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

144B needs to be set aside for the discussion made above. Keeping in view these facts, I am of the considered view that this is a fit case for invoking section 263 of 1. T. Act as the twin conditions namely, (i) the order of the Assessing Officer sought to be revised is erroneous: and (ii) it is prejudicial

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

144B needs to be set aside for the discussion made above. Keeping in view these facts, I am of the considered view that this is a fit case for invoking section 263 of 1. T. Act as the twin conditions namely, (i) the order of the Assessing Officer sought to be revised is erroneous: and (ii) it is prejudicial

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

144B needs to be set aside for the discussion made above. Keeping in view these facts, I am of the considered view that this is a fit case for invoking section 263 of 1. T. Act as the twin conditions namely, (i) the order of the Assessing Officer sought to be revised is erroneous: and (ii) it is prejudicial

MOHAN HARDASMAL TAHILYANI,GANDHIDHAM vs. INCOMETAX OFFICER WARD 1 GANDHIDHAM, GANDHIDHAM

In the result, appeal filed by the assessee is allowed

u/s 147 r.w.s. 144 read with section 144B of the Act.\n2. The grounds of appeal raised by the assessee are as follows:\n1. The order of the learned CIT (A) u/s.250 is bad in law and Contrary to the facts of\nthe case.\n2. The learned CIT(A) /NFAC has erred in not adjudicate the additional grounds of\nappeal

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 or re-computation under Section 147 of the Act and inapplicable till the issuance of notice under Section 148 of the Act. 6. The Scheme is clearly applicable for issuance of notice under section 148 of the Act and accordingly, it is only the FAO which can issue the notice under section

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 or re-computation under Section 147 of the Act and inapplicable till the issuance of notice under Section 148 of the Act. 6. The Scheme is clearly applicable for issuance of notice under section 148 of the Act and accordingly, it is only the FAO which can issue the notice under section

ASSTT COMMISSIONER OF INCOME TAX, CIRCLE - 1(1), , RAJKOT vs. SYMBOSA GRANITO PRIVATE LIMITED, WANKANER

u/s\n144B(xvi)(a), 144B(xvi)(b), and 144B(xvi)(c) of the Act, the relevant\nprovisions are reproduced below:\n\"Faceless Assessment.\n144B. (1) Notwithstanding anything to the contrary contained in any other provision\nof this Act, the assessment, reassessment or re-computation under sub-section (3) of\nsection 143 or under section 144 or under section 147

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

KALPESH RAVJIBHAI SOJITRA,JASDAN vs. THE INCOME TAX OFFICER, WARD 2(1)(2), RAJKOT, RAJKOT

In the result, appeal filed by the assessee is allowed, in above terms

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrid Hearing) Kalpesh Ravjibhai Sojitra, Vs. The Ito, Prop. Sojitra Petrolium, Bypass Ward-2(1)(2), Circle Atkot Road, Jasdan, Rajkot 360050, Rajkot-( Guj) "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Bqmps8120G (/Appellant) (/Respondent)

reassessment or recomputation under Section 147 of the Act and inapplicable to the issuance of notice under Section 148 of the Act. The Scheme is clearly applicable for issuance of notice under Section 148 of the Act and accordingly, it is only the FAO which can issue the notice under Section

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

KANAIYA FOOD PRODUCTS,JAMKANDORANA vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 336/Rjt/2024 (Assessment Year: 2017-18) (Hybrid Hearing) Kanaiya Food Products, Vs. The Principal Commissioner Of A A, Dhoraji Jamkandorana Income Tax-1, Rajkot 2Nd Floor, Aaykar Bhawan, Race Road, Near Gujarat Pani Purvatha Tank, Course Ring Road, Rajkot Jamkandodrana-360405 Rajkot-361006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aamfk9437F (अपीलाथ"/Appellant) (""यथ"/Respondent)

section 263 of the Act, the assessment order passed u/s 147 r.w.s. 144B dated 24.03.2022 is erroneous in for as it is prejudicial to the interests of revenue. 7. Aggrieved by the order of the ld PCIT, the assessee is in appeal before us. 8. Learned Counsel for the assessee, vehemently argued that in the re- assessment proceedings, no addition

KISHAN BEEJ,JAMNAGAR vs. ITO WARD 2(1), JAMNAGAR

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.384/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2017-18 Kishan Beej Ito, Wared-2(1) बनाम Kashivishvanath Road Jamnagar – 361 001 Nr. P & T Office Vs. Jamnagar – 361 001 Pan : Aacfk 2114 P (अपीलाथ"/Appellant) (""यथ"/Respondent) :

