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

undisclosed income from shipping agency business. But the Income or loss of share business was never disclosed before investigation authority. A claim which was not made in original return is not allowable in reassessment proceedings. In the decision of Hon’ble Supreme Court in CIT vs Sun Engineerings Works (P) Ltd. 198 297 (SC) (Asstyr 1960-62) it was held

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

undisclosed income from shipping agency business. But the Income or loss of share business was never disclosed before investigation authority. A claim which was not made in original return is not allowable in reassessment proceedings. In the decision of Hon’ble Supreme Court in CIT vs Sun Engineerings Works (P) Ltd. 198 297 (SC) (Asstyr 1960-62) it was held

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

undisclosed income from shipping agency business. But the Income or loss of share business was never disclosed before investigation authority. A claim which was not made in original return is not allowable in reassessment proceedings. In the decision of Hon’ble Supreme Court in CIT vs Sun Engineerings Works (P) Ltd. 198 297 (SC) (Asstyr 1960-62) it was held

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

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)

reassess such income and also any other income chargeable to tax, which has escaped assessment and which comes to his notice subsequently in the course of the proceedings under the section. The first proviso to section 147 has no application to the facts of the instant case. The basic postulate, which underlines section 147, is the formation of the belief

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)

reassess such income and also any other income chargeable to tax, which has escaped assessment and which comes to his notice subsequently in the course of the proceedings under the section. The first proviso to section 147 has no application to the facts of the instant case. The basic postulate, which underlines section 147, is the formation of the belief

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)

reassess such income and also any other income chargeable to tax, which has escaped assessment and which comes to his notice subsequently in the course of the proceedings under the section. The first proviso to section 147 has no application to the facts of the instant case. The basic postulate, which underlines section 147, is the formation of the belief

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

undisclosed sources and thereby treated as unexplained money u/s.69A of the Income Tax Act, 1961. Accordingly, addition to this extent of 10% of cash deposits/credits which comes to Rs.15,86,480/- was confirmed by ld.CIT(A) and balance addition was deleted. 9. During the appellate proceedings, before learned CIT(A), the assessee has raised additional technical/legal grounds, such as notice

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

undisclosed sources and thereby treated as unexplained money u/s.69A of the Income Tax Act, 1961. Accordingly, addition to this extent of 10% of cash deposits/credits which comes to Rs.15,86,480/- was confirmed by ld.CIT(A) and balance addition was deleted. 9. During the appellate proceedings, before learned CIT(A), the assessee has raised additional technical/legal grounds, such as notice

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

undisclosed sources and thereby treated as unexplained money u/s.69A of the Income Tax Act, 1961. Accordingly, addition to this extent of 10% of cash deposits/credits which comes to Rs.15,86,480/- was confirmed by ld.CIT(A) and balance addition was deleted. 9. During the appellate proceedings, before learned CIT(A), the assessee has raised additional technical/legal grounds, such as notice

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

undisclosed sources and thereby treated as unexplained money u/s.69A of the Income Tax Act, 1961. Accordingly, addition to this extent of 10% of cash deposits/credits which comes to Rs.15,86,480/- was confirmed by ld.CIT(A) and balance addition was deleted. 9. During the appellate proceedings, before learned CIT(A), the assessee has raised additional technical/legal grounds, such as notice

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

undisclosed sources and thereby treated as unexplained money u/s.69A of the Income Tax Act, 1961. Accordingly, addition to this extent of 10% of cash deposits/credits which comes to Rs.15,86,480/- was confirmed by ld.CIT(A) and balance addition was deleted. 9. During the appellate proceedings, before learned CIT(A), the assessee has raised additional technical/legal grounds, such as notice

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

undisclosed sources and thereby treated as unexplained money u/s.69A of the Income Tax Act, 1961. Accordingly, addition to this extent of 10% of cash deposits/credits which comes to Rs.15,86,480/- was confirmed by ld.CIT(A) and balance addition was deleted. 9. During the appellate proceedings, before learned CIT(A), the assessee has raised additional technical/legal grounds, such as notice

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

undisclosed sources and thereby treated as unexplained money u/s.69A of the Income Tax Act, 1961. Accordingly, addition to this extent of 10% of cash deposits/credits which comes to Rs.15,86,480/- was confirmed by ld.CIT(A) and balance addition was deleted. 9. During the appellate proceedings, before learned CIT(A), the assessee has raised additional technical/legal grounds, such as notice

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

undisclosed sources and thereby treated as unexplained money u/s.69A of the Income Tax Act, 1961. Accordingly, addition to this extent of 10% of cash deposits/credits which comes to Rs.15,86,480/- was confirmed by ld.CIT(A) and balance addition was deleted. 9. During the appellate proceedings, before learned CIT(A), the assessee has raised additional technical/legal grounds, such as notice

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

undisclosed sources and thereby treated as unexplained money u/s.69A of the Income Tax Act, 1961. Accordingly, addition to this extent of 10% of cash deposits/credits which comes to Rs.15,86,480/- was confirmed by ld.CIT(A) and balance addition was deleted. 9. During the appellate proceedings, before learned CIT(A), the assessee has raised additional technical/legal grounds, such as notice

SIX TWENTY REALTY PVT. LTD.,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

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

Income tax Act, 1961. That on facts as also in law, the proceedings-initiated u/s. 147 of the Act is invalid and assessment finalized on such invalid initiation deserves to be quashed and may kindly be quashed. (This is assessee's ground No. 2 in ITA No. 785/RJT/2024 for AY 2018-19, This is assessee's ground

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

undisclosed\nsources and thereby treated as unexplained money u/s.69A of the Income Tax Act,\n1961. Accordingly, addition to this extent of 10% of cash deposits/credits which\ncomes to Rs.15,86,480/- was confirmed by ld.CIT(A) and balance addition was\ndeleted.\n9. During the appellate proceedings, before learned CIT(A), the assessee has\nraised additional technical/legal grounds, such as notice

JITENDRABHAI DEVAJIBHAI BODAR,RAJKOT vs. INCOME TAX OFFICER, WARD-2(1)(1), RAJKOT, RAJKOT

In the result, the appeal is dismissed as not admitted”

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

reassessment. The proceedings u/s 147 of the I.T. Act, 1961 were initiated for the A.Y. 2013-14 and accordingly after recording reasons, a notice u/s 148 of the Act was issued on 28.04.2020, which was duly served upon the assessee through ITBA Portal/e- mail, in response to the notice, the assessee was required to furnish his ITR in the prescribed