MUKESH MANEKCHAND SHETH,RAJKOT vs. THE DCIT-ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

147 of the Act is incurably and defective. In para-3 of SCN, it is\nstated that the provision of Section 149(1)(b) has been followed by taking\napproval from the specified authority. However, as submitted above, there is no\nmention of asset or expenditure represented by the alleged-escaped income and\nhence, the notice issued u/s

MUKESH MANEKCHAND SHETH,RAJKOT vs. THE DCIT-ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

147 of the Act is incurably and defective. In para-3 of SCN, it is\nstated that the provision of Section 149(1)(b) has been followed by taking\napproval from the specified authority. However, as submitted above, there is no\nmention of asset or expenditure represented by the alleged-escaped income and\nhence, the notice issued u/s

MUKESH MANEKCHAND SHETH,RAJKOT vs. THE DCIT-ACIT, CENTRAL CIRCLE -2, RAJKOT., RAJKOT

147 of the Act is incurably and defective. In para-3 of SCN, it is\nstated that the provision of Section 149(1)(b) has been followed by taking\napproval from the specified authority. However, as submitted above, there is no\nmention of asset or expenditure represented by the alleged-escaped income and\nhence, the notice issued u/s

MUKESH MANEKCHAND SHETH,RAJKOT vs. THE DCIT-ACIT, CENTRAL CIRCLE -2, RAJKOT, RAJKOT

147 of the Act is incurably and defective. In para-3 of SCN, it is\nstated that the provision of Section 149(1)(b) has been followed by taking\napproval from the specified authority. However, as submitted above, there is no\nmention of asset or expenditure represented by the alleged-escaped income and\nhence, the notice issued u/s

ATUL VRAJLAL KARIA,RAJKOT vs. AC / DC (INT.TXN), RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.133/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2012-13 Atul Vrajlal Karia Ac/Dc (Int. Txn), बनाम C/O. D.S. Karia & Co. Ca, 203, Rajkot Cosmo Complex, Mahila College Vs. Chowk, Kalawad Road, Rajkot Pan : Adwpk6568J (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Kalpesh Doshi, Ld.Ar राज"व क" ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Sr-Dr

vii) The approval accorded u/s 151 of the Act is invalid, without application of mind and mechanical in nature. (viii) The provisions of section 147 has been wrongly applied as against the provisions of section 153C of the I.T. Act, 1961. 4. We note that most of the above additional legal grounds were already raised in Form no. 36 along

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ACIT, CENTRAL CIRL-1,, RAJKOT

In the result, appeals filed by the Revenue, in ITA No

Bench: Dr. Arjun Lal Saini & Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 134 & 135/Rjt/2023 (िनधा"रणवष" / Assessment Years: (2007-08 & 2008-09) Income Tax Officer, Ward- Shri Kherajmal Lekhrajbjai 5Th 1(2)(1), Aaykar Bhavan, Thavrani, 4- Parsana Nagar, Shri Vs. Floor, Room No. 517, Race Vaheguru Grupa, Near Refugee Course Ring Road, Rajkot-360 Colony, Rajkot-360 001 001 "थायी लेखा सं./जी आइ आर सं./Pan/Gir No.: Adrpt 5807 E (Appellant) (Respondent)

vii. In last decade, several decisions of ITATs in Gujarat, and Hon. High court of Gujarat can be found wherein the term Angadiya /shroff have been used interchangeably to cover the cases of unaccounted transactions of cash. Due to lack of clarity between these terms, several decisions of Ld. ITAT and Hon. HC have actually considered the activity of depositing

MAYURBHAI JAYSUKHLAL SHAH,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 319/Rjt/2024 (Assessment Year: 2013-14) (Hybrid Hearing) Mayurbhai Jaysukhlal Shah Vs. Principal Commissioner Of 601, Cross Way, P.N. Marg, Income Tax, Jamnagar Jamnagar, Gujarat-361001 Office Of The Principal Commissioner Of Income Tax.Pcit, Jamnagar "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afgps1754J (अपीलाथ"/Assessee) (""यथ"/Respondent)

u/s 147 rws 144B of the Act dated 31/03/2022, is erroneous and 3 Mayurbhai Jaysukhlal Shah prejudicial to the interest of the revenue within the meaning of section 263 of the Act to that extent and therefore, Ld. PCIT directed the assessing officer to pass the assessment order afresh in respect of the above issue after giving reasonable opportunity

KRUPALU METALS P. LTD.,JAMNAGAR vs. THE NFAC DELHI, DELHI

vii) The assessee has not placed any evidence on record that this is job\nwork and not sale by way of submitting copy of ITR, P&L account,\nBalance Sheet, TDS return etc. of the parties with whom alleged\ntransactions made.\n(viii) On the basis of facts and circumstances, AO has correctly adopted\nthe figures of G.P of Rs.2

SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,,JUNAGADH vs. THE INCOME TAX OFFICER-WARD 1(2)(4),, RAJKOT

36,628/-\n51,69,18,800/-\nVI\nBharat I Bhatia\n2012-13\n177,72,01,183/-\n53,31,60,355/-\n124,40,40,828/-\nVII Bharat I Bhatia\n2013-14\n58,46,25,710/-\n17,53,87,713\n40,92,37,997/-\nThe A.O. is directed to consider the income of the above-mentioned cases as determined above. Thus

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ITO, WARD-1 (1) (2),, RAJKOT

36,628/-\n51,69,18,800/-\nVI\nBharat I Bhatia\n2012-13\n177,72,01,183/-\n53,31,60,355/-\n124,40,40,828/-\nVII Bharat I Bhatia\n2013-14\n58,46,25,710/-\n17,53,87,713\n40,92,37,997/-\nThe A.O. is directed to consider the income of the above-mentioned cases as determined above. Thus\nthe

THE INCOME TAX OFFICER-WARD-2,, JUNAGADH vs. SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,, JUNAGADH

36,628/- 51,69,18,800/-\nVI\nBharat I Bhatia\n2012-13\n177,72,01,183/- 53,31,60,355/- 124,40,40,828/-\nVII\nBharat I Bhatia\n2013-14\n58,46,25,710/- 17,53,87,713 40,92,37,997/-H\nThe A.O. is directed to consider the income of the above-mentioned cases as determined above. Thus

THE DY. COMMR. OF INCOME TAX, CEN. CIR.-1,, RAJKOT vs. BHARATKUMAR ISHWARBHAI BHATIYA,, RAJKOT

36,628/-\n51,69,18,800/-\nVI\nBharat I Bhatia\n2012-13\n177,72,01,183/-\n53,31,60,355/-\n124,40,40,828/-\nVII\nBharat I Bhatia\n2013-14\n58,46,25,710/-\n17,53,87,713\n40,92,37,997/-\nThe A.O. is directed to consider the income of the above-mentioned cases as determined above. Thus\nthe