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 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 148 of the Act and not the JAO. 7. In this regards

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 made on 31.03.2015 for AY 1998-99 to AY 2004-05 on the strength of the notices u/s. 148 dated 27.02.2015 for respective AYs, under consideration in the present appeals, are required to be quashed as notices u/s. 148 issued on 27.02.2015 for those years are void ab initio. Under the circumstances the submissions made on the merits

KATARIA SNACK PELLETS PRIVATE LIMITED,RAJKOT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAJKOT

In the result, appeal of the assessee is dismissed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.468/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2015-16 Kataria Snack Pellets Pvt. Ltd. The Acit, Circle-1(1) बनाम 510, Gidc, Metoda Kalawad Road Rajkot Rajkot-360021, Gujarat Vs. Pan : Aafck2028L (अपीलाथ"/Appellant) (""यथ"/Respondent) :

147 of the Income Tax Act. Accordingly, notice u/s 148 of the Act, was issued on 31.03.2021. The Assessee submitted its Return of income on 02.04.2021. Notice u/s143(2) of the Income Tax was issued to the assessee on 04.05.2021. The reasons of reopening was also supplied to the assessee. The Assessee submitted its objection vide letter dated

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

171 Taxman 406 (Gujarat)]. Hence, in such cases, both the Supreme Court and the Jurisdictional High Court have consistently held that where evidences regarding unaccounted receipts are being assessed it is not reasonable to consider the entire unaccounted receipts for taxation Rather, only profit element lying therein should be estimated keeping in mind the facts and surrounding circumstances

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

171 Taxman 406 (Gujarat)]. Hence, in such cases, both the Supreme Court and the Jurisdictional High Court have consistently held that where evidences regarding unaccounted receipts are being assessed it is not reasonable to consider the entire unaccounted receipts for taxation Rather, only profit element lying therein should be estimated keeping in mind the facts and surrounding circumstances

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

171 Taxman 406 (Gujarat)]. Hence, in such cases, both the Supreme Court and the Jurisdictional High Court have consistently held that where evidences regarding unaccounted receipts are being assessed it is not reasonable to consider the entire unaccounted receipts for taxation Rather, only profit element lying therein should be estimated keeping in mind the facts and surrounding circumstances

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. R K DREAMLAND, RAJKOT

171 Taxman 406\n(Gujarat)]. Hence, in such cases, both the Supreme Court and the Jurisdictional\nHigh Court have consistently held that where evidences regarding unaccounted\nreceipts are being assessed it is not reasonable to consider the entire unaccounted\nreceipts for taxation Rather, only profit element lying therein should be estimated\nkeeping in mind the facts and surrounding circumstances

R K DREAMLAND,RAJKOT vs. ACIT, CC-1, RAJKOT, RAJOKT

171 Taxman 406\n(Gujarat)]. Hence, in such cases, both the Supreme Court and the Jurisdictional\nHigh Court have consistently held that where evidences regarding unaccounted\nreceipts are being assessed it is not reasonable to consider the entire unaccounted\nreceipts for taxation Rather, only profit element lying therein should be estimated\nkeeping in mind the facts and surrounding circumstances

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. R K DREAMLAND, RAJKOT

171 Taxman 406\n(Gujarat)]. Hence, in such cases, both the Supreme Court and the Jurisdictional\nHigh Court have consistently held that where evidences regarding unaccounted\nreceipts are being assessed it is not reasonable to consider the entire unaccounted\nreceipts for taxation Rather, only profit element lying therein should be estimated\nkeeping in mind the facts and surrounding circumstances

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

171 Taxman 406\n(Gujarat)]. Hence, in such cases, both the Supreme Court and the Jurisdictional\nHigh Court have consistently held that where evidences regarding unaccounted\nreceipts are being assessed it is not reasonable to consider the entire unaccounted\nreceipts for taxation Rather, only profit element lying therein should be estimated\nkeeping in mind the facts and surrounding circumstances

RK DREAMLAND,RAJKOT vs. ACIT, CC-1, RAJKOT, RAJKOT

171 Taxman 406\n(Gujarat)]. Hence, in such cases, both the Supreme Court and the Jurisdictional\nHigh Court have consistently held that where evidences regarding unaccounted\nreceipts are being assessed it is not reasonable to consider the entire unaccounted\nreceipts for taxation Rather, only profit element lying therein should be estimated\nkeeping in mind the facts and surrounding circumstances