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

bogus purchases and, moreover, values of opening stock/closing stock were not open for verification, authorities below were justified in rejecting books of account and making addition to assessee's income by adopting higher GP rate. 6.22 Hon'ble ITAT, Delhi in the case of JCIT Vs System Controls & Transformers (P.) Ltd. (2018) (89 taxmann.com 96 (Delhi Trib.) has upheld that

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

bogus purchases and, moreover, values of opening stock/closing stock were not open for verification, authorities below were justified in rejecting books of account and making addition to assessee's income by adopting higher GP rate. 6.22 Hon'ble ITAT, Delhi in the case of JCIT Vs System Controls & Transformers (P.) Ltd. (2018) (89 taxmann.com 96 (Delhi Trib.) has upheld that

PRAVINBHAI MOHANBHAI VADI,JAMNAGAR vs. PR. COMMISSIONER OF INCOME TAX, JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.102/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2021-22 Pravinbhai Mohanbhai Vadi The Pr. Commissioner Of बनाम Flat No.1, Prabhudeep Apartment Income Tax, Jamanagar. Air Force-2 Road Vs. Jamnagar. Pan : Agzpv6946P (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

bogus purchases, held as reasonable. Hence, the order passed by AO is neither erroneous nor prejudicial to the interest of revenue. 19. According to us, the present order of AO passed u/s 143(3) dated 26.12.2022 of the Act cannot be termed as erroneous since enquiry was, in fact, carried out by him on the issue on which

NARENDRAKUMAR BHANWERLAL NIMBAVAT HUF,GANDHIDHAM vs. DCIT, CC-1, RAJKOT, RAJKOT

In the result, all these appeals filed by the different assessees, are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrids Hearing) आयकरअपीलसं./Ita No.400/Rjt/2023 Assessment Year: (2021-22)

bogus purchases, unaccounted cash loans, unaccounted payments, unaccounted receipts etc.The assessing officer noted that seized documents containing name of the assessee are speaking documents and the seized page nos. A4-45, A8-180 are the invoices raised by Shamji Kangad& Co. (entity owned by the member of Neelkangh Group) in the name of the assessee on various dates during

MAHAVIR IMPEX,GANDHIDHAM vs. DCIT, CC-1, RAJKOT, RAJKOT

In the result, all these appeals filed by the different assessees, are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrids Hearing) आयकरअपीलसं./Ita No.400/Rjt/2023 Assessment Year: (2021-22)

bogus purchases, unaccounted cash loans, unaccounted payments, unaccounted receipts etc.The assessing officer noted that seized documents containing name of the assessee are speaking documents and the seized page nos. A4-45, A8-180 are the invoices raised by Shamji Kangad& Co. (entity owned by the member of Neelkangh Group) in the name of the assessee on various dates during

RISHABH STEEL SUPPLIER,GANDHIDHAM vs. DCIT, CC-1, RAJKOT, RAJKOT

In the result, all these appeals filed by the different assessees, are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrids Hearing) आयकरअपीलसं./Ita No.400/Rjt/2023 Assessment Year: (2021-22)

bogus purchases, unaccounted cash loans, unaccounted payments, unaccounted receipts etc.The assessing officer noted that seized documents containing name of the assessee are speaking documents and the seized page nos. A4-45, A8-180 are the invoices raised by Shamji Kangad& Co. (entity owned by the member of Neelkangh Group) in the name of the assessee on various dates during

SHRI RAMJI HAMIR VIRDA,GANDHIDHAM vs. THE DCIT, CENTRAL CIRCLE-1, RAJKOT

In the result, all these appeals filed by the different assessees, are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrids Hearing) आयकरअपीलसं./Ita No.400/Rjt/2023 Assessment Year: (2021-22)

bogus purchases, unaccounted cash loans, unaccounted payments, unaccounted receipts etc.The assessing officer noted that seized documents containing name of the assessee are speaking documents and the seized page nos. A4-45, A8-180 are the invoices raised by Shamji Kangad& Co. (entity owned by the member of Neelkangh Group) in the name of the assessee on various dates during

