H K ISPAT PVT. LTD.,PANCHMAHAL vs. THE DY.CIT, CENTRAL CIRCLE-2, VADODARA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblesn

section 68 of the Act. As per amended provisions, the assessee IT(SS)A No. 73/Ahd/2025 and others Group Appeals - HK Ispat Pvt Ltd Asst.Year : 2015-16 to 2021-2022 - 8– needs to explain source to source of sum credited to his bank account, the appellant submitted that such amended provisions not applicable to current year, thus the appellant

DEPUTY COMMISSIONER OF INCOME -TAX CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD, GUJARAT vs. BHAVESHKUMAR GIRISHBHAI BHANDARI, AHMEDABAD, GUJARAT

Appeal is allowed in ITA 978/Ahd/2025 and ITA\n978/Ahd/2025 as well

164 taxmann.com 669 (Ahmedabad -\nTrib.), and Smt. Paramadevi Tekriwal v. ITO [2025] 172 taxmann.com 430\n(Ahmedabad - Trib.), wherein on identical facts it was held that the so-called\ngains from penny stock scrips were not genuine but represented unaccounted\nmoney in the guise of exempt capital gains, and additions made by the\nAssessing Officer under section 68

DEPUTY COMMISSIONER OF INCOME -TAX CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD, GUJARAT vs. GIRISHKUMAR AMRATLAL BHANDARI HUF, HIMATNAGAR, GUJARAT

In the result, the appeal of the Department is allowed and the order of\nthe Assessing Officer is restored

164 taxmann.com 669 (Ahmedabad -\nTrib.), and Smt. Paramadevi Tekriwal v. ITO [2025] 172 taxmann.com 430\n(Ahmedabad - Trib.), wherein on identical facts it was held that the so-called\ngains from penny stock scrips were not genuine but represented unaccounted\nmoney in the guise of exempt capital gains, and additions made by the\nAssessing Officer under section 68

DEPUTY COMMISSIONER OF INCOME -TAX CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD, GUJARAT vs. BHAVESHKUMAR GIRISHBHAI BHANDARI, AHMEDABAD, GUJARAT

In the result, the appeal of the Department is allowed and the order of\nthe Assessing Officer is restored

164 taxmann.com 669 (Ahmedabad -\nTrib.), and Smt. Paramadevi Tekriwal v. ITO [2025] 172 taxmann.com 430\n(Ahmedabad - Trib.), wherein on identical facts it was held that the so-called\ngains from penny stock scrips were not genuine but represented unaccounted\nmoney in the guise of exempt capital gains, and additions made by the\nAssessing Officer under section 68

PAWAN EDIFICE PVT. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(2), VADODARA

68,995/-\nTotal Own Funds (a + b)\n19,52,09,835/-\n20,76,83,195/-\n18. It was thus urged that, in view of the availability of substantial own\nfunds and the binding judicial precedents, the disallowance sustained by\nthe CIT(A) under section 14A ought to be deleted in full.\n19. With regard to the disallowance of administrative

GITABEN DINESHBHAI PATEL,AHMEDABAD vs. ITO WARD 5(3)(1), AHMEDABAD

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

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

section 68 where the assessee failed to establish Gitaben Dineshbhai Patel vs. ITO Asst.Year –2017-18 - 9– the identity and creditworthiness of counterparties and could not substantiate the genuineness of steep price rise in shares of a company with no commercial worth. The ratio of this judgment squarely applies to the present case, as the assessee has completely failed

PAWAN EDIFICE PVT. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(2), VADODARA

Appeals are partly allowed for\nstatistical reasons

68,995/-\nTotal Own Funds (a + b)\n19,52,09,835/-\n20,76,83,195/-\n18.\nIt was thus urged that, in view of the availability of substantial own\nfunds and the binding judicial precedents, the disallowance sustained by\nthe CIT(A) under section 14A ought to be deleted in full.\n19.\nWith regard to the disallowance of administrative

