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

194A of the Act;\nd) The Ld. assessing officer did not conduct any sort of\nenquiry/investigation and had not issued any notices u/s.133(6)/131_to\nthe lenders and their bankers to verify the transactions;\ne) The Ld. assessing officer had not provided the copies of contrary\nmaterial/evidence and statements of 3rd parties for rebuttal and also\ndid not allow

MANSUKHBHAI KANJIBHAI SAKARIYA,RAJKOT vs. PRINCIPAL COMMISSIONER OF INCOME TAX, RAJKOT-1, RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita No.318/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2016-17 Mansukhbhai Kanjibhai Sakariya The Pr.Commissioner Of बनाम At Khajuri Gundala Income Tax-1, Rajkot. Post Station: Vavdi Vs. Amarnagar, Khajuri Gundala. Pan : Aslps 7027 E (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रतीक"ओरसे/Assessee By : Shri Rajendra Singhal, Ld.Ar राज"वक"ओरसे/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

147 r.w.s. 144B of the MansukhbhaiKanjibhai Sakariya Vs. Pr.CIT 4 Income tax Act, 1961 on 28.03.2022, is erroneous and prejudicial to the interest of the revenue. 4.Considering above such facts, notice u/s 263 of the Income-tax Act, 1961, was issued by ld.PCIT, on 29.02.2023 and duly served upon the assessee.The ld. PCIT stated in the notice that assessee case

H J ENTERPRISE,RAJKOT vs. ACIT, CIRCLE-1(1), RAJKOT, RAJKOT

In the result, the appeal of the assessee is partly allowed, in above terms

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

147 of the Act is invalid and assessment made on such invalid initiation deserves to be quashed and may kindly be quashed. 3. The Id. CIT(A) erred on facts as also in law in confirming addition of Rs. 48,00,000/-being alleged accommodative entries in the form of unsecured loan of Rs. 48,00,000/- from M/s. Bhoomidev