IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER AND SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER आयकर अपील सं./ITA Nos. 274 to 276/RJT/2024 (Assessment Year: 2013-14 to 2015-16)

(Hybrid Hearing)

Ramaben Maganlal Zalaria, Vs. The PCIT-1, Umakant Udhyognagar, Near Rajkot 360001 Gandhiya Estate, Mavdi Plot, Rajkot-360004 èथायीलेखासं./जीआइआरसं./PAN/GIR No.: AACPZ0156C ( अपीलाथ(cid:568)/Appellant) (

(cid:292)×यथ(cid:568)

/Respondent)

िनधाªåरतीकìओरस/े Assessee by : Shri Vimal Desai, Ld. AR राजÖवकìओरस/े Revenue by : Shri Sanjay Punglia, CIT-DR सुनवाईकìतारीख/ Date of Hearing : 26/08/2025 घोषणाकìतारीख/Date of Pronouncement : 29/10/2025 आदेश/ORDER Per, Dr. A. L. Saini, AM:

By way of these three appeals, pertaining to single assessee for different assessment years, the assessee has challenged the correctness of the order dated 27.03.2024 passed by the Learned Principal Commissioner of Income-tax (in short "Ld PCIT") under section 263 of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'), for the assessment years 2013-14, 2014-15 and 2015-16.

2. Since, the issues involved in all these three appeals are common and identical; therefore, these appeals have been heard together and are being disposed of by this consolidated order. For the sake of convenience, the grounds as well as the facts narrated in ITA No. 274/Rjt/2024 for assessment year 2013-14, have been taken into consideration for deciding the above appeals en masse.

3. Grievances raised by the assessee, in lead case in ITA No. 274/Rjt/2024 for assessment year 2013-14, which, being interconnected, will be taken up together, are as follows:

"1.The order u/s. 263 of the Act is bad in law.

2.The learned Pr. CIT has erred in law as well as on facts in not considering the submissions of the appellant on the strength of which the re-assessment order was neither erroneous nor prejudicial to the interest of revenue and therefore the provisions of Section 263 of the Act were not applicable to the case of the appellant.

3. The learned Pr. CIT has erred in law as well as on facts in setting aside the re- assessment order passed by the ld. assessing officer u/s 147 r.w.s. 144B and directing assessment de-novo assessment regarding verification of the alleged cheque(s)/DD(s)

received in lieu of cash deposits”

4. The relevant material facts, as culled out from the material on record, are as follows. The Assessee had filed her return of income for assessment year 2013-14, on 08/12/2021, declaring total income of Rs.2,33,670/-, in response to notice issued u/s 148 of the I.T. Act dated 29.03.2021. The Assessment was finalized u/s 147 r. w.s. 144B of the Income-tax Act, 1961, on 26/03/2022 accepting returned income of Rs. 2,33,670/-.

5.Later on, Learned Principal Commissioner of Income-tax(in short "LdPCIT") , exercised his jurisdiction under section 263 of the Income-tax Act, 1961. The learned PCIT observed that a survey action u/s 133A was carried out on 18^th September 2014.Subsequent, upon finding unaccounted cash of Rs.1,10,00,000/-

(Rs. One Crore Ten Thousand) found at premises of Yash Enterprise (Prop-Shri Chetan Haribhai Bhalodiya), 202-Darshan Complex, Opp-Bombay Garage. Gondal Road, Rajkot. Consequently, search action u/s 132 was conducted on 19th September 2014. Thereafter, unaccounted cash was found in following Bank Accounts of the above concerns.

Thereafter, search action u/s 132 was conducted on 19th September 2014. The search has resulted into seizure/impounding of incriminating documents. Further enquiries were made into source of the cash deposits and their destination. As a result, a number of beneficiaries have been identified, who had received unaccounted payments through Shri Chetanbhai Haribha Bhalodiya, Shri Chetan Bhalodiya identified beneficiaries and the cash payments made to them. On the basis of seized material and his statements recorded on various dates, the beneficiaries were identified, to whom Sh. Chetan Bhalodiya has