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

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

unexplained money u/s. 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

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

TDS) credit allowed (Rs. 3,41,378/- Hence, the charging of interest under Section 2348 is illegal, notwithstanding its consequential nature. 9. Leave to Add/Amend: The Appellant craves leave to add, amend, alter, or delete any of the above Grounds of Appeal at any time before or during the hearing of this appeal. 3. That the Ld. Council

ACIT, CIRCLE-1(1), RAJKOT vs. SUNSHINE TILES COMPANY PVT. LTD., MORBI

In the result, appeal filed by the revenue is dismissed

Bench: Dr. Arjun Lal Saini. & Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 649 /Rjt/2024 ("नधा"रण वष"/Assessment Year: (2011-12) Asstt. Commissioner Of Income Sunshine Tiles Company Pvt. Tax, Cir-1(1), Rajkot Ltd. Vs. Room No. 502, Aayakar Bhavan, S. No. 150 160/P1, B/H Sunhil Race Course Ring Road, Ceramics 8-A, National Highway, Rajkot – 360001 Rajkot – 360001 [Pan No.: Aancs3264L] (अपीलाथ"/Appellant) (""यथ"/Respondent)

money to the assessee and source in the hands of the depositor has not proved. Since, as per the assessing officer the assessee has failed to prove satisfactorily the creditworthiness of the said person, the amount credited in the books of accounts have to be treated as unexplained cash credit u/s. 68 of the Act. Therefore, the unsecured loans received

JABIR AYOOB VAHEVARIA,JAMNAGAR vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR, JAMNAGAR

In the result, assessee’s appeal ITA No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita Nos.26/Rjt/2025 िनधा"रणवष"/Assessment Year : 2021-22 Jabir Ayoob Vahevaria Principal Commissioner Of बनाम Plot No.3452 Gidc 3, Dared Income-Tax, Jamnagar, Jamnagar-361 004 ( Gujarat) Vs. Room No.101, 1St Floor, Aaykar Bhavan, Nr. Shubhas Bridge, Jamnagar-361 001 /. /. Pan/Gir No.:Aeqpv3027C "थायीलेखासं जीआइआरसं (अपीलाथ"/Appellant) .. (""यथ"/Respondent) आयकरअपीलसं/.Ita Nos.27/Rjt/2025 िनधा"रणवष"/Assessment Year : 2021-22 Altaf Ayoobbhai Vehvaria, Principal Commissioner Of बनाम Prop. Of K A Enterprise, Ground Income-Tax, Floor, Near Alamin Park, Vs. Jamnagar, Room No.101, 1St Vehwaria Madresa, Jamnagar- 361 004 Floor, Aaykar Bhavan, Nr. Shubhas Bridge, Jamnagar-361 001 /. /. Pan/Gir No.: Aempv7317M "थायीलेखासं जीआइआरसं (अपीलाथ"/Appellant) .. (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Cit- Dr

money. Thus, purchases from these entities should have been disallowed and treated, as unexplained expenditure u/s 69C r.w.s. 155BBE of the Act. The ld.PCIT observed that assessing officer failed to conduct any verification or inquiry to ascertain the genuineness of these transactions, despite it being the primary reason for scrutiny selection. 6. Considering the above facts, the Ld. PCIT issued

ALTAF AYOOBBHAI VEHVARIA,JAMNAGAR vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR, JAMNAGAR

In the result, assessee’s appeal ITA No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita Nos.26/Rjt/2025 िनधा"रणवष"/Assessment Year : 2021-22 Jabir Ayoob Vahevaria Principal Commissioner Of बनाम Plot No.3452 Gidc 3, Dared Income-Tax, Jamnagar, Jamnagar-361 004 ( Gujarat) Vs. Room No.101, 1St Floor, Aaykar Bhavan, Nr. Shubhas Bridge, Jamnagar-361 001 /. /. Pan/Gir No.:Aeqpv3027C "थायीलेखासं जीआइआरसं (अपीलाथ"/Appellant) .. (""यथ"/Respondent) आयकरअपीलसं/.Ita Nos.27/Rjt/2025 िनधा"रणवष"/Assessment Year : 2021-22 Altaf Ayoobbhai Vehvaria, Principal Commissioner Of बनाम Prop. Of K A Enterprise, Ground Income-Tax, Floor, Near Alamin Park, Vs. Jamnagar, Room No.101, 1St Vehwaria Madresa, Jamnagar- 361 004 Floor, Aaykar Bhavan, Nr. Shubhas Bridge, Jamnagar-361 001 /. /. Pan/Gir No.: Aempv7317M "थायीलेखासं जीआइआरसं (अपीलाथ"/Appellant) .. (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Cit- Dr

money. Thus, purchases from these entities should have been disallowed and treated, as unexplained expenditure u/s 69C r.w.s. 155BBE of the Act. The ld.PCIT observed that assessing officer failed to conduct any verification or inquiry to ascertain the genuineness of these transactions, despite it being the primary reason for scrutiny selection. 6. Considering the above facts, the Ld. PCIT issued

