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

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

SHAMJI NATHU VAISHYA,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

SOHAM PAPERS PRIVATE LIMITED,MORBI 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

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

CHUNILAL GOVIND VANIK,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

KISHOR VELJIBHAI FOFANDI,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

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

BHARATKUMAR KALYANJIBHAI BHINDI,JUNAGADH vs. PCIT, 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

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

Bogus Purchase and rendering the said purchase transactions to be unexplained. 3. The learned PCIT has erred in law vide para 9 and 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

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

MISS PARI ANIL GANDHI, RAJKOT,RAJKOT vs. THE PR. CIT-1, RAJKOT, RAJKOT

142 taxmann.com 247, held that where\nAssessing Officer noted that assessee had indulged in scrip of shell company\nand had claimed long term capital gain on sale of shares and made addition\nunder section 68 holding that entire transaction was bogus and in the nature of\npenny stock, however, since genuineness of investment in shares by assessee\nwas substantiated

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

section 143(3) of the Income Tax Act, 1961 (“the Act” for short). 2.Since the issue involved in all these appeals of Revenue and the Cross Objection of the assessee, are identical and common, therefore, all these appeals have been clubbed and heard together and a consolidated order is being passed for the sake of convenience and brevity

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

section 143(3) of the Income Tax Act, 1961 (“the Act” for short). 2.Since the issue involved in all these appeals of Revenue and the Cross Objection of the assessee, are identical and common, therefore, all these appeals have been clubbed and heard together and a consolidated order is being passed for the sake of convenience and brevity

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

bogus. 7.However, ld. Pr. CIT rejected the above submissions of the assessee and observed that in case of some of the suppliers, the GST registrations were cancelled therefore, this leads to conclusion that the genuineness of transactions with supplier is not proved. The ld. PCIT held that the assessment order passed Ketan Gori Vs. ITO ITA No.42 /RJT/2025

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)

142 taxmann.com 247, held that where Assessing Officer noted that assessee had indulged in scrip of shell company and had claimed long term capital gain on sale of shares and made addition under section 68 holding that entire transaction was bogus and in the nature of penny stock, however, since genuineness of investment in shares by assessee was substantiated

KUMAR RAMESH SAHU,RAJKOT, GUJARAT vs. ACIT, CIRCLE-2(2), RAJKOT, RAJKOT, GUJARAT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./I.T.A. No.336/Rjt/2023 (िनधा"रण वष" / Assessment Year : 2009-10) Kumar Ramesh Sahu बनाम/ The Acit, Sundaram, 72/3, New Cirtcle-2(3) Vs. College Wadi Rajkot – 60 001 150Ft5. Ring Road Opp. Meera Apartment Rajkot – 360 005 (Gujarat) "ायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aesps 5531 C (अपीलाथ" /Appellant) (""थ" / Respondent) .. Assessee By : Shri M.N. Manvar, Ld. Ar Revenue By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr सुनवाई की तारीख / Date Of Hearing 13/01/2025 घोषणा की तारीख /Date Of Pronouncement 04/04/2025 आदेश / O R D E R Per Dinesh Mohan Sinha:

purchase of Gold Bar dtd. 25/12/1985 is bogus and to treat sale proceed of Gold Bar as income from undisclosed sources. Further, CITA)-NFAC observed that sale bill is for sale of gold bar, whereas as per Wealth Tax Return the items shown are gold ornaments and the Appellant did not file copy of Valuation Report at any stage