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)

Section 69 of the Income-tax Act, 1961 Undisclosed investments [Bogus purchases] - Assessment year 2005-06- Assessee was engaged in business of trading in finished fabrics - Assessing Officer found that concerned parties from whom material was purchased were not found at their addresses and held that purchases made by assessee were bogus Accordingly, he made disallowance Tribunal found that though

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)

Section 69 of the Income-tax Act, 1961 Undisclosed investments [Bogus purchases] - Assessment year 2005-06- Assessee was engaged in business of trading in finished fabrics - Assessing Officer found that concerned parties from whom material was purchased were not found at their addresses and held that purchases made by assessee were bogus Accordingly, he made disallowance Tribunal found that though

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

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

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

section 263 of the Act and solely on the ground that the purchases made by the assessee were bogus, and therefore, entire addition should be made in the hands of the assessee in respect of bogus purchases instead of 25% addition made by the AO on account of bogus purchases, which is not acceptable, because only profit element embedded

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)

bogus purchases from M/s Nazar Impex Pvt. Ltd. Undisputedly, the report from the investigation wing is a tangible material which was not available to the Assessing Officer during the I.T.A No. 258/Rjt/2022 A.Y. 2011-12 Page No 5 M/s. Premji Valji & Sons (Jewellers) Pvt. Ltd. vs. DCIT proceedings carried out on the earlier occasions. The Hon’ble Gujarat High Court

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.

5(2) and Section 9(1)(i) of the Act, such income is not deemed to accrue or arise in India. Accordingly, it is not taxable in India. For that reliance is placed on the following judgements of the Hon`ble Supreme Court. (i)CIT v. Toshoku Ltd. (1980) 125 ITR 525 (SC): Commission earned by non- resident agents

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

bogus purchase. 3. It is therefore, prayed that the order of the Ld. CIT(A) be set aside and that of the AO be restored to the above extent. 4. The finding of the AO and the addition made by the AO may be upheld in toto 5. The appellant craves leave to add, amend, alter OR withdraw

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

VIJAY ANANDBHAI CHAVDA,GONDAL vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAJKOT , RAJKOT

In the result, the order passed by the PCIT u/s 263 of the Act is hereby dismissed

Bench: Ms. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

5% of purchase Section not mentioned by the A.O. 4. 1,34,27,150/- Bogus Liability as Section not advance

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 purchase of Rs. 2,00,000/- from Alpha Entech (Guj) and 52,04,130/- from Anuradha Oil, Mumbai, totaling to Rs. 54,04,130/-. 7.In this regard, the reply was submitted by assessee that the above transaction is not related to M/s. Expert Particle Board. ACIT Vs. Expert Particle Board and Others ITA No.139 /RJT/2021 and 142/RJT/2021

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 purchase of Rs. 2,00,000/- from Alpha Entech (Guj) and 52,04,130/- from Anuradha Oil, Mumbai, totaling to Rs. 54,04,130/-. 7.In this regard, the reply was submitted by assessee that the above transaction is not related to M/s. Expert Particle Board. ACIT Vs. Expert Particle Board and Others ITA No.139 /RJT/2021 and 142/RJT/2021

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

Bogus Total Income @ Sales Purchases 8.0% 1 2013-14 5,01,82,334 - 5,01,82,334 40,14,587

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

Bogus Total Income @ Sales Purchases 8.0% 1 2013-14 5,01,82,334 - 5,01,82,334 40,14,587

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

Bogus Total Income @ Sales Purchases 8.0% 1 2013-14 5,01,82,334 - 5,01,82,334 40,14,587

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

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

Bogus Total Income @ Sales Purchases 8.0% 1 2013-14 5,01,82,334 - 5,01,82,334 40,14,587

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

Bogus Total Income @ Sales Purchases 8.0% 1 2013-14 5,01,82,334 - 5,01,82,334 40,14,587