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

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)

4. The order passed by the Ld. FAO as well as order passed by National Faceless Appeal Centre under Section 250 is bad in law as well as on facts as the order is passed without dealing with all the facts brought on the records by the assessee which is duly backed by the genuine third party evidences, which

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)

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

ASSISTANT COMMISSIONER OF INCOME TAX, GANDHIDHAM vs. KAMLESH DEORAJ JAIN, GANDHIDHAM

In the result, the appeal of the Revenue is dismissed

Bench: Dr. Arjun Lal Saini, Am. & Dr. Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 594/Rjt/2025 "नधा"रणवष" / Assessment Year: (2017-18) (Hybrid Hearing) Assistant Commissioner Of Income Vs. Kamlesh Deoraj Jain, Tax, Bbz-N-108, Khanna Market, Plot No. 20/A, Sector No. 8, Gandhidham, Gandhidham Gandhidham Gujarat 370201 Gujarat 370201 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Adopj1769Q (Appellant) (Respondent) Appellant By : Shri Sunil Maloo, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 01 / 12 /2025 Date Of Pronouncement : 21/ 01 /2026

section 250 of the Income Tax Act, 1961 by National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income Tax (Appeals), dated 07/07/2025, which in turn arises out of an order passed by the Assessing Officer u/s 147 of the I.T. Act, on dated 30/03/2025. ACIT vs. Kamlesh Deoraj Jain The Grounds of appeal raised by the assessee are as follows

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

The appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 196/Rjt/2025 ("नधा"रणवष"/Assessment Year: (2012-13) Nishant Parekh – Legak Heir Of Mina Income Tax Officer, Wd – 1(3), Parekh Vs. Aayakar Bhavan, 322, Madhav Square, Opp. Avantika Jamnagar – 361001 Complex, Limda Lane Road, Jamnagar – 361001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aanpp9471F (अपीलाथ"/Assessee) (""यथ"/Respondent)

250/- Security Transaction Tax 20.56/- Shares Transaction Expense 7777.80 Total 1,65,048.36/- The assessee submitted copy of contract note received from M/s Sharukh N. Tara, vide paper book page no.14 to 15.Immediately after purchasing the shares a request letter regarding demat account details was duly sent to assessee by the Broker M/s. Sharukh N. Tara which is placed

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

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

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

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.

purchase details, ledger accounts of various expenses etc., which were placed on records. The Books of Accounts along with bills and vouchers were produced by the assessee. 4. During the assessment proceedings, the assessing officer observed that the assessee has debited foreign commission expenses of Rs. 12,13,74,525/- to its Profit & Loss Account for AY 2012-13. Hence

KAUSHALIYA SAMPATLAL DUDANI,JAMNAGAR vs. INCOME TAX OFFICER, WARD 2(6), JAMNAGAR

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./ Ita No.659/Rjt/2025 िनधा"रण वष"/Assessment Year :2012-2013 Kaushaliya Sampatlal Dudani The Ito, Ward-2(6), बनाम/ K-1/79/4 G.I.D.C., Shanker Ayakar Bhawan, Jamnagar Vs Tekri, Udyognagar, Jamnagar Jamnagar. Gujarart-361005 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Abnpd8662P (अपीलाथ"/Appellant) (""थ"/Respondent) िनधा"रती की ओर से/Assessee By : Shri Sagar Shah, Ld. Ar राज" की ओर से/Revenue By : Shri Abhimanyu Singh, Ld. Sr-Dr

section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income-tax (Appeals), dated 15.08.2025, which in turn arises out of an assessment order passed by the Assessing Officer u/s 147 of the Act, on 22.09.2021. 2. At the outset, ld. Counsel for the assessee, submitted that issue

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)

250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income-tax (Appeals), dated 06/02/2025, which in turn arises out of an order passed by the Assessing Officer dated 25/03/2022, u/s 147 r.w.s144B of the Income Tax Act, 1961. Nishant Parekh – Legal Heir of Mina Parekh 2. When this

BHAVESHBHAI HARIBHAI KANANI,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee is partially allowed in above terms