THE DY.CIT, CENTRAL CIRCLE-1, VADODARA vs. PAWAN EDIFICE PVT. LTD., VADODARA

Appeals are partly allowed for\nstatistical reasons

68,995/-\nTotal Own Funds (a + b)\n19,52,09,835/-\n20,76,83,195/-\n18.\nIt was thus urged that, in view of the availability of substantial own\nfunds and the binding judicial precedents, the disallowance sustained by\nthe CIT(A) under section 14A ought to be deleted in full.\n19.\nWith regard to the disallowance of administrative

BHAUMIK JEWELLERS PRIVATE LIMITED,AHMEDABAD vs. THE ITO, WARD-1(1)(2), AHMEDABAD

In the result, the appeal of the assessee stands allowed

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं /Ita No.1642/Ahd/2024 िनधा"रण वष" /Assessment Year : 2017-18 Bhaumik Jewellers Private The Ito बनाम/ Limited Ward-1(1)(2) V/S. 111, Gold Souk Complex Ahmedabad B/H. Sapphire Complex Cg Road Ahmedabad – 380 009 "थायी लेखा सं./Pan: Aagcb 2423 B (अपीलाथ)/ Appellant) (*+ यथ)/ Respondent) Assessee By : Shri Biren Shah, Ar Revenue By : Shri Sher Singh, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 17/12/2025 घोषणा की तारीख /Date Of Pronouncement: 03/02/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals) National Faceless Appeal Centre (Nfac), Delhi [In Short “The Cit(A)”] Passed Under Section 250 Of The Income Tax Act, 1961 (In Short “The Act”), Dated 26/07/2024 Arising Out Of The Assessment Order Passed By The Assessing Officer (In Short “The Ao”) Under Section 143(3) Of The Act For The Assessment Year 2017-18. The Assessee In This Appeal Has Agitated The Confirmation Of The Addition Of Rs. 9,65,97,834/- Made By The Ao Under Section 68 Of The Act Bhaumik Jewellers Private Limited Vs. The Ito Asst. Year : 2017-18

68 of the Act read with section 115BBE of the Act, treating the same as income from undisclosed sources. 4. Aggrieved by the order of the AO, the assessee preferred an appeal before the CIT(A). The CIT(A), however, confirmed the action of the AO. The CIT(A) relied heavily upon the decision of the Hyderabad Bench

MOHAMMED SALEEM ABDULKADER KAJALWALA,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(1)(3), VADODARA

In the result, the appeal filed by the Assessee is hereby allowed

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

68 is liable to be deleted as held by the very recent judgment of the Jurisdictional High Court in the case of PCIT vs. Merrygold I.T.A No. 536/Ahd/2023 A.Y. 2015-16 Page No 8 Mohammed Saleem Abdulkader Kajalwala Vs. ITO Gems (P.) Ltd. [2024] 164 taxmann.com 764 wherein it was held as follows: “Section

IRM PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1), AHMEDABAD

In the result the appeal filed by assessee is partly allowed for statistical purposes

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No. 1590/Ahd/2024 िनधा"रण वष" /Assessment Year : 2011-12 Irm Private Limited, The Deputy Commissioner Irm House, बनाम/ Of Income Tax, V/S. Off. C.G Raod, Circle 2(1)(1), Navrangpura, Ahmedabad. Ahmedabad-380009. "थायी लेखा सं./Pan: Aaaci3678M अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Bandish Soparkar, Ar Revenue By : Shri Abhijit, Sr-Dr

68 of the IT Act. 9. On the facts and in the circumstances of the case and in law, the NFAC erred in confirming the action of the Ld. AO in levying interest under section 234A, 234B, 234C, and 234D of the IT Act. 10. On the facts and in the circumstances of the case

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

68[(ixa) deposits with or investment in any bonds issued by a public company formed and registered in India with the main object of carrying on the business of providing long-term finance for urban infrastructure in India…” Section 13(i)(d) “(d) 1 in the case of a trust for charitable or religious purposes or a charitable

