M/S. GREEN EARTH BIOGAS PVT. LTD.,SURENDRANAGAR vs. THE PR. CIT-3, AHMEDABAD, AHMEDABAD

In the result, appeal filed by the assessee is dismissed

purchase of Plant & Machinery.\nThis credit amount requires to be added u/s 68 being unaccounted money\nintroduced in the books of account in the garb of cash sales. It is quite\nevident from the details available on record that the then assessing officer\nfailed to examine this issue and failed to make required addition by\ncarrying out proper investigation

SHRI KAMLESH DEORAJ JAIN,GANDHIDHAM KUTCHH vs. THE ITO WARD 1 , GANDHIDHAM

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 62/Rjt/2025 ("नधा"रण वष"/Assessment Year: (2018-19) Kamlesh Deoraj Jain Income Tax Officer, Ward-1, Plot No 35-36, Devashish Gandhidham, Income Tax Vs. Sector-5 Gandhidham 370201 Office, Plot No.32, Sector No.3, Near Iffco Colony, Gandhidham-370 201 "ायी लेखा सं./जीआइआरसं./Pan/Gir No.: Adopj1769Q (अपीलाथ"/Appellant) (""थ"/Respondent)

bogus purchases are present, as the assessee has furnished extensive documentary evidence comprises of total 1414 pages to substantiate the genuine purchase transactions, including quantitative details, goods movement, further sale transaction and profit thereon, confirmation from seller party, banking payments etc, clearly justifying that actual purchase transactions have been occurred. 18. In the assessee`s case under consideration

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

1. Firstly, we would like to draw your kind attention to the fact that your honour has mentioned our purchase from parties mentioned as bogus purchase and we specifically oppose your this allegation, Our complete Pravinbhai Mohanbhai Vadi ITA No.102 /RJT/2025 12 purchase made by us is duly accepted by GST department for which we have attached herewith chart

THE INCOME TAX OFFICER, WARD-4,, MORBI vs. M/S. RANG CERA COAT, , MORBI

The appeal of the Revenue is dismissed

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumar"नधा"रणवष"/Assessment Year: 2011-12 Income Tax Officer, Vs. M/S. Rang Cera Coat, Ward-4, 8-A, National Highway, Morbi Morbi Pan :Aalfr 1616 A अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Revenue By : Shri B.D. Gupta, Sr. Dr Assessee By : Shri Vimal Desai, Ar सुनवाई क" तार"ख/Date Of Hearing : 14.11.2022 घोषणा क" तार"ख /Date Of Pronouncement: 25.01.2023

1,87,63,920/- to Rs.9,38,196/-on account of bogus purchase made by the assessee without appreciating the fact that the seller has itself admitted to have indulged in providing bogus bills. 2. On the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in granting relief even after accepting that

SUN EXPORTS,VERAVAL vs. PR. CIT, RAJKOT-1, RAJKOT, RAJKOT

purchase\nand sales made by him, during the year under consideration. Such\nexplanation of the assessee, which is not backed by any corroborative\nevidence, was not accepted by ld PCIT. The ld PCIT also noticed that\nmerely saying that the noting in the note book were unaccounted\npurchase and sales made by him during the year under consideration is\nnot

THE DCIT, CIRCLE-1 (1), , RAJKOT vs. M/S. DHRUV CRAFT MILL PVT. LTD., VILLAGE: - LILAPAR, TAL. & DIST. MORBI,

In the result, both the appeals filed by the Revenue are hereby dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 69 of the Income-tax Act, 1961 Undisclosed investments [Bogus purchases] - Assessment year 2005-06- Assessee was engaged in business of trading in finished fabrics - Assessing Officer found that concerned parties from whom material was purchased were not found at their addresses and held that purchases made by assessee were bogus Accordingly, he made disallowance Tribunal found that though

THE DCIT, CIRCLE-1 (1), , RAJKOT vs. M/S. DHRUV CRAFT MILL PVT. LTD., VILLAGE: - LILAPAR, TAL. & DIST. MORBI,

In the result, both the appeals filed by the Revenue are hereby dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 69 of the Income-tax Act, 1961 Undisclosed investments [Bogus purchases] - Assessment year 2005-06- Assessee was engaged in business of trading in finished fabrics - Assessing Officer found that concerned parties from whom material was purchased were not found at their addresses and held that purchases made by assessee were bogus Accordingly, he made disallowance Tribunal found that though

