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

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 with appeal memo. We note that the remaining legal grounds, stated above, goes to the root of the matter

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

viii) On the basis of facts and circumstances, AO has correctly adopted\nthe figures of G.P of Rs.2,40,30,182/- which is as per show cause notice.\nHowever, assessee was free to substantiate its claim with documentary\nevidences, which assessee failed even in response to draft assessment\norder.\n(ix) Applicability of section 69 is correctly applied by AO.The