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

68[(ixa) deposits with or investment in any bonds issued by a public company formed and registered in India with the main object of carrying on the business of providing long-term finance for urban infrastructure in India…” Section 13(i)(d) “(d) 1 in the case of a trust for charitable or religious purposes or a charitable

THE ACIT, (EXEMPTION) CIRCLE-1, AHMEDABAD vs. VYAKTI VIKAS KENDRA INDIA, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

68[(ixa) deposits with or investment in any bonds issued by a public company formed and registered in India with the main object of carrying on the business of providing long-term finance for urban infrastructure in India…” Section 13(i)(d) “(d) 1 in the case of a trust for charitable or religious purposes or a charitable

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

68[(ixa) deposits with or investment in any bonds issued by a public company formed and registered in India with the main object of carrying on the business of providing long-term finance for urban infrastructure in India…” Section 13(i)(d) “(d) 1 in the case of a trust for charitable or religious purposes or a charitable

SHRI JAYANTILAL BABULAL SHAH,AHMEDABAD vs. THE ACIT, CIRCLE-2(2), AHMEDABAD

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

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

68 of the Act by the Assessing Officer. 2. On the facts and in the circumstances of the case and in law, the ld. CIT(A) has erred in not appreciating the facts brought on record by the Assessing Officer in the assessment order as well as in remand report. 3. On the facts and in the circumstances

THE ACIT., CENT.CIRCLE-2(1), AHMEDABAD vs. SHRI JAYANTILAL BABULAL SHAH, AHMEDABAD

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

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

68 of the Act by the Assessing Officer. 2. On the facts and in the circumstances of the case and in law, the ld. CIT(A) has erred in not appreciating the facts brought on record by the Assessing Officer in the assessment order as well as in remand report. 3. On the facts and in the circumstances

THE DCIT, CENTRAL CIRCLE-1(1),, AHMEDABAD vs. SHRI UMANG H. THAKKAR, AHMEDABAD

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

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarआयकर अपील सं / Ita No. 2150/Ahd/2008 िनधा"रण वष"/Assessment Year: 2005-06 बनाम Shri Umang Hiralal Thakkar, The Dy. Commissioner Of Vs. Dharmadev House, Income-Tax, Shyamal Cross Road, Satellite, Central Circle 1(1), Ahmedabad – 380015 Ahmedabad Pan : Aavpt 8621 R आयकर अपील सं / Ita No. 2548/Ahd/2008 िनधा"रणवष"/Assessment Year: 2005-06 बनाम Shri Umang Hiralal Thakkar, The Dy. Commissioner Of Vs. 305, Sahajanand Plaza, Bhatta Income-Tax, Ch Ar Rasta, Paldi, Ahmedabad Central Circle 1(1), Pan : Aavpt 8621 R Ahmedabad अपीलाथ"/ (Appellant) अपीलाथ" "" यथ" "" यथ"/ (Respondent) अपीलाथ" अपीलाथ" "" "" यथ" यथ" िनधा"रती की ओर से / Assessee By : Shri Bandish Soparkar, Ar & Shri Parin Shah, Ar ""थ" की ओर से / Revenue By : Shri Akhilendra Pratap Yadav, Cit-Dr तारीख/Date Of Hearing : 09.05.2024 सुनवाई क" क" तारीख सुनवाई सुनवाई सुनवाई क" क" तारीख तारीख घोषणा क" क" तारीख तारीख /Date Of Pronouncement: 30.07.2024 घोषणा घोषणा घोषणा क" क" तारीख तारीख आदेश आदेश/O R D E R आदेश आदेश

section 68 of the Act on this count.” 6.4 As is evident from the above, the ITAT noted that the Assessing Officer had made addition in the absence of any evidence filed by the assessee. The ld. CIT(A) had admitted the additional evidences filed by the assessee in this regard, and after appreciating the same and seeking