LATE SMT. PRITI A. GANDHI L/R. SHRI ANILBHAI A. GANDHI, RAJKOT,RAJKOT vs. THE PR. CIT-1, RAJKOT, RAJKOT

bogus loss was to be deleted\"\n(iii).Shri Ambalal Chimanlal Patel,[2024] 162 taxmann.com 892 (Gujarat)\n“Where assessee purchased shares of a company when trading of said company was\nsuspended and sold same and claimed exemption under section 10(38), in absence of\nany material brought on record to suggest that purchase and sale of said shares

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

10 of his Order by invoking Section 263 of the Act rendering the Assessment Order passed by the Ld. AO to be erroneous and prejudicial to the interest of the revenue. 4. Brief facts of the Case that the appellant is a Private Company and had filed Income Tax Return for the AY 2013-14 declaring total income

BABUBHAI KANJIBHAI SAKARIYA LEGAL HEIR OF LATE SMT. UJIBEN KANJIBHAI SAKARIYA,JETPUR vs. ITO WARD 1(2)(1), RAJKOT, RAJKOT

In the result, the appeal filed by the assessee is allowed

10(38), in\nabsence of any material brought on record to suggest that purchase and sale of\nsaid shares was bogus, Assessing Officer was not justified in making addition of\nsale proceeds of shares under section 68\"\n24.\nOur view is further fortified by the judgement of the Hon'ble High Court of\nCalcutta in the case of Kaushalya Dealers

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

10 1 of the assessment order. The contentions raised by the appellant during the appellate proceedings are rejected, on similar grounds, being devoid of merit. On the given facts, I do not find any reason, whatsoever, to interfere with the additions made by the AO in the assessment order, primarily on thebasis of the factual findings, emanating from the search

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

10 1 of the assessment order. The contentions raised by the appellant during the appellate proceedings are rejected, on similar grounds, being devoid of merit. On the given facts, I do not find any reason, whatsoever, to interfere with the additions made by the AO in the assessment order, primarily on thebasis of the factual findings, emanating from the search

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

10 has held that “file containing loose sheets or papers are not books” and hence entry therein are not admissible u/s. 34 of the Evidence Act, 1872. Similarly, in the present case, the impounded material having certain entries in the name of the partners, which was presumed as unaccounted investment, is not corroborated with any independent materials and entries therein

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

10 has held that “file containing loose sheets or papers are not books” and hence entry therein are not admissible u/s. 34 of the Evidence Act, 1872. Similarly, in the present case, the impounded material having certain entries in the name of the partners, which was presumed as unaccounted investment, is not corroborated with any independent materials and entries therein

BHIKHALAL PRAHLADRAI AGARWAL HUF,GANDHIDHAM vs. ASSISTANT COMMISSIONER OF INCOME TAX GANDHIDHAM CIRCLE, GANDHIDHAM

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos.779&780/Rjt/2024 ("नधा"रण वष" / Assessment Years: 2011-12 & 2016-17) Bhikhalal Prahaladrai Agarwal- Vs. Assistant Commissioner Of Income Tax, Huf, Gandhidham Circle C/O. Sarda & Sarda, Sakar, 1St It Office, Plot No. 32, Sector No. 3, Near Floor, Dr. Radha-Krishnan Road, Iffco Colony, Gandhidham Opp. Rajkumar College Rajkot Gandhidham - 370201 Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabha4638R (Assessee) (Respondent) Assessee By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 05/06/2025 Date Of Pronouncement : 21/08/2025

bogus long-term capital gain, exempt u/s 10(38) and the assessee was one of the beneficiaries who allegedly received Rs.27,05,802/-, on the sale of shares of the said penny stock. Since the assessee had shown a long-term capital gain of 17,33,289/- in their return of income, the A.O. formed an opinion that the said

BHIKHALAL PRAHALADRAI AGARWAL HUF,GANDHIDHAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, GANDHIDHAM CIRCLE, GANDHIDHAM

