MANISH RASIKLAL BAWARIA,RAJKOT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 1(2), RAJKOT, RAJKOT

आयकर अपीलीय अिधकरण, राजकोट �यायपीठ, राजकोट। In The Income Tax Appellate Tribunal, Rajkot Bench, Rajkot Before Dr. Arjun Lal Saini, Accountant Member And Shri Sonjoy Sarma, Judicial Member आयकर अपील सं./ITA No. 224/RJT/2024 [ �नधा�रण वष�/Assessment Year: 2014-15 ] Manishkumar R Bawaria Income Tax Officer, Ward - 1(2)(2), C/O. Eagle Motors Private Limited, Rajkot Vs. Eagle House, Near Moti Tanki Chowk, Aayakar Bhawan Race Course Ring Rajkot-360001, Gujarat Road, Rajkot-360001, Gujarat �थायीलेखासं./जीआइआरसं./PAN/GIR No.: ACHPB7342R (अपीलाथ�/Appellant) (��यथ�/Respondent) आयकर अपील सं./ITA No. 410/RJT/2023 [ �नधा�रण वष�/Assessment Year: 2015-16 ] & आयकर अपील सं./ITA No. 219/RJT/2024 [ �नधा�रण वष�/Assessment Year: 2016-17 ] Manishkumar R Bawaria Assistant Commissioner Of Income C/O. Eagle Motors Private Limited, Tax, Circle - 1(2), Vs. Eagle House, Near Moti Tanki Chowk, Aayakar Bhawan Race Course Ring Rajkot-360001, Gujarat Road, Rajkot-360001, Gujarat �थायीलेखासं./जीआइआरसं./PAN/GIR No.: ACHPB7342R (अपीलाथ�/Appellant) (��यथ�/Respondent) Appellant by : None Respondent by : Shri Ravinder Sindhu, Ld. CIT(DR) Date of Hearing : 01/07/2026 Date of Pronouncement : 23/07/2026 :: ORDER :: Per, Shri Sonjoy Sarma, JM: These three appeals have been filed by the same assessee. ITA No. 410/RJT/2023 for Assessment Year 2015-16 is directed against the order of the

ITA No. 219 & 224/RJT/2024 & ITA No.410/RJT/2023 Manishkumar R. Bawaria National Faceless Appeal Centre, Delhi [hereinafter referred to as “NFAC”] dated 23.11.2023, arising out of the assessment order passed under section 144 of the Income-tax Act, 1961 dated 28.12.2017. ITA No. 219/RJT/2024 for Assessment Year 2016-17 is directed against the order of the NFAC dated 19.02.2024, arising out of the assessment order passed under section 143(3) dated 26.12.2018. ITA No. 224/RJT/2024 for Assessment Year 2014-15 is directed against the order of the NFAC dated 19.02.2024, arising out of the assessment order passed under section 143(3) dated 28.12.2016. 02. Since all the appeals pertain to the same assessee and involve common issues, they were heard together and are being disposed of by this common order. For the sake of convenience, we first take up ITA No. 224/RJT/2024 for Assessment Year 2014-15. Our findings therein shall apply mutatis mutandis to ITA No. 219/RJT/2024 and ITA No. 410/RJT/2023. 03. Brief facts of the case are that the assessee is engaged in the business of trading in petroleum products and filed its return of income for the year under consideration declaring a total income of Rs.64,06,650/-. The case was selected for scrutiny, and notices under sections 143(2) and 142(1) of the Act were issued. During the course of assessment proceedings, the Assessing Officer noticed unsecured loans amounting to Rs.2,13,43,050/-. The assessee was called upon to furnish confirmations, copies of returns of income of the creditors and other supporting evidence. However, according to the Assessing Officer, only ledger accounts of the parties were furnished. On verification of the Profit and Loss Account, the Assessing Officer further noticed that the assessee had debited interest on loans, interest on delayed payment of TDS, penalty and donation. The assessment was accordingly completed under section 143(3) of the Act by determining the total income at Rs.3,42,36,600/-, resulting in a tax demand of Rs.1,52,19,710/-.

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ITA No. 219 & 224/RJT/2024 & ITA No.410/RJT/2023 Manishkumar R. Bawaria 04. Aggrieved, the assessee preferred an appeal before the Ld. CIT(A), who partly allowed the appeal by granting certain relief. 05. Still aggrieved, the assessee is in further appeal before the Tribunal. 06. At the time of hearing, none appeared on behalf of the assessee despite service of notices on several occasions. As no request for adjournment was received, we are of the considered view that the assessee is not interested in prosecuting the appeals. Therefore, we proceed to dispose of the appeals after hearing the Ld. DR and on the basis of the material available on record. 07. We have heard the submissions of the Ld. DR and perused the material available on record. Despite repeated opportunities, none has appeared on behalf of the assessee. The conduct of the assessee clearly indicates that it is not interested in pursuing the appeals. Accordingly, we see no reason to interfere with the order of the Ld. CIT(A), which is hereby sustained. 08. Since the issues involved in ITA No. 410/RJT/2023 and ITA No. 219/RJT/2024 are identical to those involved in ITA No. 224/RJT/2024, our findings recorded herein shall apply mutatis mutandis to those appeals as well. 09. In the result, all the appeals filed by the assessee are dismissed.

Order pronounced in the open court on this 23rd day of July, 2026.

Sd/- Sd/- [ Dr. Arjun Lal Saini ] [ Shri Sonjoy Sarma ] लेखा सद�य/Accountant Member �याियक सद�य/Judicial Member राजकोट/Rajkot िदनांक/ Date: 23/07/2026 Copy of the order forwarded to : 1. The assessee 2. The Respondent 3. CIT

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ITA No. 219 & 224/RJT/2024 & ITA No.410/RJT/2023 Manishkumar R. Bawaria 4. The CIT(A) 5. DR, ITAT, Rajkot 6. Guard File By order //True Copy// Sr. Private Secretary ITAT, Rajkot

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