GOJIYA BHIKHUBHAI,JAMNAGAR vs. PRINCIPAL COMMISSIONEROF INCOME TAX, JAMNAGAR

TDS Rs.5,17,98,259/-. This issue is in ITA\nNo.612/RJT/2024, only.\n(3) Row expenses, under the direct expenses Rs.1,36,50,985/-, assessee had\ntreated revenue expenditure, however, as per Ld. PCIT it should be capital\nexpenditure. This issue is in ITA No.612/RJT/2024, only.\n27. Now we shall take these issues one by one as follows. The first

ASHOK GOPALDAS VITHLANI,JAMKHAMBHALIYA vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, appeals filed by the assessees(ITA No

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 595/Rjt/2024 "नधा"रणवष" / Assessment Year: (2018-19) (Hybrid Hearing) Shiv Green Energy Pvt. Ltd. Vs. The Principal Commissioner Of Income Tax, 107, Divyam Park, Jamnagar 361001 Opp. H.O. Bhatt Bunglow, Nr. Sanjeevani Medical Store, Jamnagar - 361006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aascs8645J (Appellant) (Respondent)

TDS Rs.5,17,98,259/-. This issue is in ITA No.612/RJT/2024, only. (3) Row expenses, under the direct expenses Rs.1,36,50,985/-, assessee had treated revenue expenditure, however, as per Ld. PCIT it should be capital expenditure.This issue is in ITA No.612/RJT/2024, only. 27. Now we shall take these issues one by one as follows. The first issue raised

SHIV GREEN ENERGY PRIVATE LIMITED,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, appeals filed by the assessees(ITA No

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 595/Rjt/2024 "नधा"रणवष" / Assessment Year: (2018-19) (Hybrid Hearing) Shiv Green Energy Pvt. Ltd. Vs. The Principal Commissioner Of Income Tax, 107, Divyam Park, Jamnagar 361001 Opp. H.O. Bhatt Bunglow, Nr. Sanjeevani Medical Store, Jamnagar - 361006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aascs8645J (Appellant) (Respondent)

TDS Rs.5,17,98,259/-. This issue is in ITA No.612/RJT/2024, only. (3) Row expenses, under the direct expenses Rs.1,36,50,985/-, assessee had treated revenue expenditure, however, as per Ld. PCIT it should be capital expenditure.This issue is in ITA No.612/RJT/2024, only. 27. Now we shall take these issues one by one as follows. The first issue raised

HOLLIS VITRIFIED PRIVATE LIMITED,MORBI, GUJARAT, INDIA vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 1, RAJKOT, RAJKOT, GUJARAT, INDIA

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

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 363/Rjt/2024 (Assessment Year: 2018-19) (Hybrid Hearing) Hollis Vitrified Pvt. Ltd. Vs. The Pr. Commissioner Of Income Revenue Survey No. 756/P1/P1/P1, Opp. Tax-1, Rajkot Antique Granito, Ghuntu,-Lakhdhirpur Road, Morbi (Gujarat)-363642 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacch5628Q (अपीलाथ"/Appellant) (""थ"/Respondent)

TDS amount Rs.3,57,008/- and repayment of unsecured loan of Rs.3,33,744/- net closing balance of unsecured loan accepted during the F.Y.2017-18 of Rs.8,36,60,540/-. The contention of the assessee is accepted and unsecured loan for the year under consideration is taken amounting to Rs.8,36,60,540/-, Therefore, such cash credit is remained unexplained

SHREE SWAMINARAYAN MANDIR TRUST ,RAMPAR vs. THE ITO, EXEMPTION WARD - 1, RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.340/Rjt/2024 ("नधा"रण वष" / Assessment Year: (2020-21)

Section 143(3) r.w.s 144B of the Income Tax Act, 1961 (hereinafter referred to as “the Act”), vide order dated 09.09.2022. 2. The grievances raised by the assessee are as follows: ITA No.340/RJT/2024 - A.Y. 2020-21 Shree Swaminarayan Mandir Trust vs. ITO “1. The learned Commissioner of Income-tax (Appeals), Income Tax Department NFAC, Delhi erred in confirming the action

PRAMUKH ARANYA DEVELOPERS,JUNAGADH vs. PR. CIT, RAJKOT-1, RAJKOT, RAJKOT

TDS as per section 1941A. Party-wise+ Amount-wise Sales break up for the\nyear is also attached herewith for your perusal. (As per Q-010 Documents filed)\n11) Not Applicable. The sales transaction of Rs. 2,64,60,13,950/- does not belong to\nus. Please furnish more details if any.\n12) Please find herewith:\n•Detail of total

SHIV EXTRUSION,JAMNAGAR vs. INCOME TAX OFFICER, JAMNAGAR

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini, Am. & Dr. Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 646/Rjt/2025 "नधा"रणवष" / Assessment Year: (2016-17) (Hybrid Hearing) Shiv Extrusion Vs. Income Tax Officer Plot No.3978 Phase Iiiroad Income Tax Office, Ito Ward No.-R Dared, Jamnagar 2(10), Jamnagar, Income 361004, Gujarat, India, Jamnagar Tax Office, Shiv Smruti, Jamnagar, Jamnagar, Gujarat, 361008, Jamnagar "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abkfs7199F (Appellant) (Respondent) Appellant By : Shri Ramesh M. Patel, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 23/12/2025 Date Of Pronouncement : 12/03/2026

69A (unexplained money/investment), as the addition represents cash proceeds/profit from sales. The income, represented as cash proceeds from unaccounted sales, does not constitute an "Asset" as defined by the restrictive Explanation to Section 149(1)(b). The term "asset" includes immovable property, shares, securities, loans, advances, and deposits in a bank account, implying an exhaustive definition that excludes general cash

VINAY INFRATECH PVT LTD,RAJKOT vs. THE PCIT, RAJKOT-1, RAJKOT, RAJKOT

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No. 101/Rjt/2022 िनधा"रण वष"/Asstt. Years: 2017-2018 M/S Vinay Infratech Pvt. Ltd., The Principal Commissioner Of 110-112, Silver Chamber, Vs. Income Tax, Tagore Road, Rajkot-1, Rajkot. Rajkot.

