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

bogus purchases made by several concerns which included the names of beneficiaries alongwith scanned copies of statements recorded under Section 131 of the Income-tax Act, 1961 (“the Act)” for short), of 201

THE DY. COMMR. OF INCOME TAX, CIR.-3(1), RAJKOT-GUJARAT vs. M/S. SONPAL EXPORTS PVT. LTD., RAJKOT-GUJARAT

In the result, appeal filed by the revenue is dismissed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 29/Rjt/2018 "नधा"रणवष" / Assessment Year: (2012-13) (Hybrid Hearing) The Dcit, Circle – 3(1), Vs. M/S. Sonpal Exports Pvt. Ltd. Rajkot Aayakar Bhavan, Room Dhari Bagsara Road, Nr. Ice No. 114, 1St Floor, Race Course Factory, Amreli Ring Road, Rajkot Pan No.: Aajcs0177N (Assessee) (Respondent) Assessee By : Shri Kalpesh Doshi, Ld. Ar Respondent By : Shri Praveen Verma, Ld. Cit(Dr) Date Of Hearing : 24/06/2025 Date Of Pronouncement : 21/08/2025 आदेश / O R D E R Per, Dr. Arjun Lal Saini, Am; By Way Of This Appeal, The Revenue, Has Challenged Correctness Of The Order Dated 16.11.2017, Passed By The Learned Cit(A), In The Matter Of Assessment Under Section 143(3) Of The Income Tax Act 1961, For The Assessment Year 2012-13. Grievances Raised By The Revenue, Which Are Interconnected & Will Be Taken Up Together, Are As Follows: “1. On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Deleting The Addition Of Rs. 13,96,33,023/- Holding That Provision Of Section 195 Will Not Be Applicable. 2. On The Facts Of The Case & In Law, The Ld. C.I.T. (A) Erred In Ignoring The Facts That The Assessee Has Failed To Prove The Genuineness Of Foreign Commission Expenses Before The A.O. 3. It Is, Therefore, Prayed That The Order Of The C.I.T. (A) May Be Set Aside & That Of The A.O. Be Restored To The Above Extent. Dcit Vs. M/S. Sonpal Export Pvt. Ltd.

bogus. 19.About the second issue, which is regarding applicability of section 40(a)(ia) of the Act, in respect of these commission payments, the ld. CIT(A) noted that there is no doubt that all these foreign agents are not residents and are not having business connection in India. There is also no doubt that they have rendered services

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)

201, VarajResidency, 8 – Patel Colony, Income Tax, Gujarat – 361008 Aayakar Bhavan, Lal Wadi Main Road, Kaushal Nagar, Gujarat – 361110 "ायीलेखासं./जीआइआरसं./PAN/GIR.: AEFPV6723A (Appellant) (Respondent) Appellant by : Shri Sagar Shah, Ld. AR Respondent by : Shri Sanjay Kumar, Ld. CIT(DR) Date of Hearing : 19/06/2025 Date of Pronouncement : 05/08/2025 आदेश / O R D E R PER DINESH MOHAN SINHA, JM: Captioned

SHRI SHAMJIBHAI SADHABHAI KANGAD,GANDHIDHAM-KUTCH vs. THE DCIT CENTRAL CIRCLE-1 , RAJKOT

bogus purchase is\ncompletely illogical. The averments made by Shri Naran Maheshwari in his\nstatement was clarified by him in his duly sworn affidavit. Here it is relevant to\nemphasise that salt procurement and manufacturing industries by and large are\ndriven by the unorganised and unskilled labourers / agents and village people,\nstaying remotely in desert or forest there for they

THE DCIT CENTRAL CIRCLE-1 , RAJKOT vs. SHRI SHAMJIBHAI SADHABHAI KANGAD, GANDHIDHAM-KUTCH

In the result, appeal filed by the Revenue, in IT(SS) No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआ.(खो और ज).सं./It(Ss)A Nos.11 To 20/Rjt/2022 "नधा"रण वष"/ Assessment Years:2011-12 To 2020-21 बनाम/ Shri Shamjibhai Sadhabhai Deputy Commissioner Of Kangad Income Tax, Central Circle-1, Vs. Bbz-S-60, Zanda Chowk, “Amruta Estate”, 2Nd Floor, Gandhidham-370 201 M.G. Road, Rajkot-360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.:Adepk 3471 E (अपीलाथ"/Assessee) (""यथ"/Respondent) आ.(खो और ज).सं./It(Ss)A Nos.21 To 23/Rjt/2022 "नधा"रण वष"/ Assessment Years:2014-15, 2016-17 &2017-18 बनाम/ Deputy Commissioner Of Income Shri Shamjibhai Sadhabhai Tax, Central Circle-1, “Amruta Kangad Vs. Estate”, 2Nd Floor, M.G. Road, Bbz-S-60, Zanda Chowk, Rajkot-360001 Gandhidham-370 201 "थायीलेखासं./जीआइआरसं./Pan/Gir No.:Aabca 8202 E (अपीलाथ"/Assessee) (""यथ"/Respondent) आ.(खो और ज).सं./It(Ss)A Nos.15/Rjt/2023 "नधा"रण वष"/ Assessment Year:2019-20 बनाम/ Deputy Commissioner Of Shri Hetab Shamjibhai Kangad Income Tax, Central Circle-1, Bbz-South-60, Zanda Chowk, Vs. “Amruta Estate”, 2Nd Floor, Gandhidham-370 201 M.G. Road, Rajkot-360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.:Aqtpk 7484 M (अपीलाथ"/Assessee) (""यथ"/Respondent)