144B of the Act, dated 19.3.2022. Kishan Beej Vs. ITO 2 2. The grounds of appeal raised by the assessee are as follows: 1.That, the Ld. CIT(A) has wrongly passed the order without providing proper opportunity of being heard. 2.That, the Ld. CIT(A) has wrongly confirmed reopening of assessment u/s 147 of the l.T. Act, 1961. 3.That

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

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

reassessment and issuance of notice u/s 148 of the\nAct, although not valid, as per the provisions of section 148 of the Act,\nhowever, for that separate remedy is available to the assessee. That is, the\nassessee can file the appeal against the impugned order before appropriate\nauthority. However, the jurisdiction exercised by Ld.PCIT u/s 263 does not get\nimpeded

ABDULKADAR HAJIAHMED VADIWALA,JAMNAGAR vs. PR. COMMISSIONER OF INCOME TAX, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.103/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2016-17 Abdulkadar Hajiahmed Vadiwala The Pr.Cit बनाम Maniar Street, Lindi Bazar Jamanagar. Jamnagar-361001 Vs. Pan : Aatpv 4729 Q (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

u/s 147 r.w.s. 144B of the Act, dated 16/03/2023, in the case of the above mentioned assessee for the assessment year (AY) 2016-17 is erroneous in so far as it is prejudicial to the interest of revenue within the meaning of section 263 of the Act. Therefore, learned PCIT set aside the assessment order passed under section 147 read

CHUNILAL MAHADEVBHAI SANJA,MORBI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 279/Rjt/2024 (Assessment Year: 2016-17) (Hybrid Hearing) Chunilal Mahadevbhai Sanja, Vs. The Pcit-1 C/O M/S. Nobel Cera Coat, Rajkot At-Jambudia, Morbi-363642 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acnpp7711N (अपीलाथ"/Appellant) (""यथ"/Respondent)

u/s 147 r.w.s. 144B of the Income Tax Act dated 30.03.2022 is erroneous in for as it is prejudicial to the interests of revenue. Accordingly, the impugned assessment order passed by the assessing officer under section 147, read with section 144B of the Income tax Act, dated 30.03.2022, was set aside by ld PCIT for fresh assessment and directed

JIVANBHAI DE vs. HIBHAI SARLA,THANGADH, DIST. SURENDRANAGARVS.THE ITO WARD-2, SURENDRANAGAR, SURENDRANAGAR

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

147 r.w.s 144B of the Act dated 19.05.2023 and 26.05.2023 respectively. 2. Since, the issues involved in all the appeals are common and identical; therefore, these appeals have been heard together and are being disposed of by this consolidated order. 3. Both these appeals filed by the same assessee, for assessment year 2013–14 and for assessment

JIVANBHAI DE vs. HIBHAI SARLA,THANGADH, DIST. SURENDRANAGARVS.THE ITO WARD 2, SURENDRANAGAR, SURENDRANAGAR

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

147 r.w.s 144B of the Act dated 19.05.2023 and 26.05.2023 respectively. 2. Since, the issues involved in all the appeals are common and identical; therefore, these appeals have been heard together and are being disposed of by this consolidated order. 3. Both these appeals filed by the same assessee, for assessment year 2013–14 and for assessment

GOPAL SNACKS PVT LTD ,RAJKOT vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAJKOT

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita Nos. 498 & 499/Rjt/2025 "नधा"रणवष"/ Assessment Years: 2015-16 & 2020-21 बनाम Gopal Snacks Pvt. Ltd. Asst. Commissioner Of Plot No.2322-2324, Gidc Metoda, Income Tax Vs. Lodhika, Rajkot, Gujarat-360021 Circle-1(1), Rajkot Pan : Aadcg6113A (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Prakash Jhunjhunwala & Shri K. K. Maloo, Ars. राज"व क" ओर से/Revenue By : Shri Shramdeep Sinha, Cit.Dr & Shri Abhimanyu Singh, Sr. Dr सुनवाई क" तार"ख /Date Of Hearing : 19/11/2025 घोषणा क" तार"ख /Date Of Pronouncement : 08/12/2025

147 of the Act, (b) issuance of notice under section 148 of the Act, shall be through automated allocation, in accordance with risk management strategy formulated by the Board as referred to in section 148 of the Act for issuance of notice, and in a faceless manner, to the extent provided in section 144B of the Act with reference