TAKDIR TRADERS,RAJKOT vs. THE PCIT-1, RAJKOT, RAJKOT

In the result, the appeal filed by the assessee is dismissed”

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

147 r.w.s. 1448 of the Income-tax Act, 1961 on 28.03.2022 is set aside for fresh assessment only the extent of the issues discussed supra and direct the Assessing Officer to pass a fresh assessment order after making necessary enquiries relating to cash transactions made by the assessee with M/s National Shroff and if not found satisfactorily, appropriate addition under

MANISH GYANCHAND JAIN,GANDHIDHAM vs. ASSTT. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE, , GANDHIDHAM

In the result the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

u/s 147 of the Act has to be limited to the extent they reduce the income to originally assessed and as such income for the purpose of re-assessment cannot be reduced beyond the income originally assessed. Therefore, in reassessment proceedings under section 147 of the Act, the assessee cannot seek a review of concluded item, unconnected with escapement

MANISH GYANCHAND JAIN,GANDHIDHAM vs. ASSTT. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE, , GANDHIDHAM

In the result the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

u/s 147 of the Act has to be limited to the extent they reduce the income to originally assessed and as such income for the purpose of re-assessment cannot be reduced beyond the income originally assessed. Therefore, in reassessment proceedings under section 147 of the Act, the assessee cannot seek a review of concluded item, unconnected with escapement

SHRI MANISH GYANCHAND JAIN ,GANDHIDHAM vs. THEACIT, GANDHIDHAM CIRCLE, GANDHIDHAM

In the result the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

u/s 147 of the Act has to be limited to the extent they reduce the income to originally assessed and as such income for the purpose of re-assessment cannot be reduced beyond the income originally assessed. Therefore, in reassessment proceedings under section 147 of the Act, the assessee cannot seek a review of concluded item, unconnected with escapement

MANISH GYANCHAND JAIN,GANDHIDHAM vs. ASSTT. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE, , GANDHIDHAM

In the result the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

u/s 147 of the Act has to be limited to the extent they reduce the income to originally assessed and as such income for the purpose of re-assessment cannot be reduced beyond the income originally assessed. Therefore, in reassessment proceedings under section 147 of the Act, the assessee cannot seek a review of concluded item, unconnected with escapement

NILESH BIPINCHANDRA MEHTA HUF,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

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

reassessment and issuance of notice u/s 148 of the\nAct, although not valid, as per the provisions of section 148 of the Act,\nhowever, for that separate remedy is available to the assessee. That is, the\nassessee can file the appeal against the impugned order before appropriate\nauthority. However, the jurisdiction exercised by Ld.PCIT u/s 263 does not get\nimpeded

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

In the result, the appeal of the assessee is dismissed

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)

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

MANSUKHLAL KHIMJI KHIMASIYA HUF,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

reassessment order. Therefore, during the assessment proceedings, the assessee was asked for various details/documents in respect of the transaction. All details/documents, such as, Contract Note for Purchase of shares, Broker Ledger (with broker details) from whom shares were purchased and Contract Note for Sale of shares etc. were filed before the assessing officer. 8. However, ld.PCIT rejected the above contention

BHANUBEN MANSUKHLAL KHIMASIYA,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

reassessment order. Therefore, during the assessment proceedings, the assessee was asked for various details/documents in respect of the transaction. All details/documents, such as, Contract Note for Purchase of shares, Broker Ledger (with broker details) from whom shares were purchased and Contract Note for Sale of shares etc. were filed before the assessing officer. 8. However, ld.PCIT rejected the above contention

JAYESH KHIMJI KHIMASIYA HUF,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

reassessment order. Therefore, during the assessment proceedings, the assessee was asked for various details/documents in respect of the transaction. All details/documents, such as, Contract Note for Purchase of shares, Broker Ledger (with broker details) from whom shares were purchased and Contract Note for Sale of shares etc. were filed before the assessing officer. 8. However, ld.PCIT rejected the above contention

