M/S. PREMJI VALJI & SONS (JEWELLERS) P. LTD.,RAJKOT vs. THE DCIT, CIRCLE - 2 (1), RAJKOT, RAJKOT

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

Bench: Ms Suchitra Kamble & Shri Waseem Ahmed, Accountant, Judic Member आयकरअपीलसं./Ita Nos.257 & 223/Rjt/2022 निर्धररवरध/Asstt. Years: 2010-11 & 2012-13 M/S Premji Valji & Sons D.C.I.T, (Jewellers) Pvt. Ltd. Vs. Circle-2(1), “Kuvarjibhai Tower” Rakot. Palace Road, Rajkot-360001. Pan: Aaccp2555N

bogus purchases amounting to Rs. 11,99,268/- which cannot be allowed as deduction u/s 37(1) of the Act. Thus

M/S. PREMJI VALJI & SONS (JEWELLERS) P. LTD.,RAJKOT vs. THE DCIT, CIRCLE - 2 (1), RAJKOT, RAJKOT

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

Bench: Shri Waseem Ahmed (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

bogus purchases amounting to Rs. 56,77,000/- which cannot be allowed as deduction u/s 37(1) of the Act. Thus

THE ACIT, CEN. CIR.-2, RAJKOT, RAJKOT vs. EXPERT PARTICLE BOARD, MORBI

In the result, cross objection filed by the assessee, ( in CO No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.139/Rjt/2021 िनधा"रणवष"/ Assessment Year: 2019-2020 Asstt.Commissioner Of Income-Tax Expert Particle Board बनाम Cent.Cir.2, Rajkot. Survey No.111, 8-A National Vs. Highway B/H. Bharatinagar Iti, Ravapar Nadi Morbi 363 642. Pan : Aahfe 0299 G आयकर अपील सं /.Ita No.142/Rjt/2021 With Cross Objection No.05/Rjt/2022 िनधा"रणवष"/ Assessment Year: 2019-2020 Asstt.Commissioner Of Income-Tax Bhagvaji Prabhubhai बनाम Cent.Cir.2, Rajkot. Amrutiya, Meera Park-2 Vs. House No.1, Vavdi Road Morbi. Pan : Aiwpa 0121 A (अपीलाथ"/Assessee) : (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr सुनवाई क" तार"ख /Date Of Hearing : 05/06/2025 घोषणा क" तार"ख /Date Of Pronouncement : 29/08/2025 Order Per, Dr. Arjun Lal Saini: The Captioned Two Appeals Filed By The Revenue Pertaining To Assessment Year 2019-20 & The Cross Objection Filed By The Assessee, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income-Tax

deduction is allowed. (i)Addition of Rs. 1,48,89,125/-, u/s. 69B of the Act, as amount of investment not disclosed in the books of account. (ii)Addition of Rs. 6,77,34,130/-, on account of unexplained receipt of cash u/s. 69A of the Act. (iii)Addition of Rs. 54,04,130/- on account of bogus purchase

THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT vs. SHRI BHAGVANJI PRABHUBHAI AMRUTIYA, MORBI

In the result, cross objection filed by the assessee, ( in CO No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.139/Rjt/2021 िनधा"रणवष"/ Assessment Year: 2019-2020 Asstt.Commissioner Of Income-Tax Expert Particle Board बनाम Cent.Cir.2, Rajkot. Survey No.111, 8-A National Vs. Highway B/H. Bharatinagar Iti, Ravapar Nadi Morbi 363 642. Pan : Aahfe 0299 G आयकर अपील सं /.Ita No.142/Rjt/2021 With Cross Objection No.05/Rjt/2022 िनधा"रणवष"/ Assessment Year: 2019-2020 Asstt.Commissioner Of Income-Tax Bhagvaji Prabhubhai बनाम Cent.Cir.2, Rajkot. Amrutiya, Meera Park-2 Vs. House No.1, Vavdi Road Morbi. Pan : Aiwpa 0121 A (अपीलाथ"/Assessee) : (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr सुनवाई क" तार"ख /Date Of Hearing : 05/06/2025 घोषणा क" तार"ख /Date Of Pronouncement : 29/08/2025 Order Per, Dr. Arjun Lal Saini: The Captioned Two Appeals Filed By The Revenue Pertaining To Assessment Year 2019-20 & The Cross Objection Filed By The Assessee, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income-Tax

