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

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

u/s. 147 of the Act vide order dated 07/05/2021. 3.3. On further verification, as per information from ITO (CIB)-1, Mumbai, it is noticed that out of nine assessees, who had taken bogus long term capital gains from penny stock Karma Ispat, addition was made in six cases. No addition was made in three cases, out of which one case

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

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

u/s. 147 of the Act vide order dated 07/05/2021. 3.3. On further verification, as per information from ITO (CIB)-1, Mumbai, it is noticed that out of nine assessees, who had taken bogus long term capital gains from penny stock Karma Ispat, addition was made in six cases. No addition was made in three cases, out of which one case

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

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

u/s. 147 of the Act vide order dated 07/05/2021. 3.3. On further verification, as per information from ITO (CIB)-1, Mumbai, it is noticed that out of nine assessees, who had taken bogus long term capital gains from penny stock Karma Ispat, addition was made in six cases. No addition was made in three cases, out of which one case

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

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

u/s. 147 of the Act vide order dated 07/05/2021. 3.3. On further verification, as per information from ITO (CIB)-1, Mumbai, it is noticed that out of nine assessees, who had taken bogus long term capital gains from penny stock Karma Ispat, addition was made in six cases. No addition was made in three cases, out of which one case

GLOBAL EXTRUSIONS PVT. LTD. ,JAMNAGAR vs. THE PR. CIT, JAMNAGAR, JAMNAGAR

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.203/Rjt/2024 "नधा"रणवष" / Assessment Year: (2013-14) (Hybrid Hearing) Global Extrusions Private Limited. Vs. Pcit Jamnagar, Ca Govind Sonecha Taranjali Building, “S&A House”, Near Golden City, Jamnagar 361008 80Ft Road, Khodiyar Colony, B/H Saru Section Police Headquarters, Jamnagar 361006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabcm4319E (Appellant) (Respondent) Appellant By : Ms. Amoli Gusani, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. (Cit)Dr Date Of Hearing : 19/03 /2025 Date Of Pronouncement : 09/06/2025

revise the assessment order. 5. Being aggrieved by the above order of the Ld. PCIT u/s. 263 dated 09.02.2024 of the Act, the appellant has filed this appeal before us. Global extrusions pvt. Ltd. 6. During the course of hearing the Ld. AR has submitted that a notice issued on account bogus purchase

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

revision order from page no.2 to 5. 5. In response to the notice of the ld. Pr. CIT, the assessee submitted its written submissions before the ld. Pr. CIT, along with documentary evidences. The assessee submitted that various notices issued by the AO in the course of assessment proceedings, to enquiry the issue, which are as follows: (a). Notice u/s.142

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

In the result, appeal of the assessee is allowed

bogus purchases and made addition of " 76,86,510/- disallowing 30% of the purchase of " 2,53,99,953/- since no TCS was collected on the same. However, as per the Principal CIT, the entire purchase amounting to " 2,53,99,953/- should have been treated as un-expenditure in the nature of unverifiable purchases and the total amount

BHARATKUMAR KALYANJIBHAI BHINDI,JUNAGADH vs. PCIT, RAJKOT-1, RAJKOT , RAJKOT

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhasr. No. 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 324/Rjt/2024 322/Rjt/2024 323/Rjt/2024 312/Rjt/2024 326/Rjt/2024 327/Rjt/2024 329/Rjt/2024 331/Rjt/2024 335/Rjt/2024 371/Rjt/2024

bogus expenses to the tune of Rs.90,00,000/-, ought to have taxed, as deemed income u/s 69C of the Act, and taxed u/s 115BBE of the Income Tax Act. However, the assessing officer failed to do the same. Therefore, learned PCIT noticed that order passed by the assessing officer is without proper inquiry and investigation, which is erroneous

KISHOR VELJIBHAI FOFANDI,VERAVAL vs. PR. CIT, RAJKOT-1, RAJKOT, RAJKOT

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

bogus expenses to the tune of Rs.90,00,000/-, ought to have taxed, as deemed income u/s 69C of the Act, and taxed u/s 115BBE of the Income Tax Act. However, the assessing officer failed to do the same. Therefore, learned PCIT noticed that order passed by the assessing officer is without proper inquiry and investigation, which is erroneous