SHREE N H ENTERPRISES,RAJKOT vs. PCIT-1 RAJKOT, RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No. 227/Rjt/2025 िनधा"रण वष"/ Assessment Year: (2021-22) Shree N. H. Enterprises बनाम/ Pcit-1, D-101, Golden Portico Apartment, Dr. Income Tax Office, Vs. Madhapar Circle, Morbi Road, Rajkot- Rajkot-360007 360007 /. /. Pan/Gir No.: Adlfs7019K "थायीलेखासं जीआइआरसं (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) सुनवाई क" तारीख /Date Of Hearing : 07/10/2025 : 20/11/2025 घोषणा क" तारीख /Date Of Pronouncement

section 263 of the Act, to revise the assessment order should be quashed. 4 Shree N. H. Enterprises vs. PCIT 10. On the other hand, the Ld. DR for the revenue submitted that the assessing officer, disallowed 25% of bogus purchases, however, as per Ld. PCIT 100% purchases, which were bogus, should have been disallowed by the assessing officer, therefore

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

section 147 of the Act in the given facts and circumstances. Hence, the ground of appeal of the assessee is hereby dismissed. 8. The second issue raised by the assessee is that the ld. CIT(A) erred in confirming the addition made by the Assessing Officer in part being 25% of bogus purchases instead of deleting the same in entirety

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

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)

1,41,890.76 MT worth Rs.15,83,48,463/- was purchased from group concerns" namely, M/s Terapanth Foods Ltd and M/s Nidhi Mining during the year. The assessing officer, on the basis of the observation of the Special Auditor, called upon the assessee to explain the reason as to why the purchases from Terapanth Foods Ltd, has been made

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)

1,41,890.76 MT worth Rs.15,83,48,463/- was purchased from group concerns" namely, M/s Terapanth Foods Ltd and M/s Nidhi Mining during the year. The assessing officer, on the basis of the observation of the Special Auditor, called upon the assessee to explain the reason as to why the purchases from Terapanth Foods Ltd, has been made

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)

1,41,890.76 MT worth Rs.15,83,48,463/- was purchased from group concerns" namely, M/s Terapanth Foods Ltd and M/s Nidhi Mining during the year. The assessing officer, on the basis of the observation of the Special Auditor, called upon the assessee to explain the reason as to why the purchases from Terapanth Foods Ltd, has been made

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)

1,41,890.76 MT worth Rs.15,83,48,463/- was purchased from group concerns" namely, M/s Terapanth Foods Ltd and M/s Nidhi Mining during the year. The assessing officer, on the basis of the observation of the Special Auditor, called upon the assessee to explain the reason as to why the purchases from Terapanth Foods Ltd, has been made

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)

1,41,890.76 MT worth Rs.15,83,48,463/- was purchased from group concerns" namely, M/s Terapanth Foods Ltd and M/s Nidhi Mining during the year. The assessing officer, on the basis of the observation of the Special Auditor, called upon the assessee to explain the reason as to why the purchases from Terapanth Foods Ltd, has been made

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)

section 250 of the Income Tax Act, 1961; in short “the Act”. I.T.A No. 258/Rjt/2022 A.Y. 2011-12 Page No 2 M/s. Premji Valji & Sons (Jewellers) Pvt. Ltd. vs. DCIT 2. The assessee has raised the following grounds of appeal: “1. The CIT(A) erred in confirming the reopening of the assessment. The confirmation of the reopening is not justified

DHRUV PRINT PACK INDUSTRIES,MORBI vs. PR. CIT, RAJKOT-1, RAJKOT, RAJKOT

purchase and sales made by him during the year under consideration is not sufficient to claim these unaccounted receipts as business receipts. Therefore, ld. PCIT observedthat excess stock found during the survey and admitted by the assessee, as its income earned during that year, should be treated, as deemed income in view of the provisions of section

HETALKUMAR PRAVINCHANDRA RAJYAGURU,RAJKOT vs. PR. CIT, RAJKOT-1, RAJKOT, RAJKOT

purchase\nand sales made by him, during the year under consideration. Such\nexplanation of the assessee, which is not backed by any corroborative\nevidence, was not accepted by ld PCIT. The ld PCIT also noticed that\nmerely saying that the noting in the note book were unaccounted\npurchase and sales made by him during the year under consideration is\nnot

M/S. DHRUV CRAFT MILL PVT. LTD.,MORBI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAJKOT

purchase\nand sales made by him, during the year under consideration. Such\nexplanation of the assessee, which is not backed by any corroborative\nevidence, was not accepted by ld PCIT. The ld PCIT also noticed that\nmerely saying that the noting in the note book were unaccounted\npurchase and sales made by him during the year under consideration is\nnot

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

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

purchase and sales made by him during the year under consideration is not sufficient to claim these unaccounted receipts as business receipts. Therefore, ld. PCIT observedthat excess stock found during the survey and admitted by the assessee, as its income earned during that year,should be treated, as deemed income in view of the provisions of section