deduction is allowed. (i)Addition of Rs. 1,48,89,125/-, u/s. 69B of the Act, as amount of investment not disclosed in the books of account. (ii)Addition of Rs. 6,77,34,130/-, on account of unexplained receipt of cash u/s. 69A of the Act. (iii)Addition of Rs. 54,04,130/- on account of bogus purchase

M/S. R M TRADELINK,RAJKOT vs. THE PR. CIT-1, RAJKOT, RAJKOT

In the result, appeal of the assessee is allowed

deducted on the purchase of " I.T.A No. 68/Rjt/2022 A.Y. 2018-19 Page No 3 M/s. R.M. Tradelink vs. Pr. CIT- 1 2,53,99,953/- under section 206C of the Act. The AO disallowed 30% of " 2,53,99,953/- i.e." 76,86,510/- u/s. 40(a)(ia) of the Act. 4. Subsequently, Principal CIT initiated 263 proceedings

THE ITO, WARD-3(2),, JAMNAGAR vs. SHRI RAJESH GULABRAI SHAYANI,, JAM-KHAMBHALIA

In the result, the appeal of the Revenue is dismissed

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

bogus purchases from-the aforesaid parties which are engaged in billing activities. The purchases of Rs. l0,08,76,757/-is therefore unexplained. In view of the above facts, no deduction

THE DY. COMMR. OF INCOME TAX, CIR.-2,, JAMNAGAR vs. ADITYA COKE PRIVATE LIMITED,, BHACHAU - KUTCH

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No. 554/Rjt/2015 िनधा"रण वष"/Asstt. Years: 2012-2013 D.C.I.T., Aditya Coke Private Limited, Circle-2, Vs. Survey No.14, Jamnagar Village Chopadva, Tal. Bhachai, Dist. Kutch, (Gujarat)

bogus. However, the assessee was allowed deduction on account of purchases from these bogus parties in earlier year. 10.10 Even

KHUSHBOO JAYKUMAR VITHLANI,JAMNAGAR vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR, JAMNAGAR

In the result, both the appeals of the same assessee (ITA No

Bench: Dr. Arjunlal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 75/Rjt/2025 ("नधा"रणवष" / Assessment Year: (2021-22) (Hybrid Hearing) Jay Prabhudasvithlani Vs. The Principal Commissioner Of 201, Varajresidency, 8 – Patel Colony, Income Tax, Gujarat – 361008 Aayakar Bhavan, Nr. Subhash Bridge, Jamnagar Rajkot Highway Gujarat – 361001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abcpv0266A (Appellant) (Respondent)

bogus and have remained unverified. The AO should have verified such transactions in details particularly when the core reason of selection of case for assessment is to verify the geniuses of purchases. However, it is seen that AO allowed the claim of purchase without any verification.” 6. In response to the Show cause notice issued

JAY PRABHUDAS VITHALANI,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, both the appeals of the same assessee (ITA No

bogus and have remained unverified. The AO\nshould have verified such transactions in details particularly when the\ncore reason of selection of case for assessment is to verify the geniuses of\npurchases. However, it is seen that AO allowed the claim of purchase\nwithout any verification.\n6. In response to the Show cause notice issued

JAYESH KHIMJI KHIMASIYA HUF,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

deduction u/s 10(38) of the Act, is treated as bogus long term capital gain u/s 45 of the Act and Mansukhlal khimji and others v. PCIT ITA No.3,4,5,6/Rjt/2024 AY.2012-13 & 2013-14 is added back to the total income kor the year consideration. Penalty proceedings u/s. 270A(9)(a) r.w.s. 270A(8) for underreporting in consequence

