KRUPALU METALS P. LTD.,JAMNAGAR vs. THE NFAC DELHI, DELHI

In the result, assessee’s appeal ITA No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita Nos.111 To 113/Rjt/2024 "नधा"रणवष" /Assessment Years: 2013-14 To 2015-16

TDS return etc. of the parties with whom alleged transactions made. (viii) On the basis of facts and circumstances, AO has correctly adopted the figures of G.P of Rs.2,40,30,182/- which is as per show cause notice. However, assessee was free to substantiate its claim with documentary evidences, which assessee failed even in response to draft assessment order

KRUPALU METALS P. LTD.,JAMNAGAR vs. THE NFAC CIT(A), DELHI, DELHI

In the result, assessee’s appeal ITA No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita Nos.111 To 113/Rjt/2024 "नधा"रणवष" /Assessment Years: 2013-14 To 2015-16

TDS return etc. of the parties with whom alleged transactions made. (viii) On the basis of facts and circumstances, AO has correctly adopted the figures of G.P of Rs.2,40,30,182/- which is as per show cause notice. However, assessee was free to substantiate its claim with documentary evidences, which assessee failed even in response to draft assessment order

KRUPALU METALS P. LTD.,JAMNAGAR vs. THE NFAC DELHI, DELHI

TDS return etc. of the parties with whom alleged\ntransactions made.\n(viii) On the basis of facts and circumstances, AO has correctly adopted\nthe figures of G.P of Rs.2,40,30,182/- which is as per show cause notice.\nHowever, assessee was free to substantiate its claim with documentary\nevidences, which assessee failed even in response to draft assessment

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

Unexplained Investment in Properties and Rent thereof as per KYC\ndocuments of Undisclosed Foreign Bank Account Rs.5,93,51,875/-\n(Rs.5,82,72,750/- + Rs.10,79,125/-).\n(vii). Deemed Rent of more than one property reflected in Balance sheet\nRs.1,80,000/-.\n(viii). Disallowance of payment of commission to Shri Rajesh Bhatt\nRs.3

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

Unexplained Investment in Properties and Rent thereof as per KYC\ndocuments of Undisclosed Foreign Bank Account Rs.5,93,51,875/-\n(Rs.5,82,72,750/- + Rs.10,79,125/-).\n(vii). Deemed Rent of more than one property reflected in Balance sheet\nRs.1,80,000/-.\n(viii). Disallowance of payment of commission to Shri Rajesh Bhatt\nRs.3

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

Unexplained Investment in Properties and Rent thereof as per KYC\ndocuments of Undisclosed Foreign Bank Account Rs.5,93,51,875/-\n(Rs.5,82,72,750/- + Rs.10,79,125/-).\n(vii). Deemed Rent of more than one property reflected in Balance sheet\nRs.1,80,000/-.\n(viii). Disallowance of payment of commission to Shri Rajesh Bhatt\nRs.3

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

Unexplained Investment in Properties and Rent thereof as per KYC\ndocuments of Undisclosed Foreign Bank Account Rs.5,93,51,875/-\n(Rs.5,82,72,750/- + Rs.10,79,125/-).\n(vii). Deemed Rent of more than one property reflected in Balance sheet -\nRs.1,80,000/-.\n(viii). Disallowance of payment of commission to Shri Rajesh Bhatt -\nRs.3

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

Unexplained Investment in Properties and Rent thereof as per KYC\ndocuments of Undisclosed Foreign Bank Account Rs.5,93,51,875/-\n(Rs.5,82,72,750/- + Rs.10,79,125/-).\n(vii). Deemed Rent of more than one property reflected in Balance sheet\nRs.1,80,000/-.\n(viii). Disallowance of payment of commission to Shri Rajesh Bhatt\nRs.3

