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
ITA 612/RJT/2025[2016-17]Status: DisposedITAT Rajkot10 Mar 2026AY 2016-17
Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha
For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10Section 10(23)(iiia)Section 11Section 139Section 142(1)Section 145(3)Section 147Section 148Section 148ASection 149(1)(b)
u/s 147/148 of the Act. It is trite law that the sanctioning authority is expected to judiciously review and then record objective satisfaction and reflects independent application of mind.
7. It is respectfully submitted that satisfaction that has been accorded by the Ld.
Designated Authority cannot be regarded as a valid satisfaction since it does not reflect due application