BHANUBEN MANSUKHLAL KHIMASIYA,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

deduction u/s 10(38) of the Act, is treated as bogus long term capital gain u/s 45 of the Act and Mansukhlal khimji and others v. PCIT ITA No.3,4,5,6/Rjt/2024 AY.2012-13 & 2013-14 is added back to the total income kor the year consideration. Penalty proceedings u/s. 270A(9)(a) r.w.s. 270A(8) for underreporting in consequence

MANSUKHLAL KHIMJI KHIMASIYA,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

deduction u/s 10(38) of the Act, is treated as bogus long term capital gain u/s 45 of the Act and Mansukhlal khimji and others v. PCIT ITA No.3,4,5,6/Rjt/2024 AY.2012-13 & 2013-14 is added back to the total income kor the year consideration. Penalty proceedings u/s. 270A(9)(a) r.w.s. 270A(8) for underreporting in consequence

MANSUKHLAL KHIMJI KHIMASIYA HUF,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

deduction u/s 10(38) of the Act, is treated as bogus long term capital gain u/s 45 of the Act and Mansukhlal khimji and others v. PCIT ITA No.3,4,5,6/Rjt/2024 AY.2012-13 & 2013-14 is added back to the total income kor the year consideration. Penalty proceedings u/s. 270A(9)(a) r.w.s. 270A(8) for underreporting in consequence

M/S MGM TRADELINK PVT. LTD.,,GANDHIDHAM vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM

In the result, the appeal of the assessee is partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedआयकर अपील सं./Ita No. 974/Rjt/2010 िनधा"रण वष"/Asstt. Year: 2005-2006

purchases cannot be disallowed believing them as bogus. Once the sale has Asstt. Year 2005-06 7 been accepted, then the assessee deserves for the deduction

SMT. GRACY KUTHUMKAL THOMAS,,VERAVAL vs. THE JOINT COMMISSIONER OF INCOME TAX, JUNAGADH RANGE-1,, JUNAGADH

In the result, appeals of the Revenue and assessee, both are dismissed

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

bogus purchases, expenses and unrecorded sales and instances of excess stock or other such specific irregularity is detected. A particular expenditure may be disallowable as per I.T. Act if it is capital in nature and not for the purpose of business, however, if it is correctly recorded in books of account, the books of account cannot be rejected

THE DEPUTY COMISSIONER OF INCOME TAX, CIRCLE-1,, JUNAGADH vs. SMT. GRACY KUTHUKMAL THOMAS,, VERAVAL

In the result, appeals of the Revenue and assessee, both are dismissed

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

bogus purchases, expenses and unrecorded sales and instances of excess stock or other such specific irregularity is detected. A particular expenditure may be disallowable as per I.T. Act if it is capital in nature and not for the purpose of business, however, if it is correctly recorded in books of account, the books of account cannot be rejected

SHRI SHAMJIBHAI SADHABHAI KANGAD,GANDHIDHAM-KUTCH vs. THE DCIT CENTRAL CIRCLE-1 , RAJKOT

bogus purchase is\ncompletely illogical. The averments made by Shri Naran Maheshwari in his\nstatement was clarified by him in his duly sworn affidavit. Here it is relevant to\nemphasise that salt procurement and manufacturing industries by and large are\ndriven by the unorganised and unskilled labourers / agents and village people,\nstaying remotely in desert or forest there for they

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

deducting the G.P. of Rs.44,25,901/-from the total unaccounted sales of Rs. 1,77,03,604/-, as the unaccounted investment in business towards the purchase of raw material and subsequent manufacturing expenditure on unaccounted raw material u/s 69 of the Act. Accordingly, an addition of Rs. 1,32,77,703/- is made to the total income

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

deducting the G.P. of Rs.44,25,901/-from the total unaccounted sales of Rs. 1,77,03,604/-, as the unaccounted investment in business towards the purchase of raw material and subsequent manufacturing expenditure on unaccounted raw material u/s 69 of the Act. Accordingly, an addition of Rs. 1,32,77,703/- is made to the total income