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.233/Rjt/2025 िनधा"रण वष"/Assessment Year : 2018-19 बनाम/ Bhaveshbhai Haribhai Kanani Income Tax Officer Plot No. E211, Gidc Phase-2, Vs Ward – 2(10), Jamnagar Dared, Jamnagar, Gujarat - 361008 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Acypk5085F (अपीलाथ"/Appellant) (""थ"/Respondent)

250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income-tax (Appeals) (‘CIT(A)’), dated 19.11.2024, which in turn arises out of an assessment order passed by Assessing Officer u/s. 143(3) r.w.s. 144B of the Act, on 20.04.2021. Bhaveshbhai Haribhai Kanani vs. ITO 2. The appeal filed

TALSHIBHAI KANJIBHAI NAROLA,DAMNAGAR vs. THE ITO WD 3(1)(4), RKT, AMRELI-RAJKOT

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

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

section 147 r.w.s. 144B of the Income Tax Act, 1961 (in short “the Act”), vide order dated 22.03.2023. Talsibhai K. Narola 2. Grounds of appeal raised by the assessee are as follows: 1. The learned Commissioner (Appeals), National Faceless Appeal Centre (NFAC), Delhi erred in dismissing the appeal of the Appellant ex-parte, by failing to appreciate that the Appellant

ITO WARD 3(1)(4), RAJKOT-STATION- AMRELI, AMRELI, GUJARAT vs. AVADH AGRI EXPORTS, AMRELI, GUJARAT

In the result, appeal filed by the revenue is dismissed

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

250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) by the Learned Commissioner of Income Tax (Appeals)-11, Ahmedabad, dated 08.09.2025, which, in turn, arises out of an assessment order passed by the Assessing Officer (AO) u/s 143(3) of the Act, dated 27.03.2015. 2. The grounds of appeal raised by the Revenue are as under

JITENDRABHAI DEVAJIBHAI BODAR,RAJKOT vs. INCOME TAX OFFICER, WARD-2(1)(1), RAJKOT, RAJKOT

In the result, the appeal is dismissed as not admitted”

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

250 of the Act, by the Learned Commissioner of Income Tax(Appeals), National Faceless Appeal Centre, Delhi, dated 16.07.2025, which in turn arises out of an assessment order passed by Assessing Officer u/s 147 r.w.s. 144 of the Income Tax Act, 1961, vide order dated 10.09.2021 2. Grounds of appeal raised by the assessee, are as follows: “1. The grounds

SAPNA NAINESH JATANIA,RAJKOT vs. INCOME TAX OFFICER, WARD 1(1), JAMNAGAR, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini

250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income-tax (Appeals), dated 10/03/2025, which in turn arise out of separate assessment orders passed by the Assessing Officer, u/s 144 r.w.s. 147 of the Income Tax Act, 1961. ITA NO. 449 & 469/RJT/2025 Sapna Nainesh Jatania, 2. Both these

SAPNA NAINESH JATANIA,RAJKOT vs. INCOME TAX OFFICER, WARD 1(4), DWARKA, DWARKA

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

Bench: Dr. Arjun Lal Saini

250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income-tax (Appeals), dated 10/03/2025, which in turn arise out of separate assessment orders passed by the Assessing Officer, u/s 144 r.w.s. 147 of the Income Tax Act, 1961. ITA NO. 449 & 469/RJT/2025 Sapna Nainesh Jatania, 2. Both these

OSWAL PETROCHEM,GANDHIDHAM vs. DCIT, CC-1, RAJKOT, RAJKOT

In the result, all these appeals filed by the different assessees, are allowed for

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrids Hearing) आयकर अपीलसं./Ita No.400/Rjt/2023

250 of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'), which in turn arise out of separate assessment orders passed by the Assessing Officer u/s 143(3) of the Income Tax Act, 1961. 2. Since, the issues involved in all the appeals are common and identical; therefore, these appeals have been heard together and are being disposed

PRIYANSI CORPORATION,DIST RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

In the result, all these appeals filed by the different assessees, are allowed for

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrids Hearing) आयकर अपीलसं./Ita No.400/Rjt/2023

250 of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'), which in turn arise out of separate assessment orders passed by the Assessing Officer u/s 143(3) of the Income Tax Act, 1961. 2. Since, the issues involved in all the appeals are common and identical; therefore, these appeals have been heard together and are being disposed