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos.779&780/Rjt/2024 ("नधा"रण वष" / Assessment Years: 2011-12 & 2016-17) Bhikhalal Prahaladrai Agarwal- Vs. Assistant Commissioner Of Income Tax, Huf, Gandhidham Circle C/O. Sarda & Sarda, Sakar, 1St It Office, Plot No. 32, Sector No. 3, Near Floor, Dr. Radha-Krishnan Road, Iffco Colony, Gandhidham Opp. Rajkumar College Rajkot Gandhidham - 370201 Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabha4638R (Assessee) (Respondent) Assessee By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 05/06/2025 Date Of Pronouncement : 21/08/2025

bogus long-term capital gain, exempt u/s 10(38) and the assessee was one of the beneficiaries who allegedly received Rs.27,05,802/-, on the sale of shares of the said penny stock. Since the assessee had shown a long-term capital gain of 17,33,289/- in their return of income, the A.O. formed an opinion that the said

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

10 1 of the assessment order. The contentions raised by the\nappellant during the appellate proceedings are rejected, on similar grounds, being\ndevoid of merit. On the given facts, I do not find any reason, whatsoever, to interfere\nwith the additions made by the AO in the assessment order, primarily on thebasis of\nthe factual findings, emanating from the search

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

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

26. Brief facts qua the issue as per lead case in ITA No. 177/RJT/2024, are as follows: Initial comments of the assessing officer in the assessment order reads as follows: “In this case, assessment order was passed on 28.03.2023 and assessment order was issued and served to assessee, vide Din & order No.ITBA/AST/S/147/2022- 23/1051608029(1), dated

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

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

26. Brief facts qua the issue as per lead case in ITA No. 177/RJT/2024, are as follows: Initial comments of the assessing officer in the assessment order reads as follows: “In this case, assessment order was passed on 28.03.2023 and assessment order was issued and served to assessee, vide Din & order No.ITBA/AST/S/147/2022- 23/1051608029(1), dated

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

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

26. Brief facts qua the issue as per lead case in ITA No. 177/RJT/2024, are as follows: Initial comments of the assessing officer in the assessment order reads as follows: “In this case, assessment order was passed on 28.03.2023 and assessment order was issued and served to assessee, vide Din & order No.ITBA/AST/S/147/2022- 23/1051608029(1), dated

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

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

26. Brief facts qua the issue as per lead case in ITA No. 177/RJT/2024, are as follows: Initial comments of the assessing officer in the assessment order reads as follows: “In this case, assessment order was passed on 28.03.2023 and assessment order was issued and served to assessee, vide Din & order No.ITBA/AST/S/147/2022- 23/1051608029(1), dated

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

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

26. Brief facts qua the issue as per lead case in ITA No. 177/RJT/2024, are as follows: Initial comments of the assessing officer in the assessment order reads as follows: “In this case, assessment order was passed on 28.03.2023 and assessment order was issued and served to assessee, vide Din & order No.ITBA/AST/S/147/2022- 23/1051608029(1), dated

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

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

26. Brief facts qua the issue as per lead case in ITA No. 177/RJT/2024, are as follows: Initial comments of the assessing officer in the assessment order reads as follows: “In this case, assessment order was passed on 28.03.2023 and assessment order was issued and served to assessee, vide Din & order No.ITBA/AST/S/147/2022- 23/1051608029(1), dated

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

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

26. Brief facts qua the issue as per lead case in ITA No. 177/RJT/2024, are as follows: Initial comments of the assessing officer in the assessment order reads as follows: “In this case, assessment order was passed on 28.03.2023 and assessment order was issued and served to assessee, vide Din & order No.ITBA/AST/S/147/2022- 23/1051608029(1), dated

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

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

26. Brief facts qua the issue as per lead case in ITA No. 177/RJT/2024, are as follows: Initial comments of the assessing officer in the assessment order reads as follows: “In this case, assessment order was passed on 28.03.2023 and assessment order was issued and served to assessee, vide Din & order No.ITBA/AST/S/147/2022- 23/1051608029(1), dated