Search: reassessment u/s 147

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Section 1477 Section 143(3)5 Section 2633 Section 1483 Reassessment3 Addition to Income3 Section 10(38)2 Reopening of Assessment2

HANSA JITENDRA HARIA,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, the appeal of the assessee is dismissed

ITA 104/RJT/2024[2013-14]Status: DisposedITAT Rajkot20 Jun 2025AY 2013-14

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)

For Appellant: Shri Dhaval Shah, ARFor Respondent: Shri Sanjay Punglia, CIT. DR

Section 10(38)Section 147Section 263Section 69A

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

SMT. HARSHIDABEN M. POBARU,,JAMNAGAR. vs. DY. COMMR. OF INCOME TAX, CIRCLE-1, , JAMNAGAR.

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

ITA 371/RJT/2018[2011-12]Status: DisposedITAT Rajkot25 Jun 2019AY 2011-12

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./Ita No.371/Rjt/2018 "नधा"रण वष"/Asstt. Year: 2011-2012 D.C.I.T, Smt. Harshidaben M. Pobaru, Circle-1, Vs. “Gokul’’, Park Colony, Jamnagar. Jamnagar-361008. Pan: Acmpp9140J

Section 143(3)Section 147Section 69

Reassessment has to be based on "fresh material". A reopening based on reappraisal of existing material is invalid. There was no tangible material before the Assessing Officer to form the belief that the income had escaped assessment and therefore, reopening of assessment under section 147 was not valid. We rely upon following judicial precedents a. Balakrishna Hiralal Wani

LILAVANTIBEN GORDHANBHAI PADARIYA,RAJKOT vs. ITO, WARD 1(1)(3), RAJKOT, RAJKOT

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 372/RJT/2023[2013-14]Status: DisposedITAT Rajkot19 Sept 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 372/Rjt/ 2023 ("नधा"रणवष" / Assessment Year: (2013-14) Lilavantiben Gordhanbhai Padariya Vs. Ito, Wd – 1(1)(3), Rajkot Vrajdham, Shardanagar Main Road, Aayakar Bhavan, Race Course Mabdi Road, Rajkot – 360001 Ring Road, Rajkot – 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acgpp7067E (Appellant) (Respondent) Appellant By : Shri D. M. Rindani, Ld.Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 24/06/2025 Date Of Pronouncement : 19/09/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm: Captioned Appeal Filed By The Assessee Is Directed Against The Order Passed By The National Faceless Appeal Centre [(In Short “Nfac/Ld. Cit(A)”] Vide Order Dated 09.09.2023, Which In Turn Assessment Order Passed By Assessment Unit, Income Tax Department / Assessing Officer Under Section 143(3) R.W.S. 147 Of The Income Tax Act, 1961 (In Short “The Act”), Vide Order Dated 04.12.2017. 2. Grounds Of The Appeal Raised By The Assessee Are As Follows: 1. The Learned Commissioner (Appeals), National Faceless Appeal Centre, Delhi Erred In Upholding Validity Of Assessment U/S 147 By Issue Of Notice U/S 148 Of The Act. 2 The Learned Commissioner (Appeals), National Faceless Appeal Centre, Delhi Erred In Confirming Action Of Assessing Officer In Making Addition Of Rs. 1,11,13,196/- By Way Of Alleged Difference Between Sales As Per Annual Vat Return & Sales As Per Audited Accounts By Failing To Appreciate That The Alleged Difference Was Duly Reconciled & Explained.

For Appellant: Shri D. M. Rindani, Ld.ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 139Section 143(3)Section 147Section 148Section 44A

147 by issue of notice u/s 148 of the Act. 2 The learned Commissioner (Appeals), National Faceless Appeal Centre, Delhi erred in confirming action of assessing officer in making addition of Rs. 1,11,13,196/- by way of alleged difference between sales as per Annual VAT return and sales as per audited accounts by failing to appreciate that