OSWAL AGRICOMM PRIVATE LIMITED,GANDHIDHAM vs. DCIT, CC-1, RAJKOT, RAJKOT

In the result, all these appeals filed by the different assessees, are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrids Hearing) आयकरअपीलसं./Ita No.400/Rjt/2023 Assessment Year: (2021-22)

bogus purchases, unaccounted cash loans, unaccounted payments, unaccounted receipts etc.The assessing officer noted that seized documents containing name of the assessee are speaking documents and the seized page nos. A4-45, A8-180 are the invoices raised by Shamji Kangad& Co. (entity owned by the member of Neelkangh Group) in the name of the assessee on various dates during

OSWAL PETROCHEM,GANDHIDHAM vs. DCIT, CC-1, RAJKOT, RAJKOT

In the result, all these appeals filed by the different assessees, are allowed for

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrids Hearing) आयकर अपीलसं./Ita No.400/Rjt/2023

bogus purchases, unaccounted cash loans, unaccounted payments, unaccounted receipts etc. The assessing officer noted that seized documents containing name of the assessee are speaking documents and the seized page nos. A4-45, A8-180 are the invoices raised by Shamji Kangad& Co. (entity owned by the member of Neelkangh Group) in the name of the assessee on various dates during

PRIYANSI CORPORATION,DIST RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

In the result, all these appeals filed by the different assessees, are allowed for

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrids Hearing) आयकर अपीलसं./Ita No.400/Rjt/2023

bogus purchases, unaccounted cash loans, unaccounted payments, unaccounted receipts etc. The assessing officer noted that seized documents containing name of the assessee are speaking documents and the seized page nos. A4-45, A8-180 are the invoices raised by Shamji Kangad& Co. (entity owned by the member of Neelkangh Group) in the name of the assessee on various dates during

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita Nos.111 To 113/Rjt/2024 निर्धारण वर्ष / Assessment Years: 2013-14 To 2015-16 Krupalu Metals Pvt. Ltd Income Tax Officer, बनाम / National Faceless Assessment Plot No..4345, Gidc, Phase- Vs. Centre, Delhi/Dcit, Circle-3, Iii, Udhyog Nagar, Jamnagar Jamnagar-361008 स्थायी लेखा सं/. जीआइआर सं/.Pan/Gir No.: Aadck6122 B (अपीलार्थी/Appellant) (प्रत्यर्थी / Respondent) निर्धारिती की ओर से/Assessee By : Shri Sarvesh Gohil, Ld. Ar राजस्व की ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Ld. Sr-Dr सुनवाई की तारीख /Date Of Hearing : 27/02/2025 घोषणा की तारीख/Date Of Pronouncement : 22/05/2025 Per Bench: आदेश / Order Captioned Three Appeals, Filed By The Assessee, Pertaining To

bogus purchases and, moreover, values of opening stock/closing stock were not open for verification, authorities below were justified in rejecting books of account and making addition to assessee's income by adopting higher GP rate. 6.22 Hon'ble ITAT, Delhi in the case of JCIT Vs System Controls & Transformers (P.) Ltd. (2018) (89 taxmann.com 96 (Delhi Trib.) has upheld that

ASSISTANT COMMISSIONER OF INCOME TAX, GANDHIDHAM vs. KAMLESH DEORAJ JAIN, GANDHIDHAM

In the result, the appeal of the Revenue is dismissed

Bench: Dr. Arjun Lal Saini, Am. & Dr. Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 594/Rjt/2025 "नधा"रणवष" / Assessment Year: (2017-18) (Hybrid Hearing) Assistant Commissioner Of Income Vs. Kamlesh Deoraj Jain, Tax, Bbz-N-108, Khanna Market, Plot No. 20/A, Sector No. 8, Gandhidham, Gandhidham Gandhidham Gujarat 370201 Gujarat 370201 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Adopj1769Q (Appellant) (Respondent) Appellant By : Shri Sunil Maloo, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 01 / 12 /2025 Date Of Pronouncement : 21/ 01 /2026

nature of transaction, pattern of documentation, and the treatment by the AO are identical for A.Ys. 2017-18 and 2018-19. In fact, the AO in both years made an addition of 12.5% on the very same premise i.e., bogus purchases which has already been struck down by the appellate authority. Disregarding a binding appellate precedent, particularly in the appellant