69A in respect of on-money receipts, however, said order was set aside by Tribunal holding that AO had made detailed enquiries in respect of such on-money receipts and said view was also confirmed by High Court, A.Y. 2017-18 8 SLP filed against decision of High Court was liable to be dismissed. The facts of this case were

M/S. RADHE EXIM PVT. LTD. ,RAJKOT vs. THE PR. CIT-1, RAJKOT, RAJKOT

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

Bench: Shri Waseem Ahmed & Shri T.R Senthil Kumarआयकरअपीलसं./Ita No.75/Rjt/2021 निर्धररवरध/Asstt. Year: 2016-2017 M/S. Radhe Exim Pvt. Ltd., The Principal Commissioner Plot No.G-557, Vs. Of Income-Tax-1, Gidc Metoda, Rajkot. Kalawad Road, Metoda, Rajkot-360021. Pan: Aadcr1763P

69A in respect of on-money receipts, however, said order was set aside by Tribunal holding that AO had made detailed enquiries in respect of such on-money receipts and said view was also confirmed by High Court, SLP filed against decision of High Court was liable to be dismissed. The facts of this case were that pursuant to search

PANKAJ CHIMANLAL LODHIYA,RAJKOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

TDS. The penalty confirmed is totally\nunjustified on facts was also in law and may kindly be deleted.\n5.\nThe relevant material facts, as culled out from the material on record, are\nas follows. The assessee, before us, is an in individual and has originally filed\nreturn of income u/s 139(1) of the Act, on 30.09.2008, declaring total income

PANKAJKUMAR CHIMANLAL LODHIYA,RAJKOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

TDS. The penalty confirmed is totally\nunjustified on facts was also in law and may kindly be deleted.\n5. The relevant material facts, as culled out from the material on record, are\nas follows. The assessee, before us, is an in individual and has originally filed\nreturn of income u/s 139(1) of the Act, on 30.09.2008, declaring total income

PANKAJKUMAR CHIMANLAL LODHIYA,RAJKOT vs. THE ACTIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

TDS. The penalty confirmed is totally\nunjustified on facts was also in law and may kindly be deleted.\n5.\nThe relevant material facts, as culled out from the material on record, are\nas follows. The assessee, before us, is an in individual and has originally filed\nreturn of income u/s 139(1) of the Act, on 30.09.2008, declaring total income

PANKAJKUMAR CHIMANLAL LODHIYA,RAKJOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

TDS. The penalty confirmed is totally\nunjustified on facts was also in law and may kindly be deleted.\n5.\nThe relevant material facts, as culled out from the material on record, are\nas follows. The assessee, before us, is an in individual and has originally filed\nreturn of income u/s 139(1) of the Act, on 30.09.2008, declaring total income

PANKAJKUMAR CHIMANLAL LODHIYA,RAJKOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

TDS. The penalty confirmed is totally\nunjustified on facts was also in law and may kindly be deleted.\n5.\nThe relevant material facts, as culled out from the material on record, are\nas follows. The assessee, before us, is an in individual and has originally filed\nreturn of income u/s 139(1) of the Act, on 30.09.2008, declaring total income

PANKAJKUMAR CHIMANLAL LODHIYA,RAKJOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

TDS. The penalty confirmed is totally\nunjustified on facts was also in law and may kindly be deleted.\n5.\nThe relevant material facts, as culled out from the material on record, are\nas follows. The assessee, before us, is an in individual and has originally filed\nreturn of income u/s 139(1) of the Act, on 30.09.2008, declaring total income

SHRI HARILAL LAXMIDAS VAISHNANI,RAJKOT vs. THE ACIT/DCIT(INT. TAXN.), RAJKOT

In the result, in view of the discussion above and the facts placed on record before us, we are hereby allowing the appeal of the assessee

69A of the Act, it is seen that the appellant has only stated that Rs.5,00,000/- was his income/savings of earlier years held as cash in hands and Rs.62,000/- was deposited out of earlier withdrawals from the bank accounts. However the AO has held that there were no supporting evidences of cash in hand and there

SHRI GAJRAJ NATUBHA JETHVA,JAMNAGAR vs. THE ITO WARD-3 (2), JAMNAGAR, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 426/Rjt/2023 ("नधा"रणवष" / Assessment Year: (2016-17) (Hybrid Hearing) Gajraj Natubha Jethva Vs. Income Tax Officer, Ito Ward – Sikka Patiya, Moti Khavadi, 3(2), Taranjali Building, Nr. Amber Jamnagar-361140 Cinema, Pt. Nehru Marg, Hospital Road Jamnagar - 361140 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Akypj9388E (Appellant) (Respondent) Appellant By : Smt. Astha Maniyar, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 24/03/2025 Date Of Pronouncement : 17/06/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm:

section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income-tax (Appeals), dated 20.10.2023, which in turn arises out of an order passed by the Assessing Officer u/s 143(3) of the Act, on 29.12.2018. 2. Grounds of appeal raised by the assessee are as follows