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)

money or the value of articles not recorded in the books of account or the unexplained expenditure may be deemed to be the income of the assessee. It follows that the moment a satisfactory explanation is given about such nature and source by the assessee, than the source would stand disclosed and will, therefore, be known and the income would

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)

money or the value of articles not recorded in the books of account or the unexplained expenditure may be deemed to be the income of the assessee. It follows that the moment a satisfactory explanation is given about such nature and source by the assessee, than the source would stand disclosed and will, therefore, be known and the income would

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

money or the value of articles not recorded in the books of account or the unexplained expenditure may be deemed to be the income of the assessee. It follows that the moment a satisfactory explanation is given about such nature and source by the assessee, than the source would stand disclosed and will, therefore, be known and the income would

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

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 and the\nincome would

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

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

money or the value of articles not recorded in the books of account or the unexplained expenditure may be deemed to be the income of the assessee. It follows that the moment a satisfactory explanation is given about such nature and source by the assessee, than the source would stand disclosed and will, therefore, be known and the income would

H J ENTERPRISE,RAJKOT vs. ACIT, CIRCLE-1(1), RAJKOT, RAJKOT

In the result, the appeal of the assessee is partly allowed, in above terms

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

TDS of ₹3,654/-was deducted. (Page 15 in Paper-Book) The AO found that in the original assessment transaction as genuine and accepted the income declared in return with minor disallowances out of the interest payment. That the fact as stated above. Shri Prakash S. Bagrecha the Director of Bhoomidey Credit Corporation Ltd. vide his affidavit executed

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)

money" received and which was disclosed during the survey, was accepted by the AO without making inquiries or verification which should have been made. The, Pr.CIT-1, Rajkot observed that the order passed by the AO was erroneous and prejudicial to the interest of the revenue. 6. Accordingly, in order to pass an appeal effect order, under section

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)

money" received and which was disclosed during the survey, was accepted by the AO without making inquiries or verification which should have been made. The, Pr.CIT-1, Rajkot observed that the order passed by the AO was erroneous and prejudicial to the interest of the revenue. 6. Accordingly, in order to pass an appeal effect order, under section

DAWN CHEMICALS,RAJKOT vs. ACIT, CIRCLE-2(1), RAJKOT, RAJKOT

The appeal of the assessee is allowed for statistical purpose

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

money into books of account by taking the shade of unsecured loan, and added the unsecured loan in the total income of appellant u/s.68 of the Act. AO alleged that appellant had paid commission expenses for securing unsecured loan at @1.5% on total amount of Rs. 11,00,000/- and added to Rs. 16,500/- in the appellant's total

DEPUTY COMMIOSSIONER OF INCOMETAX, JAMNAGAR vs. VASANTBHAI MULJIBHAI KANANI, JAMNAGAR

In the result, appeal filed by the revenue is dismissed, whereas appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.124/Rjt/2025 िनधा"रणवष"/ Assessment Year: 2022-23 Dy. Cit, Cir-1 Vasantbhai Muljibhai Kanani बनाम Jamnagar. Plot No.7, Ambica Enterprise Vs. Sardar Patel Ind. Estte-4 Indira Road Opp: Jakat Naka, Jamnagar-361004 (Guj) Pan : Aitpk 8038 P आयकर अपील सं /.Ita No.08/Rjt/2025 िनधा"रणवष"/ Assessment Year: 2022-23 Vasantbhai Muljibhai Kanani Dy. Cit, Cir-1 बनाम Plot No.7, Ambica Enterprise Jamnagar. Sardar Patel Ind. Estte-4 Vs. Indira Road Opp: Jakat Naka, Jamnagar- 361004 (Guj) Pan : Aitpk 8038 P (अपीलाथ"/Assessee) : (""यथ"/Respondent)

money. The fact is being part of the submission, however the same is not considered in passing the assessment and appellate order while making addition u/s 68 of the Act 3. Based on the facts and circumstance of the case the order passed by the Id. CIT(A) and Ld. assessing officer has erred in law as well

PARSHWA PRINT PACK PVT. LTD.,,WADHWAN vs. THE ASSISTANT COMMR. INCOME TAX, SURENDRANAGAR CIRCLE,, SURENDRANAGAR

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

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmed

unexplained cash credit to the tune of Rs. 21 lakhs. 4) The CIT(A) erred in law as well as on facts in upholding the order of the AO were by AO has disallowed the interest paid on the amounts borrowed to the tune of Rs.2,52,000/- without even referring to the provision of the section

PARSHWA PRINT PACK PVT. LTD.,,WADHWAN vs. THE ASSISTANT COMMR. INCOME TAX, SURENDRANAGAR CIRCLE,, SURENDRANAGAR

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

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmed

unexplained cash credit to the tune of Rs. 21 lakhs. 4) The CIT(A) erred in law as well as on facts in upholding the order of the AO were by AO has disallowed the interest paid on the amounts borrowed to the tune of Rs.2,52,000/- without even referring to the provision of the section