has made his submissions in response to the notice issued. The details called for in connection with the above reasons were furnished by the assesse. The same has been examined and after examining the same, the submissions are found to be acceptable and as such the income returned by the assesse

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

section 139(1) of the Act. Further, the assessee has made his submissions in response to the notice issued. The details called for in connection with the above reasons were furnished by the assesse. The same has been examined and after examining the same, the submissions are found to be acceptable and as such the income returned by the assesse

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

section 139(1) of the Act. Further, the assessee has made his submissions in response to the notice issued. The details called for in connection with the above reasons were furnished by the assesse. The same has been examined and after examining the same, the submissions are found to be acceptable and as such the income returned by the assesse

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)

1, Rajkot failed to appreciate the contention of the appellant raised before him that the underlying order u/s 147 itself was bad in law and therefore it was not amenable to revision u/s 263 of the Act. 6. The appellant craves leave to add, amend, alter and withdraw any ground of appeal anytime up to the hearing of this appeal

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)

1, Rajkot failed to appreciate the contention of the appellant raised before him that the underlying order u/s 147 itself was bad in law and therefore it was not amenable to revision u/s 263 of the Act. 6. The appellant craves leave to add, amend, alter and withdraw any ground of appeal anytime up to the hearing of this appeal

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:

Section 147 of the of the Act. (iii) According to written statement, the reasons recorded on the basis of the information by some other officer could not satisfy the requirement in law. This is a case of only borrowed satisfaction, which is not at all permissible and therefore the power u/s 147 of the Act should not be exercised mechanically

ILA JIGNESHKUMAR VAKHARIA,RAJKOT vs. THE INCOME TAX OFFICER, WARD 1(2)(1), RAJKOT

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

Bench: Dr. Arjun Lal Saini, Am. & Dr. Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 599/Rjt/2025 "नधा"रणवष" / Assessment Year: (2014-15) (Hybrid Hearing) Ila Jignesh Kumar Vakharia, Vs. The Income Tax Officer, Ward Bagasra Road, At Derdi Kumbhaji, 1(2)(1), Derdi – Gondal - 364465 New Aayakar Bhawan, Vatiaka Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aqfpv0899R (Appellant) (Respondent) Appellant By : Shri Samir Bhuptani, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 01 / 12 /2025 Date Of Pronouncement : 20 / 01 /2026

147 read with section 144B of the I.T. Act, on dated 28/05/2023. Ila Jigneshkumar Vakharia The Grounds of appeal raised by the assessee are as follows: - 1. 1. Ld. CIT(A) erred in law as well as on facts in passing the 1 order u/s. 250 of the Income Tax Act, 1961, which is bad in law and without appropriate

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. RK INFRALINK LLP, RAJKOT

In the result, ground No. 3 in Revenue`s appeal in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

u/s. 132(1) of the Act was carried out at the premises of R K Group. During the course of search, premises of Shri Girish Vanjani was also covered, who was maintaining the accounts of the R.K. Group (including the unaccounted cash transactions) at the instructions of Shri Sarvanand Sonvani, the main person of the R.K. Group. The assessing officer

R K INFRALINK LLP,RAJKOT vs. ACIT, CC-1, RAJKOT, RAJOKT

In the result, ground No. 3 in Revenue`s appeal in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

u/s. 132(1) of the Act was carried out at the premises of R K Group. During the course of search, premises of Shri Girish Vanjani was also covered, who was maintaining the accounts of the R.K. Group (including the unaccounted cash transactions) at the instructions of Shri Sarvanand Sonvani, the main person of the R.K. Group. The assessing officer

R K INFRALINK LLP,RAJKOT vs. ACIT, CC-1, RAJKOT, RAJKOT

In the result, ground No. 3 in Revenue`s appeal in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

u/s. 132(1) of the Act was carried out at the premises of R K Group. During the course of search, premises of Shri Girish Vanjani was also covered, who was maintaining the accounts of the R.K. Group (including the unaccounted cash transactions) at the instructions of Shri Sarvanand Sonvani, the main person of the R.K. Group. The assessing officer

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. RK INFRALINK LLP, RAJKOT

In the result, ground No. 3 in Revenue`s appeal in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

u/s. 132(1) of the Act was carried out at the premises of R K Group. During the course of search, premises of Shri Girish Vanjani was also covered, who was maintaining the accounts of the R.K. Group (including the unaccounted cash transactions) at the instructions of Shri Sarvanand Sonvani, the main person of the R.K. Group. The assessing officer