MANSUKHLAL KHIMJI KHIMASIYA,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

reassessment order. Therefore, during the assessment proceedings, the assessee was asked for various details/documents in respect of the transaction. All details/documents, such as, Contract Note for Purchase of shares, Broker Ledger (with broker details) from whom shares were purchased and Contract Note for Sale of shares etc. were filed before the assessing officer. 8. However, ld.PCIT rejected the above contention

DCIT, CENTRAL CIRCLE 2, RAJKOT, RAJKOT vs. SHRI MUKESH MANEKCHAND SHETH, RAJKOT

set of various kinds of\nunaccounted transactions that came to surface from the seized Miracle data,\nshould be added in the hands of the assessee. The assessing officer noted that the\nseized digital data in the form of accounting entries on Miracle file is accurate,\nreliable and self-explanatory. Further, there is also no doubt thatthe accounts of\nthe assessee

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

set of various kinds of\nunaccounted transactions that came to surface from the seized Miracle data,\nshould be added in the hands of the assessee. The assessing officer noted that the\nseized digital data in the form of accounting entries on Miracle file is accurate,\nreliable and self-explanatory. Further, there is also no doubt thatthe accounts of\nthe assessee

PAREEN RIAZ DOSANI,BHANVAD vs. THE ITO WARD-1, DWARKA, DWARKA

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

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

reassessment order dated 22/12/2017 was held erroneous and prejudicial to the interest of revenue and therefore the ITA No.101/RJT/2024 – A.Y. 2010-11 Pareen Riaz Dosani vs. ITO same was set aside with a direction to make a fresh assessment after giving opportunity to the assessee. 5. The set aside assessment proceedings were transferred to National Faceless Assessment Centre

THE ITO, WARD-3(1)(1),, RAJKOT-GUJARAT vs. SHRI GIRISHKUMAR M. PURUSWANI,, RAJKOT-GUJARAT

In the result, the appeal filed by the Revenue is hereby dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

reassessment order is correct in law and set aside the order passed by the Ld. CIT(A) and restore that of the Assessing Officer. 6. Per contra, Ld. A.R. Mr. Mehul Ranpura appearing for the Assessee submitted before us a Paper Book which contains various details namely the 148 notice and copy of the Licence issued to the assessee

THE ITO, WARD-3(1)(1),, RAJKOT-GUJARAT vs. SHRI GIRISHKUMAR M. PURUSWANI,, RAJKOT-GUJARAT

In the result, the appeal filed by the Revenue is hereby dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

reassessment order is correct in law and set aside the order passed by the Ld. CIT(A) and restore that of the Assessing Officer. 6. Per contra, Ld. A.R. Mr. Mehul Ranpura appearing for the Assessee submitted before us a Paper Book which contains various details namely the 148 notice and copy of the Licence issued to the assessee

THE ITO, WARD-3(1)(1),, RAJKOT-GUJARAT vs. SHRI GIRISHKUMAR M. PURUSWANI,, RAJKOT-GUJARAT

In the result, the appeal filed by the Revenue is hereby dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

reassessment order is correct in law and set aside the order passed by the Ld. CIT(A) and restore that of the Assessing Officer. 6. Per contra, Ld. A.R. Mr. Mehul Ranpura appearing for the Assessee submitted before us a Paper Book which contains various details namely the 148 notice and copy of the Licence issued to the assessee

KANAIYA FOOD PRODUCTS,JAMKANDORANA vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 336/Rjt/2024 (Assessment Year: 2017-18) (Hybrid Hearing) Kanaiya Food Products, Vs. The Principal Commissioner Of A A, Dhoraji Jamkandorana Income Tax-1, Rajkot 2Nd Floor, Aaykar Bhawan, Race Road, Near Gujarat Pani Purvatha Tank, Course Ring Road, Rajkot Jamkandodrana-360405 Rajkot-361006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aamfk9437F (अपीलाथ"/Appellant) (""यथ"/Respondent)

setting aside the re- assessment order passed by the Ld. A.O. u/s 147 and directing de-novo assessment regarding verification of violation of section 40A(3) in respect of cash payments made to agriculturists for purchasing agricultural produce.” 3. Succinctly, the factual panorama of the case is that assessee before us is a partnership –firm. The Assessee had filed