bogus purchase is completely illogical. The averments made by Shri Naran Maheshwari in his statement was clarified by him in his duly sworn affidavit. Here it is relevant to emphasise that salt procurement and manufacturing industries by and large are driven by the unorganised and unskilled labourers / agents and village people, staying remotely in desert or forest there for they

ACIT CIRCLE-1(1), RAJKOT, RAJKOT vs. GRENIC TILES PVT LTD, MORBI

The appeal of the assessee is allowed, whereas\nappeal of the revenue is dismissed

section 68 of the Act.\nReliance is further placed on the decision of the ITAT, Mumbai Bench in\nthe case of ITO vs. Surana Traders, (2005)93 TTJ 875: (2005)92 ITD 212,\nthe relevant observation of the Mumbai Bench are as under:\n\"So merely because for the reasons that the purchaser parties were not traceable, the\nassessee could

GRENIC TILES PRIVATE LIMITED,WANKANER-MORBI vs. ASST.COMMISSIONER OF INCOME-TAX CIRCLE 1(1) RKT, RAJKOT

The appeal of the assessee is allowed, whereas\nappeal of the revenue is dismissed

section 68 of the Act.\nReliance is further placed on the decision of the ITAT, Mumbai Bench in\nthe case of ITO vs. Surana Traders, (2005)93 TTJ 875: (2005)92 ITD 212,\nthe relevant observation of the Mumbai Bench are as under:\n\"So merely because for the reasons that the purchaser parties were not traceable, the\nassessee could

SMT. KRUSHNABA PRAVINSINH JADEJA,,RAJKOT-GUJARAT vs. THE DY. COMMR. OF INCOME TAX, CIR.-1(1),, RAJKOT-GUJARAT

201, 2nd\nFloor, Opera Tower, Jawahar Road,\nRajkot-360 001\n(Assessee)\n(Respondent)\nआयकर अपील सं./ITA No.577/RJT/2015\n(निर्धारण वर्ष / Assessment Year: 2012-13)\nDeputy Commissioner of Income Tax,\nCircle-1(1), Rajkot, Aaykar Bhavan, Race\nVs.\nKrushnaba Pravinsinh Jadeja,\nC.o. R.K. Shukla & Co.,\nCourse Ring Road, Rajkot-360 001\n201, 2nd Floor, Opera Tower,\nJawahar Road, Rajkot

THE DY. COMMR. OF INCOME TAX, CIR.-1(1), RAJKOT-GUJARAT vs. SMT. KRUSHNABA P. JADEJA,, RAJKOT-GUJARAT

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

201, 2nd Floor, Opera Tower, Course Ring Road, Rajkot-360 001 Jawahar Road, Rajkot-360001 "थायीलेखासं./जीआइआरसं./PAN/GIR No.: ACYPJ 6178 N (Assessee) (Respondent) Assessee by : Shri D.M. Rindani, Ld. AR Respondent by : Shri Sanjay Punglia, Ld. CIT-DR Date of Hearing : 03/06/2025 Date of Pronouncement : 30/07/2025 आदेश / O R D E R Per, Dr. A. L. Saini, AM: Captioned

SHREE BALAJI LUMBERS PRIVATE LIMITED,GANDHIDHAM vs. ACIT CIRCLE , GANDHIDHAM

In the result, the appeal of the assessee is allowed

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

201 PAN : AALCS 7866 C : (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रतीक"ओरसे/Assessee by : ShriChetan Agarwal, ld.AR राज"वक"ओरसे/Revenue by : Shri Abhimanyu Singh Yadav, Sr-DR सुनवाईक"तार"ख/Date of Hearing : 27/01/2025 घोषणाक"तार"ख/Date of Pronouncement : 23/04/2025 ORDER PERDR. ARJUN LAL SAINI, ACCOUNTANT MEMBER: Captioned appeal filed by the assessee, pertaining to Assessment Year