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

Unexplained Investment in Properties and Rent thereof as per KYC\ndocuments of Undisclosed Foreign Bank Account Rs.5,93,51,875/-\n(Rs.5,82,72,750/- + Rs.10,79,125/-).\n(vii). Deemed Rent of more than one property reflected in Balance sheet\nRs.1,80,000/-.\n(viii). Disallowance of payment of commission to Shri Rajesh Bhatt\nRs.3

SHANTI DEVELOPERS,RAJKOT vs. DCIT, CIRCLE-1(1), RAJKOT, RAJKOT

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

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 827/Rjt/2024 ("नधा"रणवष"/Assessment Year: 2011-12) Shanti Developers The Dcit, Circle – 1(1), V-88, Opp. S.R.P. Quarter, 150Ft Ring Vs. Aayakar Bhavan, Nr. Race Course Road, Ghanteshwar, Jamnagar Road, Ring Road, Rajkot (Gujarat) – 360006 Rajkot (Gujarat) – 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abpfs2815R (अपीलाथ"/Appellant) (""यथ"/Respondent)

invested in the work in progress (WIP) was below Rs.20,000/-, to substantiate these facts, the assessee has submitted the relevant documents before the Bench, ( which were also submitted by the assessee before the lower authorities) vide page no.1, 2, 6 and 7 of the Paper-Book. That is, at the time of assessment proceeding, the assessee had provided

SHANTI DEVELOPERS,RAJKOT vs. ITO, WARD-1(2)(2), RAJKOT, RAJKOT

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

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 827/Rjt/2024 ("नधा"रणवष"/Assessment Year: 2011-12) Shanti Developers The Dcit, Circle – 1(1), V-88, Opp. S.R.P. Quarter, 150Ft Ring Vs. Aayakar Bhavan, Nr. Race Course Road, Ghanteshwar, Jamnagar Road, Ring Road, Rajkot (Gujarat) – 360006 Rajkot (Gujarat) – 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abpfs2815R (अपीलाथ"/Appellant) (""यथ"/Respondent)

invested in the work in progress (WIP) was below Rs.20,000/-, to substantiate these facts, the assessee has submitted the relevant documents before the Bench, ( which were also submitted by the assessee before the lower authorities) vide page no.1, 2, 6 and 7 of the Paper-Book. That is, at the time of assessment proceeding, the assessee had provided

THE DY. COMMR. OF INCOME TAX, CIR.-1(2), RAJKOT-GUJARAT vs. M/S RAMBOO PROLEN PVT. LTD.,, RAJKOT-GUJARAT

In the result, ground number 8 of the Department’s appeal is dismissed

unexplained/ unaccounted investment in stock. The appellant has declared higher stock in the books of account by 36.50 Lac and, therefore, no addition thereto is warranted. I.T.A No. 503/Rjt/2015 A.Y. 2005-06 Page No 8 Dy. CIT vs. M/s. Ramboo Prolen (I) Pvt. Ltd. Moreover, the books result declared by the appellant also shows improvement in terms

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

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

SHREE SAMARTH SWITCHGEAR AND TRANSMISSION PVT LTD,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR, JAMNAGAR

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

unexplained stock has been purchased. Accordingly, you have offered gross disclosure of amount of Rs.65,25,851/-, in the return of income filed for the year under consideration” 15.In response to the above show -cause notices, the assessee, submitted written submissions before the ld.Pr.CIT and explained, the issues raised by the ld. PCIT.About the stock difference in the valuation

SHREE SAMARTH ELECTRICALS PVT LTD,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

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

unexplained stock has been purchased. Accordingly, you have offered gross disclosure of amount of Rs.65,25,851/-, in the return of income filed for the year under consideration” 15.In response to the above show -cause notices, the assessee, submitted written submissions before the ld.Pr.CIT and explained, the issues raised by the ld. PCIT.About the stock difference in the valuation

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

investments and money\nor the value of articles not recorded in the books of account or the unexplained\nexpenditure may be deemed to be the income of the assessee. It follows that the\nmoment a satisfactory explanation is given about such nature and source by the\nassessee, than the source would stand disclosed and will, therefore, be known

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

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

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