DEEPMALA MARINE EXPORTS,VERAVAL vs. PR. CIT, RAJKOT-1, RAJKOT, RAJKOT

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

bogus expenses to the tune of Rs.90,00,000/-, ought to have taxed, as deemed income u/s 69C of the Act, and taxed u/s 115BBE of the Income Tax Act. However, the assessing officer failed to do the same. Therefore, learned PCIT noticed that order passed by the assessing officer is without proper inquiry and investigation, which is erroneous

CHUNILAL GOVIND VANIK,VERAVAL vs. PR. CIT, RAJKOT-1, RAJKOT, RAJKOT

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

bogus expenses to the tune of Rs.90,00,000/-, ought to have taxed, as deemed income u/s 69C of the Act, and taxed u/s 115BBE of the Income Tax Act. However, the assessing officer failed to do the same. Therefore, learned PCIT noticed that order passed by the assessing officer is without proper inquiry and investigation, which is erroneous

SOHAM PAPERS PRIVATE LIMITED,MORBI vs. PR. CIT, RAJKOT-1, RAJKOT, RAJKOT

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

bogus expenses to the tune of Rs.90,00,000/-, ought to have taxed, as deemed income u/s 69C of the Act, and taxed u/s 115BBE of the Income Tax Act. However, the assessing officer failed to do the same. Therefore, learned PCIT noticed that order passed by the assessing officer is without proper inquiry and investigation, which is erroneous

SHAMJI NATHU VAISHYA,VERAVAL vs. PR. CIT, RAJKOT-1, RAJKOT, RAJKOT

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

bogus expenses to the tune of Rs.90,00,000/-, ought to have taxed, as deemed income u/s 69C of the Act, and taxed u/s 115BBE of the Income Tax Act. However, the assessing officer failed to do the same. Therefore, learned PCIT noticed that order passed by the assessing officer is without proper inquiry and investigation, which is erroneous

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

263 of the Act was issued to the assessee on 04/12/2024, requesting an explanation as to why the assessment order u/s 143(3) rws 144B of the Act dated 24/12/2022 should not be revised, which are as under: "Please refer to the above 2 In this case, it is observed that Return of Income for the AY under consideration

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)

263 of the Act was issued to the assessee on 04/12/2024, requesting an explanation as to why the assessment order u/s 143(3) rws 144B of the Act dated 24/12/2022 should not be revised, which are as under: "Please refer to the above 2 In this case, it is observed that Return of Income for the AY under consideration

HANSA JITENDRA HARIA,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, the appeal of the assessee is dismissed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.104/Rjt/2024 ("नधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Hansa Jitendra Haria Vs. Principal Commissioner Of 2, Oswal Colony, Near Rajendra Income Tax Balkrindagan, Jamnagar, Gujarat Jamnagar 361005. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahph4309L (Assessee) (Respondent)

revision proceedings initiated by the learned PCIT under section 263 of the Act may be quashed. 14. On the other hand, Ld. DR for the Revenue argued that the PCIT has passed a speaking order u/s 263 after considering the submission of the assessee made during 263 proceedings. In the order he has given elaborate findings regarding the failure made

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

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 and appropriate withholding and reporting obligation have been complied with; 2) Whether investment and income

KETAN GORI,JAMNAGAR vs. INCOME TAX OFFICER, WARD 2(10), JAMNAGAR

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.42/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2021-22 Ketan Gori The Pr.Cit बनाम Plot No.3009 Jamnagar. Gidc Phase-Iii Vs. Dared. Pan : Ahppg 5892 A (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Sagar Shah, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

263 of the Act. 6. In response to the notice of the ld. Pr. CIT, the assessee submitted its written submissions along with documentary evidences, which are reproduced by the ld. Pr. CIT in the revision order. The assessee submitted before the learned PCIT that revision proceeding are mere change of opinion and without bringing anything new on the record

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

bogus and were likely used to accommodate unaccounted 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