M/S. SIMERO VITRIFIED P. LTD. ,MORBI vs. THE PR. CIT-3 , RAJKOT

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

Bench: Us Is A Private Limited Company & Engaged In The Business Of Manufacturing Of Vitrified Tiles. The Return Of Income Has Been E-Filed By The Assessee, On 10/09/2016 For Assessment Year (A.Y.) 2016-17, Reporting Loss Of Rs. 5,68,00,829/-, Which Was Later Revised On 09/03/2018, Declaring Total Loss Of Rs. 13,97,40,413/-, Claiming Investment Allowance U/S 32Ac Of The Income Tax Act. The Case Has Been Selected For Complete Scrutiny (Cass) Specifically To Examine The Followings: 1) Whether Outward Foreign Remittance Is From Disclosed Sources & Appropriate Withholding & Reporting Obligation Have Been Complied With; 2) Whether Investment & Income Relating To Properties Are Duly Disclosed; 3) Whether Receipt Of Foreign Remittance Has Been Correctly Offered For Tax And, 4) Whether Sundry Creditors Are Genuine. 4. The Assessment Order U/S 143(3) For The Assessment Year (A.Y.) 2016-17 Was Passed By Dcit, Morbi Circle, Morbi, Being The Assessing Officer (Ao), On 21/12/2018, Allowing The Loss Claimed Of Rs. 13,97,40,413/- To Be Carry Forward To Subsequent Years. 2

bogus entries of name-lenders, has failed to conduct verifications/inquiries that should have been done and accepted the share capital as well as the unsecured loans as genuine. 8. The Ld.PCIT noticed that trade payables of Rs. 11,61,51,118/-,have been reported as on 31/03/2016. In this regard, the AO vide notice dated 18/07/2018

KAUSHALIYA SAMPATLAL DUDANI,JAMNAGAR vs. INCOME TAX OFFICER, WARD 2(6), JAMNAGAR

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./ Ita No.659/Rjt/2025 िनधा"रण वष"/Assessment Year :2012-2013 Kaushaliya Sampatlal Dudani The Ito, Ward-2(6), बनाम/ K-1/79/4 G.I.D.C., Shanker Ayakar Bhawan, Jamnagar Vs Tekri, Udyognagar, Jamnagar Jamnagar. Gujarart-361005 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Abnpd8662P (अपीलाथ"/Appellant) (""थ"/Respondent) िनधा"रती की ओर से/Assessee By : Shri Sagar Shah, Ld. Ar राज" की ओर से/Revenue By : Shri Abhimanyu Singh, Ld. Sr-Dr

natural justice because of which the assessee was adversely affected CIT vs. Mukesh RatilatMarolia (Bombay High Court) INCOME TAX APPEAL NO. 456 OF 200 7 7th September 2011 Long-term capital gains on sale of "penny" stocks cannot be treated as bogus & unexplained cash credit if the documentation is in order & there is no allegation of manipulation by SEBI

SAMEER SHAH (HUF),1 "SWAPNEEL" ,OPP. GURUDATATREY TEMPLE PALACE ROAD vs. INCOME TAX OFFICER, WARD 1(3), JAMNAGAR, GUJARAT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini. आयकरअपीलसं./Ita No.248/Rjt/2025 "नधा"रणवष" / Assessment Year: (2013-14) (Hybrid Hearing) Sameer Shah (Huf), Vs. The Ito Ward 1(3), 1 “Swapneel”, Opp. Jamnagar - 361001 Gurudatatrey Temple, Palace Road, Jamnagar - 361008 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aawhs3749E (Appellant) (Respondent)

natural justice, though the assessee has specifically prayed to grant an opportunity of heard and the same was not granted. Thus, the order is passed under the gross violation of maxim Audi Alteram Partem read with article 14 of the constitution and therefore, the order is liable to be quashed. 2. The order passed by the Ld. FAO as well

