JIVANBHAI DE vs. HIBHAI SARLA,THANGADH, DIST. SURENDRANAGARVS.THE ITO WARD-2, SURENDRANAGAR, SURENDRANAGAR

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

68. It is apparent from the above details that impugned notice under section 148 of the Act is issued beyond the period of 'surviving time' as per the direction of Hon'ble Apex Court in case of Rajeev Bansal (supra)and therefore, such notices would be invalid notices. 69. The impugned notices issued under section 148

JIVANBHAI DE vs. HIBHAI SARLA,THANGADH, DIST. SURENDRANAGARVS.THE ITO WARD 2, SURENDRANAGAR, SURENDRANAGAR

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

68. It is apparent from the above details that impugned notice under section 148 of the Act is issued beyond the period of 'surviving time' as per the direction of Hon'ble Apex Court in case of Rajeev Bansal (supra)and therefore, such notices would be invalid notices. 69. The impugned notices issued under section 148

ANSHOYABEN BHAGVANJIBHAI BHOJANI,MORBI vs. INCOME TAX OFFICER, WARD-1, MORBI, MORBI

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

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 13/Rjt/2026 ("नधा"रणवष"/Assessment Year: (2017-18) Anshoyaben Bhagvanjibhai Bhojani, Income Tax Officer, Ward 1, Morbi Shreeji Nagar, B/H. Chhatralaya Road, Vs. Income Tax Office, Aayakar Vibhag, B/H New Bus Stand, Morbi, J.K. Chamber, National Highway-8-A, Gujarat 363641 At- Lalpar, Morbi Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Brnpb6281R (अपीलाथ"/Appellant) (""यथ"/Respondent)

148 of the Act was issued and served upon the assessee on 14/07/2022, after due approval of the competent authority. The notice u/s 143(2) of the Act was issued to the assessee electronically through ITBA on 11/05/2023. In this case, the assessee has filed return of her income for the relevant assessment year on 13.02.2018, declaring therein total income

THE ACIT, CIRCLE-2,, JAMNAGAR vs. M/S HIRAVATI MARINE PRODUCTS (P) LTD.,, PORBANDAR

In the result, the appeal of the revenue is partly allowed for statistical purposes

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed"नधा"रण वष"/Asstt. Year:2007-2008 Addl. Commissioner Of Hiravati Marine Products Pvt. Income Tax, Vs Ltd. Range-2, Porbandar, Jamnagar. Pan No: Aabch2110C "नधा"रण वष"/Asstt. Year:2008-2009

68,148/- being the disallowance on account of delay in payments made to employer as well as employee's contribution to provident fund. 3. The Id. CIT(A) has erred in law and in facts in deleting the addition of Rs.7,23,110/- being the disallowance on account of investigation expenses paid by the bank. 4. The Ld.CIT

HIRAVATI MARINE PRODUCTS PVT. LTD.,,PORBANDAR vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, RANGE-2,, JAMNAGAR

In the result, the appeal of the revenue is partly allowed for statistical purposes

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed"नधा"रण वष"/Asstt. Year:2007-2008 Addl. Commissioner Of Hiravati Marine Products Pvt. Income Tax, Vs Ltd. Range-2, Porbandar, Jamnagar. Pan No: Aabch2110C "नधा"रण वष"/Asstt. Year:2008-2009

68,148/- being the disallowance on account of delay in payments made to employer as well as employee's contribution to provident fund. 3. The Id. CIT(A) has erred in law and in facts in deleting the addition of Rs.7,23,110/- being the disallowance on account of investigation expenses paid by the bank. 4. The Ld.CIT

KISHAN BEEJ,JAMNAGAR vs. ITO WARD 2(1), JAMNAGAR

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.384/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2017-18 Kishan Beej Ito, Wared-2(1) बनाम Kashivishvanath Road Jamnagar – 361 001 Nr. P & T Office Vs. Jamnagar – 361 001 Pan : Aacfk 2114 P (अपीलाथ"/Appellant) (""यथ"/Respondent) :

2. The grounds of appeal raised by the assessee are as follows: 1.That, the Ld. CIT(A) has wrongly passed the order without providing proper opportunity of being heard. 2.That, the Ld. CIT(A) has wrongly confirmed reopening of assessment u/s 147 of the l.T. Act, 1961. 3.That, the Ld. CIT(A) has wrongly confirmed addition

KALPESH RAVJIBHAI SOJITRA,JASDAN vs. THE INCOME TAX OFFICER, WARD 2(1)(2), RAJKOT, RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrid Hearing) Kalpesh Ravjibhai Sojitra, Vs. The Ito, Prop. Sojitra Petrolium, Bypass Ward-2(1)(2), Circle Atkot Road, Jasdan, Rajkot 360050, Rajkot-( Guj) "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Bqmps8120G (/Appellant) (/Respondent)

2. The Ld.AO erred in law as well as on facts that notice/order u/s.148 issued by the JAO and not in faceless manner.” 4. Learned Counsel for the assessee, argued that above additional legal grounds raised by the assessee should be admitted, in the interest of justice, as all facts relating to above legal grounds were before assessing officer. Therefore

AMBARADI SEVA SAHKARI MANDALI LTD.,AMBARADI , DIST. AMRELI vs. THE DCIT(CPC), BANGALURU, BENGALURU

In the result, all the 4 appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2019-20

148/-, under Section 80P(2)(a)(iv) – Rs.3,76,152/-, under Section 80P(2)(d) – Rs.3,51,076/- and under Section 80P(2)(e) – Rs.70,900/-. ITA Nos.186, 197, 204 & 203/RJT/2022 Assessment Years: 2019-20 (for all) Page 3 of 10 Thereafter, the assessee was in receipt of communication under Section

