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

Section 131 of the Act had evidentiary value. The learned CIT(A) was convinced with the explanation of the assessee that the entire purchases could not be disallowed as being bogus noting the fact that being a trader and the sales having not been doubted, there was no question of corresponding purchases in relation to the said sales having

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

bogus as entire quantity of opening stock, purchases and the quantity 8 Shree N. H. Enterprises vs. PCIT manufactured during the year under consideration were sold by the assessee. In that view of the matter, not the entire amount, but the profit margin embedded in such amount would be subjected to tax. Therefore, we note that in the course

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)

20-09-2023 Date of pronouncement : 03-11-2023 आदेश/ORDER PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:- These two appeals are filed by the Revenue as against the two separate appellate orders both dated 31.05.2022 passed by the Commissioner of Income Tax (Appeals-11, Ahmedabad arising out of the reassessment order passed under section 143 r.w.s. 147 of the Income

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)

20-09-2023 Date of pronouncement : 03-11-2023 आदेश/ORDER PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:- These two appeals are filed by the Revenue as against the two separate appellate orders both dated 31.05.2022 passed by the Commissioner of Income Tax (Appeals-11, Ahmedabad arising out of the reassessment order passed under section 143 r.w.s. 147 of the Income

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

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

20,49,99,184/- by following decision of Vijay Proteins Ltd. the Hon'ble Supreme Court vide order dated 06/04/2015 disallowance bogus Purchases against the same we would like to submit as under:- We would like to mentioned that in your earlier show cause notice you have pointed out to submit documents for purchase where we have submitted the complete

THE ITO, WARD-4,, MORBI vs. M/S RAIYANI COTTON INDUSTRIES,, MORBI

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Pradip Kumar Kedia & Ms. Madhumita Royआयकर अपील सं./I.T.A No. 129/Rjt/2016 ("नधा"रण वष" / Assessment Years: 2011-12)

bogus loans/deposits received from four different parties. 6. On the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the addition u/s. 40A(3) made by AO being purchase of kapas from different parties of total Rs. 5,00,000/-. 7. On the facts and circumstances of the case

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

bogus purchases, that is, cash received from the suppliers against purchase claimed in the books of account. ACIT Vs. Expert Particle Board and Others ITA No.139 /RJT/2021 and 142/RJT/2021 (AY : 2019-20) with CO No.05/RJT/2022 17 23. Before the learned CIT (A), the assessee submitted that the statement of Shri Bhupendra Balubhai Patel recorded u/s 133A

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

bogus purchases, that is, cash received from the suppliers against purchase claimed in the books of account. ACIT Vs. Expert Particle Board and Others ITA No.139 /RJT/2021 and 142/RJT/2021 (AY : 2019-20) with CO No.05/RJT/2022 17 23. Before the learned CIT (A), the assessee submitted that the statement of Shri Bhupendra Balubhai Patel recorded u/s 133A

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

In the result, appeal of the assessee is allowed

purchase is bogus or not is also the subject matter of appeal before Ld. CIT(Appeals). It is well-settled law that once the proceedings are before Ld. CIT(Appeals) in respect of certain issues, then the same issue again cannot be re-agitated by taking recourse to proceedings under section 263 of the Act as held in the case

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

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini. आयकरअपीलसं./Ita No.215/Rjt/2025 "नधा"रणवष" / Assessment Year: (2015-2016) Nishant Parekh – Legal Heir Of Vs. Income Tax Officer Mina Parekh Aaykar Bhavan 322 Madhav Square, Opp 361001, Gujrat Avantika Complex, Limda Lane Road, Gujrat-361001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aanpp9471F (Appellant) (Respondent)

section 10(38) of the Act. The assessing officer, nowhere, in the assessment order, stated that these documentary evidences, submitted by the assessee, are bogus. 17. We note that there are three conditions to claim exemption u/s 10(38) of the Act viz: (i) Shares were purchased via Account Payee Cheque-For that the copy of bank statements reflecting

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

section 69, towards purchase of raw material and manufacturing expenditure in relation to the said unaccounted sales. The addition is duly supported by factual findings of the search action, as discussed in detail in the preceding paragraphs. Inparticular, the following evidence brings out that the corresponding purchase of raw material (and consequently the manufacturing expenditure related thereto) were also

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

section 69, towards purchase of raw material and manufacturing expenditure in relation to the said unaccounted sales. The addition is duly supported by factual findings of the search action, as discussed in detail in the preceding paragraphs. Inparticular, the following evidence brings out that the corresponding purchase of raw material (and consequently the manufacturing expenditure related thereto) were also

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

section 69, towards purchase of raw material and manufacturing expenditure in relation to the said unaccounted sales. The addition is duly supported by factual findings of the search action, as discussed in detail in the preceding paragraphs. Inparticular, the following evidence brings out that the corresponding purchase of raw material (and consequently the manufacturing expenditure related thereto) were also

M/S MGM TRADELINK PVT. LTD.,,GANDHIDHAM vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM

In the result, the appeal of the assessee is partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedआयकर अपील सं./Ita No. 974/Rjt/2010 िनधा"रण वष"/Asstt. Year: 2005-2006

20,000 in cash in contravention to the provisions of section 40A(3) of the Act read with rule 6DD of Income Tax Rules. 11.1 From the preceding discussion we note that there are contradictory statements furnished by the assessee and his Ld. counsel viz a viz confirmation filed by the supplier. It is an undisputed fact that the assessee

PRITIBEN JAGDISHBHAI MEHTA,RAJKOT vs. THE PR. COMMISSIONER OF INCOME TAX-1, RAJKOT, RAJKOT

In the result, appeal filed by the assessee is allowed

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

section 10(38) of the Act. The assessing officer, nowhere, in the assessment order, stated that these documentary evidences, submitted by the assessee, are bogus. 17. We note that there are three conditions to claim exemption u/s 10(38) of the Act viz: (i) Shares were purchased via Account Payee Cheque-For that the copy of bank statements reflecting

THE ITO, WARD-3(2),, JAMNAGAR vs. SHRI RAJESH GULABRAI SHAYANI,, JAM-KHAMBHALIA

In the result, the appeal of the Revenue is dismissed

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

20,62,542/- i.e. 0.75% of total turnover. As discussed the assessee has not produced the books of accounts therefore the learned AO has made efforts to verify the trading [transactions of the assessee from Sales Tax Department. The Deputy Sales Tax Commissioner (Investigation), Dep. - 7, Rajkot vide his letter No. STO(l)/INV/Dep. 7/RAJ/2010-11 dated Nil, has informed that

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

Bogus Total Income @ Sales Purchases 8.0% 1 2013-14 5,01,82,334 - 5,01,82,334 40,14,587 2 2015-16 6,67,76,311 - 6,67,76,311 53,42,105 3 2018-19 7,73,95,498 6,22,25,000 13,96,20

CLASSIC NETWORK PRIVATE LIMITED,RAJKOT vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL - 1, RAJKOT, RAJKOT

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

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

Bogus Total Income @ Sales Purchases 8.0% 1 2013-14 5,01,82,334 - 5,01,82,334 40,14,587 2 2015-16 6,67,76,311 - 6,67,76,311 53,42,105 3 2018-19 7,73,95,498 6,22,25,000 13,96,20