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

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

Bench: Dr. Arjunlal Saini & Shri Dinesh Mohan Sinhaआयकर अपीलसं./Ita No. 75/Rjt/2025 (निर्धारणवर्ष / Assessment Year: (2021-22) (Hybrid Hearing) Jay Prabhudas Vithlani 201, Varajresidency, 8 – Patel Colony, Gujarat-361008 Vs. The Principal Commissioner Of Income Tax, Aayakar Bhavan, Nr. Subhash Bridge, Jamnagar Rajkot Highway Gujarat-361001 स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abcpv0266A (Appellant) (Respondent) आयकर अपीलसं./Ita No.74/Rjt/2025 (निर्धारणवर्ष / Assessment Year: (2021-22) Khushaboo Jaykumar Vithlani 201, Varajresidency, 8 – Patel Colony, Gujarat-361008 Vs. The Principal Commissioner Of Income Tax, Aayakar Bhavan, Lal Wadi Main Road, Kaushal Nagar, Gujarat - 361110 स्थायी लेखासं . / जी आइआरसं . / Pan/Gir.: Aefpv6723A (Appellant) (Respondent) Appellant By Respondent By Date Of Hearing Date Of Pronouncement : Shri Sagar Shah, Ld. Ar : Shri Sanjay Kumar, Ld. Cit(Dr) : 19/06/2025 : 05/08/2025 आदेश / Order Per Dinesh Mohan Sinha, Jm: Captioned Two Appeals Filed By The Different Assessee, Pertaining To Assessment Year (Ay) – 2021-22, Are Directed Against The Separate Order Passed By The Principal Commissioner Of Income Tax [(In Short "Ld. Pr.Cit”] U/S. 263 Of The Act, Both Orders Dated 24.01.2025. 2. Since, These Two Appeals Filed By The Different Assessee For Same

purchased, Screen shot reflecting return filing frequency of the supplier and proof that transaction is reported in 2A of the appellant which subsequently proved that suppliers have filed their GSTR-1 and also paid tax in their GSTR-3B. Ld. PCIT has considered no value of all this documentary evidences and merely stated that suppliers are bogus. 6. Based

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)

purchased, Screen shot reflecting return filing frequency of the supplier and proof that transaction is reported in 2A of the appellant which subsequently proved that suppliers have filed their GSTR-1 and also paid tax in their GSTR-3B. Ld. PCIT has considered no value of all this documentary evidences and merely stated that suppliers are bogus. 6. Based

NISHANT PAREKH - LEGAL HEIR OF MINA PAREKH,JAMNAGAR vs. INCOME TAX OFFICER, WARD 1(3), JAMNAGAR

The appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 196/Rjt/2025 ("नधा"रणवष"/Assessment Year: (2012-13) Nishant Parekh – Legak Heir Of Mina Income Tax Officer, Wd – 1(3), Parekh Vs. Aayakar Bhavan, 322, Madhav Square, Opp. Avantika Jamnagar – 361001 Complex, Limda Lane Road, Jamnagar – 361001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aanpp9471F (अपीलाथ"/Assessee) (""यथ"/Respondent)

nature. However, to meet the end of justice, we confine ourselves to the core of the controversy and main grievances of the Assessee. With this background, we summarize and concise the grounds raised by the Assessee, as follows: (i) The order passed by the Ld. Fassessing officer as well as order passed by National Faceless Appeal Centre under Section

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

justice, we confine ourselves to the core of the controversy and main grievances of Revenue and the Assessee as well. With this background, we summarize and concise the grounds raised by the Revenue as well as Assessee as follows: (i) Ground No.1. The ld. CIT(A) has erred in law and on facts in deleting the addition made on account