DHARESHWAR SEVA SAHAKARI MANDALI LTD. ,VILLAGE: - DHARESHWAR, TALUKA: - RAJULA, DIST. AMRELI vs. THE DCIT (CPC), BANGALORE, BANGALORE

In the result, all the 4 appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2019-20

148/-, under Section 80P(2)(a)(iv) – Rs.3,76,152/-, under Section 80P(2)(d) – Rs.3,51,076/- and under Section 80P(2)(e) – Rs.70,900/-. ITA Nos.186, 197, 204 & 203/RJT/2022 Assessment Years: 2019-20 (for all) Page 3 of 10 Thereafter, the assessee was in receipt of communication under Section

AMRUTPUR SEVA SAHKARI MANDALI LTD.,VILLAGE: - AMRUTPUR TALUKA DHARI, DIST. AMRELI vs. THE DCIT (CPC), BANGALORE, BANGALORE

In the result, all the 4 appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2019-20

148/-, under Section 80P(2)(a)(iv) – Rs.3,76,152/-, under Section 80P(2)(d) – Rs.3,51,076/- and under Section 80P(2)(e) – Rs.70,900/-. ITA Nos.186, 197, 204 & 203/RJT/2022 Assessment Years: 2019-20 (for all) Page 3 of 10 Thereafter, the assessee was in receipt of communication under Section

SHREE SANALIYA SEVA SAHKARI MANDLI LTD.,LITAL MOTALILIYA SANALIYA, DIST. AMRELI vs. THE DCIT (CPC), BANGALORE, BANGALORE

In the result, all the 4 appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2019-20

148/-, under Section 80P(2)(a)(iv) – Rs.3,76,152/-, under Section 80P(2)(d) – Rs.3,51,076/- and under Section 80P(2)(e) – Rs.70,900/-. ITA Nos.186, 197, 204 & 203/RJT/2022 Assessment Years: 2019-20 (for all) Page 3 of 10 Thereafter, the assessee was in receipt of communication under Section

ANIL DHANSUKHLAL,RAJKOT vs. INCOME TAX OFFICER (INT. TAXATION) GANDHIDHAM, GANDHIDHAM

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Sainiand Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.68/Rjt/2024 "नधा"रणवष"/ Assessment Year: (2018-19) Anil Dhansukhlal Income Tax Officer बनाम Vakhat Niwas 10, Divan Para (Int.Txn), Gandhidham, Vs. Rajkot -360 001 Amruta Estate Building, Jheelwas, Sadar, Rajkot- 360 001 Pan/Gir No.Ajypd6405F "थायीलेखासं /. जीआइआरसं /. (अपीलाथ"/Appellant) .. (""यथ"/Respondent) "नधा"रतीक"ओरसे/Assessee By : Shri Bharat Kumar, Ar राज"वक"ओरसे/Revenue By : Shri Abhimanyu Singh Yadav, Sr-Dr

148 of the Act was issued and served upon the appellant. In response thereof, the appellant assessee filed return of income declaring the total income at Rs.480/-. The assessing officer issued the draft assessment order dated 24.03.2023 u/s 144C of the Act by making an addition of Rs.2,97,63,459/-, on account of unexplained investment in purchase of immovable

GOPAL SNACKS PVT LTD ,RAJKOT vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAJKOT

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita Nos. 498 & 499/Rjt/2025 "नधा"रणवष"/ Assessment Years: 2015-16 & 2020-21 बनाम Gopal Snacks Pvt. Ltd. Asst. Commissioner Of Plot No.2322-2324, Gidc Metoda, Income Tax Vs. Lodhika, Rajkot, Gujarat-360021 Circle-1(1), Rajkot Pan : Aadcg6113A (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Prakash Jhunjhunwala & Shri K. K. Maloo, Ars. राज"व क" ओर से/Revenue By : Shri Shramdeep Sinha, Cit.Dr & Shri Abhimanyu Singh, Sr. Dr सुनवाई क" तार"ख /Date Of Hearing : 19/11/2025 घोषणा क" तार"ख /Date Of Pronouncement : 08/12/2025

68 of unsecured loans received of Rs.85,00,000/-, ought to have considered the understated vital facts, being; a) The exhaustive documentary evidences, being Ledger, Confirmation, PAN, Own bank statement, I.T return, bank statement and balance sheet of lenders and TDS certificate for interest payment to prove the identity, genuineness and credit-worthiness of the lenders has not been disproved

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

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

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

148 has been Page 26of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) obtained separately from Joint Commissioner of Income Tax as per the provisions of section 151 of the Act. 40. We have gone through the above reasons recorded by the assessing officer and noticed that these reasons were recorded based

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

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

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

148 has been Page 26of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) obtained separately from Joint Commissioner of Income Tax as per the provisions of section 151 of the Act. 40. We have gone through the above reasons recorded by the assessing officer and noticed that these reasons were recorded based

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAJKOT vs. CLASSIC NETWORK PVT. LTD., RJAKOT

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

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

148 has been Page 26of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) obtained separately from Joint Commissioner of Income Tax as per the provisions of section 151 of the Act. 40. We have gone through the above reasons recorded by the assessing officer and noticed that these reasons were recorded based

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

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

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

148 has been Page 26of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) obtained separately from Joint Commissioner of Income Tax as per the provisions of section 151 of the Act. 40. We have gone through the above reasons recorded by the assessing officer and noticed that these reasons were recorded based

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

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

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

148 has been Page 26of44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) obtained separately from Joint Commissioner of Income Tax as per the provisions of section 151 of the Act. 40. We have gone through the above reasons recorded by the assessing officer and noticed that these reasons were recorded based